uniformity between the individual States adopting control programs; and the much greater period of time needed to enact and fully implement such a control system nationwide.

3. Federal-State Partnership. This is the control strategy which had been adopted by the Nation's major environmental pollution control statutes. The Federal Government would establish minimum Federal hazardous waste treatment and disposal standards; all States would be required to adopt these as minimum State standards within a specified time period. The States would bear the responsibility for establishing and administering EPA-approved State control programs. Functions could include operating a Statewide hazardous waste facility permit program; maintaining an inspection and monitoring force; enforcing statutory sanctions against violators; and filing program progress reports with EPA. As in the Federal air and water pollution control programs, States with approved implementation programs would be eligible for Federal financial assistance. For those States which fail to submit approved programs, or which do not enforce the Federal-State standards, back-up Federal enforcement powers could be exercised to ensure uniform compliance, or Federal program grant funds could be withheld. Provision could also be made for a Federallyadministered control and enforcement program for certain hazardous wastes determined to pose extremely severe hazards, an approach already utilized by the TEC for high-level radioactive wastes.

The major advantage of this control strategy stems from the well-established legislative precedents discussed earlier; land pollution control regulations employing this strategy would be capable of being fully integrated with existing controls over air and water pollution. Other advantages include utilizing the Federal Government's superior resources to set standards and design programs, while retaining the concept of State responsibility for what are traditionally recognized as State problems; minimal Federal involvement once the States' implementation programs are fully underway; uniform minimum national hazardous waste standards, with States retaining the power to set more stringent standards if local conditions so dictate; and reasonable assurance that the standards will be enforced ultimately by someone.

The disadvantages of the combined Federal-State hazardous waste control strategy involve its potential for delay in final implementation, since States can be expected to demonstrate varying degrees of readiness and interest in gearing up State machinery to run their respective control programs. The major drawback to this approach, however, involves its potential for large expendi

tures of Federal manpower and funds, should the States choose to sit back and "let the Feds do it"; even worse is the possibility that Federal standards for hazardous waste control will be completely unenforced in laggard States simply because of the lack of adequate funds to exercise the "reserve" powers mentioned above. This problem seems capable of resolution, however, if adequate incentives for State action are made available (Federal grants or technical assistance) and if significant disincentives are applied (withholding air and water program grant funds; characterizing the State as "irresponsible", etc.).

Summary

The earlier parts of this section described the gap in Federal and State hazardous waste management legislation, a gap in which if not filled soon by Congress' adoption of a comprehensive hazardous waste control strategy could well result in irreparable damage to the health and environment of the Nation's citizens. The most viable hazardous waste control strategy would consist of a FederalState regulatory partnership, in which the Federal Government would bear the responsibility for setting process and performance standards applicable to all hazardous waste treatment and disposal activities, while qualified State governments would be responsible for administering federally-approved control programs and enforcing the Federal standards.

Section 4

ISSUES OF IMPLEMENTATION

The previous section has spelled out the need for a regulatory program. A hazardous waste regulatory program does not directly create a national disposal site "system" as envisioned in Section 212 of the Resource Recovery Act of 1970. However, such a system would be ineffective unless its use is mandated via regulations. Even with total governmental subsidy of its construction and operation, such a system would not be assured of receiving all hazardous wastes. Therefore, a regulatory program is needed in any case.

EPA believes that private industry will respond to a regulatory program, but there are a number of questions relating to that response. Furthermore, several options are available to the Gov

ernment to modify a purely private sector system to circumvent these questions if need be.

In this section, estimates are developed of a hazardous waste management system required to implement a hazardous waste regulatory program, the cost of such a system, and possible variations of the system. Issues related to cost distribution, private sector response and the role of Government are discussed thereafter.

Hazardous Waste Management System

A hazardous waste management program should result in creation of a "system" with certain characteristics:

• Adequate treatment and disposal capacity nationwide,

• Lowest cost to society consistent with public health and environmental protection,

• Equitable and efficient distribution of cost to those responsible for waste generation, and

• Conservation of natural resources achieved by recovery and recycling of wastes instead of their destruction.

This system should combine on-site (point of generation) treatment of some wastes, off-site (central facility) treatment for hazard elimination and recovery, and secure land disposal of residues which remain hazardous after treatment.

Scenario. Estimates of total required treatment and disposal capacity, and the mix of on-site and off-site capacity, are keyed to hazardous waste source quantities, types, and geographical distribution; the degree of regulation and enforcement; and the timing of regulatory and enforcement implementation. The hazardous waste management scenario developed below represents, in EPA's judgment, a system with the aforementioned characteristics. It is based on the best available source data and technology assessments,6,7,9,10 discussions with major waste generators and disposal firms, and consideration of the following criteria: earth sciences (geology, hydrology, soils, climatology), transportation economics and risk, ecology, human environment, demography, resources utilization, and public acceptance. The scenario assumes complete regulation, treatment and disposal of all non-radioactive hazardous wastes (as defined in Appendix B), and anticipates issuance of regulations and vigorous enforcement of them at the earliest practicable time period.

The scenario which follows and the cost estimates derived from the scenario should be viewed with caution. Given any reasonable degree of dependence on private market choices on the part of waste generators and waste treatment/disposal firms, the actual

implementation of a hazardous waste management program in the United States is not likely to follow predictable, orderly lines. Numerous interactive factors are likely to influence the shape and the cost of the system as it evolves-including such factors as the impact of air and water effluent regulations on waste stream volume and composition, the impact of uneven response to regulatory pressures from region to region, changes in technology, shifting locational patterns, and the like. What follows, therefore, should be considered as one of many possible permutations of the system. Nonetheless, the scenario does represent EPA's current best judgment of a reasonable, environmentally adequate hazardous waste management system.

As noted previously, approximately 10 million tons (9 million metric tons) of non-radioactive hazardous wastes are generated per year. Of these, about 60 percent by weight are organics, 40 percent are inorganics; about 90 percent of wastes are aqueous in form.

Economic analyses indicate that on-site treatment is generally justified only for dilute aqueous toxic metal wastes and only where the generation rate is high (see Appendix E). Based on analyses of source data, it is estimated that about 15 percent of the total wastes (1.5 million tons or 1.36 million metric tons) are in the dilute aqueous toxic metal category and would be pre-treated by generators on-site. Since on-site facilities are anticipated to be small in scale compared to off-site facilities, about 50 on-site facilities each capable of handling approximately 30,000 tons (27,000 metric tons) per year would be economically justified. About one-third (0.5 million tons or 0.45 million metric tons) of pre-treated wastes would require further processing at off-site facilities.

In this postulated scenario, therefore, most of the wastes (8.5 million tons or 7.7 million metric tons plus pre-treatment residues) would be transported to off-site facilities for treatment/disposal. The size and location of treatment plants is likely to correspond to patterns of waste generation: larger facilities would be located in major industrial regions, smaller facilities elsewhere. Background studies have identified the location of industrial waste production centers and designs and unit costs of small, medium and large size processing facilities (see Appendix F).

A reasonable prediction is that five large facilities, each capable of handling approximately 1.3 million tons (1.2 million metric tons) per year, would be created to serve five major industrial regions in the U.S. and 15 medium size treatment plants each processing approximately 160,000 tons (145 metric tons) would

be built elsewhere to provide reasonable access from other waste generation points. Such an array of treatment plants, taken in conjunction with existing privately owned facilities, is capable of processing all the non-radioactive hazardous waste generated in the U.S. at present with a 25 percent margin for future growth in waste volume.

Processing reduces aqueous waste volume by about 50 percent and usually results in the elimination of hazard (detoxification, neutralization, decontamination, etc.). If the appropriate treatment processes are used, most processing residues will be harmless and disposal in ordinary municipal landfills will be possible. A small portion (5 percent-225,000 tons or 204,000 metric tons) of residues containing toxic metals would require disposal in special, secure landfills.

Under the assumption that maximum treatment for hazard elimination and volume reduction of extremely hazardous waste is carried out, no more than five (and possibly fewer) large scale secure landfills would be required. Facilities would transport their toxic metal residues to such land disposal sites rather than operating secure landfills of their own given the scarcity of naturally secure sites, the difficulty in gaining public acceptance of such sites, the additional expense of artificially securing sites, and the relatively low costs of long-haul transport.

Costs. Based on the above scenario, cost estimates have been prepared for on- and off-site treatment facilities, secure disposal, and waste transportation. The actual values used for estimation purposes are shown in Table 4.1; more detail is presented in Appendix F. Estimates are based on comprehensive engineering cost studies. Each regional processing facility was assumed to provide a complete range of treatment processes capable of handling all types of hazardous wastes, and therefore, each is much more costly than existing private facilities which are more specialized. Based on these estimates, the development of this version of a national hazardous waste management system would require investments in new facilities of approximately $940 million. Average annual operating expenditures (including capital recovery, operating costs, and interest) of about $620 million would be required to sustain the program. In addition, administrative expenses of about $20 million annually for Federal and State regulatory programs would be necessary.

For this scenario, system costs fall into five broad categories: (1) on-site treatment (about 6 percent of total costs on an annualized basis), (2) transportation of wastes to off-site treatment facilities (16 percent), (3) off-site treatment (74 percent), (4)