IMPLICATIONS FOR THE FUTURE

It is highly likely that the hazardous waste system of tomorrow will be different than the one of today. Regulatory impacts, costs of waste disposal, liability considerations, regional capacity constraints, and waste minimization efforts are already affecting waste management practices.

As a result of the regulatory and other factors discussed above, a number of general observations about the waste management system become apparent.

First, there will be increasing restrictions on land disposal without some type of treatment.

Second, hazardous waste treatment and disposal will steadily increase in cost.

• Third, it will be important that the impacts of new regulations are carefully examined to ensure that additional problems are not created.

Having made these observations, let's briefly look at the initial implications that can be drawn from information provided in the report. These implications are intended to serve as a starting point in identifying national priorities as well as focusing on issues of concern to regions and states. The initial implications of the report are summarized below.

First, more facilities are needed to incinerate certain hazardous wastes. This need is likely to increase as SARA's remedial action provisions and RCRA's corrective action and land disposal restriction programs are implemented.

Second, a better understanding of on-site hazardous waste management activities is required. With 96 percent of all RCRA hazardous wastes managed on-site, it is important to understand and deal with likely industry responses to the various regulatory and other impacts.

Third, waste management capacity is largely a regional and waste specific issue. While there is generally adequate capacity to handle some wastes, such as most liquid organic wastes, there is currently inadequate capacity to treat dioxin and solvent contaminated soils and certain dilute wastewaters. In addition, some states and regions have inadequate capacity and must ship their wastes to other areas of the country. Since wastes can move freely in interstate commerce, it will be difficult to "tie down" specific capacity shortfalls.

Fourth, EPA fully supports the concept of waste minimization through the use of technology transfer, recovery and recycling operations, waste exchange programs, and source reduction techniques. It is far better to reduce the generation of hazardous waste than manage waste after it is created.

• Finally, there is a recognized need to site and permit new hazardous waste management facilities and to expand existing units. This is an important part of planning for the future. The 20-year state capacity certification requirement in SARA is a major step in encouraging states to develop new capacity.

This report provides a "big picture" look at emerging hazardous waste issues. It offers a framework for strategic planning at the national, regional, and state level. Furthermore, Exhibit 1 provides a conceptual tool for qualitatively evaluating the interrelationships among various parts of the waste system. However, for assessing the needs for regional or waste specific capacity, more detailed information is required than is presented in this report.

The information contained in this report is based on existing EPA surveys and studies as well as in-person interviews with several major hazardous waste generators and treatment and disposal facility operators. Some data are better than others, and not all data are comparable. At the conclusion of several on-going EPA and other studies, more detailed information on hazardous waste generation, treatment, and disposal will be available.

In 1985, about 275 million metric tons (MMT) of hazardous waste, as the term is currently defined, were managed in RCRA regulated units. In this section, the important issue of hazardous waste definition is addressed. Also included in this section is a breakdown of the sources, locations, and quantities of hazardous waste managed in the RCRA-regulated system.

DEFINITIONS OF HAZARDOUS WASTE

Defining what constitutes a "hazardous waste" requires consideration of both legal and scientific factors. The basic definitions used in this report are derived from: the Resource Conservation and Recovery Act (RCRA) as amended by the Hazardous and Solid Waste Amendments (HSWA), and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act (SARA).

Hazardous Waste refers to "...a solid waste, or combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may...pose a hazard to human health or the environment..." [RCRA, Section 1004(5)].

Solid Waste means "any garbage, refuse, sludge from a waste treatment plant, water supply treatment plant, or air pollution control facility and other discarded material, including solid, liquid, semisolid, or contained gaseous material resulting from industrial, commercial, mining, and agricultural operations and from community activities, but does not include solid or dissolved material in domestic sewage..." [RCRA, Section 1004(27)].

Hazardous Substance means "any substances designated in Section 311(b)(2)(A) of the Federal Water Pollution Control Act...any hazardous waste having the characteristics identified in Section 3001 of the Solid Waste Disposal Act...any toxic pollutant listed under Section 307(a) of the Federal Water Pollution Control Act, any hazardous air pollutant listed under Section 112 of the Clean Air Act, and any imminently hazardous chemical substance or mixture...listed in Section 7 of the Toxic Substances Control Act" [CERCLA, Section 101(14)].