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[Waste Management] - Selected Problems of Hazardous Waste Management, January 1970
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[Waste Management] - Selected Problems of Hazardous Waste Management, January 1970
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Ronald Reagan Presidential Library Digital Library Collections This is a PDF of a folder from our textual collections. Collection: Reagan, Ronald: Gubernatorial Papers, 1966-74: Press Unit Folder Title: [Waste Management] - Selected Problems of Hazardous Waste Management, January 1970 Box: P38 To see more digitized collections visit: https://reaganlibrary.gov/archives/digital-library To see all Ronald Reagan Presidential Library inventories visit: https://reaganlibrary.gov/document-collection Contact a reference archivist at: [email protected] Citation Guidelines: https://reaganlibrary.gov/citing National Archives Catalogue: https://catalog.archives.gov/ SELECTED PROBLEMS OF HAZARDOUS WASTE MANAGEMENT IN CALIFORNIA JANUARY 1970 REPORT OF THE HAZARDOUS WASTES WORKING GROUP OF THE GOVERNOR'S TASK FORCE ON SOLID WASTE MANAGEMENT STATE OF CALIFORNIA RONALD REAGAN, GOVERNOR GOVERNOR'S TASK FORCE ON SOLID WASTE MANAGEMENT SACRAMENTO CHAIRMAN Frank R. Dansby VICE CHAIRMAN January 2, 1970 Dr. Howard Laitin EXECUTIVE BOARD Dr. Howard Laitin, Chairman My dear Governor Frank R. Dansby Robert R. Darby It is my privilege to submit SELECTED PROBLEMS OF Robert L. Foreman HAZARDOUS WASTE MANAGEMENT IN CALIFORNIA. Dr. John M. Heslep Donald H. Lee General findings and recommendations concerning State Carl C. Sexton requirements and policies as well as specific responsi- Dewey Vittori bilities of a designated State agency are presented in REPORT OF THE GOVERNOR'S TASK FORCE ON SOLID TASK FORCE MEMBERS WASTE MANAGEMENT. This volume presents in some Z. Harry Astor detail those Task Force recommendations dealing with Ruth Benell certain critical problem areas uncovered by the Task Force. Dr. Ralph A. Clave John R. Danch Edwin A. Estudillo Respectfully, Carl Fossette Victor Gomer Harley K. Gray Ben J. Kazarian, Jr. IRNanshy Ronald M. Ketcham Charles J. Lyons, Jr. Frank R. Dansby John P. Moscone Chairman James E. Ogden Governor's Task Force on Solid Waste Management William Ohanesian J. E. Pilon W. W. Steiner Rudolph L. Vaccarezza The Honorable Ronald Reagan Robert Van Roekal Governor of California Sacramento, California 95814 TECHNICAL ADVISORS Ralph H. Dudley Dr. Solomon W. Golomb Kenneth K. Hekimian Bernard B. Levitt Dr. Rolf R. Piekarz Dr. Harold Steingold Robert B. Wheelock SELECTED PROBLEMS OF HAZARDOUS WASTE MANAGEMENT IN CALIFORNIA JANUARY 1970 REPORT OF THE HAZARDOUS WASTES WORKING GROUP OF THE GOVERNOR'S TASK FORCE ON SOLID WASTE MANAGEMENT HAZARDOUS WASTES WORKING GROUP GOVERNOR'S TASK FORCE ON SOLID WASTE MANAGEMENT Chairman Howard Laitin, Ph. D., P.E. Manager, Systems Analysis Hughes Aircraft Company; and Adjunct Professor of Industrial and Systems Engineering University of Southern California Members Technical Advisors Ralph A. Clave, M.D., FACS Ralph H. Dudley, M.S., P.E. Assistant Clinical Professor of Member, Technical Staff Surgery - School of Medicine Aerospace Corporation University of Southern California Solomon W. Golomb, Ph. D. Harley K. Gray Professor of Electrical Water Quality Engineer Engineering Southern California Water Company University of Southern California James B. Ogden Kenneth K. Hekimian, M.S., P.E. Liquid Waste Consultant Senior Systems Analyst Aerojet-General Corporation Rolf R. Piekarz, Ph. D. Senior Economist Institute for Defense Analyses Harold Steingold, Ph.D., P.E. Senior Research Engineer RAND Corporation ii PREFACE This report is concerned with those wastes which present a hazard to human, animal, or plant life when not managed properly. FINDINGS AND MAJOR RECOMMENDATIONS are listed in Section I. In section II, GENERAL INTRODUCTION TO HAZARDOUS WASTES, hazardous wastes are defined, chemical and biological contamination are discussed and the responsibilities and method of approach of the Working Group are described. In each of the following sections a selected problem is discussed and recommendations concerning the specific area are made: Section III, CHEMICAL AND PETROLEUM INDUSTRY WASTES Section IV, DRUGS, HYPODERMIC NEEDLES, MEDICAL SUPPLIES, ETC. Section V, RADIOACTIVE WASTES Section VI, SEWAGE TREATMENT SLUDGE Section VII, FEDERAL AND MILITARY In the appendix selected data from Dr. Thrift D. Hanks, Solid Waste/Disease Relationships and from Sanitary Engineering Research Laboratory, Comprehensive Studies of Solid Waste Management - Second Annual Report are adapted. These data identify solid waste sources and indicate hazardous constituents. These data were used as a framework for the screening, review and analysis of the Hazardous Waste problem in California conducted by the Working Group. iii CONTENTS I FINDINGS AND MAJOR RECOMMENDATIONS 1 II GENERAL INTRODUCTION TO HAZARDOUS WASTES 5 1. Background 5 2. Responsibilities and Method of Approach 8 III CHEMICAL AND PETROLEUM INDUSTRY WASTES 13 1. Quantitative Estimates 13 2. Problems 18 3. Recommendations 21 IV DRUGS, HYPODERMIC NEEDLES, MEDICAL SUPPLIES, ETC 23 1. Background: The Drug Manufacturing Industry 23 2. Background: The Local Problem 24 V RADIOACTIVE WASTES 27 1. Background 27 2. Problems 28 3. Recommendations 29 VI SEWAGE TREATMENT SLUDGE 31 1. Background 31 2. Problems 32 3. Recommendations 34 > VII FEDERAL AND MILITARY 35 1. Background 35 2. Problems 35 3. Recommendations 36 APPENDIX: SOME HAZARDOUS SOLID WASTE SOURCES AND CONSTITUENTS 37 vi I. FINDINGS AND MAJOR RECOMMENDATIONS The effective Solid Waste Management Program which California needs cannot be accomplished within the framework of existing legislation. Therefore, the Working Group recommends consideration of its findings and prompt passage of appropriate legislation to accomplish the general recommendations listed in Table I-1. To date, the following hazardous wastes have been examined by the Working Group in detail: (1) Chemical and Petroleum Industry Wastes; (2) Drugs, Hypodermic Needles, Medical Supplies, etc; (3) Radioactive Wastes; (4) Sewage Treatment Sludge; (5) Federal and Military. We have found that, for these special problem areas, it is unlikely that questionnaire surveys and voluntary self-reporting can provide an adequate data base for problem identification and definition and program development. Further, since these special problems tend to be concentrated in specific localities, standard projection and extrapolation techniques tend to understate the state- wide picture in terms of potential damage to the environment and the popula- tion. Therefore, in order to acquire the necessary data base and information for adequate problem definition, and for the development of special standards, the Working Group urges the implementation of the functional recommenda- tions of Table I-2 by the designated State agency. 1 Table I-1. General Findings and Recommendations DRUGS, HYPODERMIC NEEDLES, CHEMICAL AND PETROLEUM MEDICAL SUPPLIES, ETC. CP 1 Develop a uniform system for the classi- DM 1 Develop basic information on solid fication or coding of waste chemicals waste management practices within as to type and degree of hazard. the drug industry in California: (1) to determine the number, location and CP 2 Conduct a detailed field survey of the size of drug industry production and major chemical and petroleum waste processing centers; (2) to determine generators and a questionnaire survey and evaluate present practices, needs, of the smaller firms to develop infor- and problem areas of industrial solid mation on generation of hazardous waste management within the industry; wastes by location of point of genera- (3) to provide data by type on quanti- tion, amount of waste generated by ties of solid waste generated by the type and degree of hazard, company various drug manufacturing firms, ownership, specific identification of information an solid waste generation the official responsible for disposal, points within the production processes, and the current means and points of other sources of solid wastes from the disposal. The questionnaire survey plants, storage practices, collection, should be validated by on-site verifi- disposal or treatment methods, and cation of an appropriate sample and a point of discharge. further check with the haulers involved. DM 2 Determine the nature and extent of the CP 3 Develop special standards of design problems associated with disposal of and/or operation far collection, stor- unused, used, or partially used con- age, transport and/or disposal sites tainers, bottles, hypodermic syringes, receiving hazordous wastes and methods hypodermic needles, drugs, medicines, of audit and control to assure compliance medical supplies and other similar with the standards. items, including bandages and dressings in the State of California. DM 3 Should this problem be reported as "major" or "important" by any signifi- cant number of jurisdictions in the State, then enabling legislation should be passed by the State Legislature to require the designated State Agency to establish standards and regulations in respect to the collection of, trans- portation for disposal, and disposal of discarded drugs, drug containers, syringes, and other contaminated or single-use medical supplies as used by physicians, hospitals, clinics, and similar health care facilities. 2 Table I-1. General Findings and Recommendations (Continued) RADIOACTIVE MATERIALS FEDERAL AND MILITARY RM 1 Survey current situation to determine: FM 1 Survey Federal installations and activi- the generators; quantity and radio- ties for quantities and characteristics active level of wastes produced; fre- of wastes generated and provisions quency and costs of collection; equip- made for the collection, storage, and ment used; and points of discharge ar disposal of these wastes. disposal. FM 2 For each category of wastes where RM 2 Conduct a field study and investigation special procedures are required for to assure that all radioactive wastes storage, collection, transport, or generated within the State enter the disposal, prepare recommended stan- formal collection and disposal system. dards, regulations, operating pro- cedures, or control procedures for RM 3 Re-examine current standards, practices, issue in the public press and for pos- and monitoring and enforcement tech- sible incorporation in Federal niques to assure that they are adequate legislation. in meeting the current and future needs of California. FM 3 Seek legislation which will: require the Federal Government to clean up areas of Federally caused pollution or SEWAGE TREATMENT SLUDGE will authorize the State to do so and recover the costs from the Federal ST 1 Study the ecology of the Santa Monica Government; and establish appropriate Bay to assure that changes induced by standards for Federal installations and the reduction in nutriments reaching activities which assure that the Federal the coastal waters do not cause great Government ceases to cause pollution. damage to the ecological balance. Consider solutions such as treatment and insertion of sewer sludge from the Hyperion plant into the shallow coastal waters and other methods. ST 2 Study contamination in the San Francisco Bay area to determine the relationship of the disposal of sewage sludge in landfills and the identified contamination. Establish standards and regulations for collection, trans- portation, and disposal of these sludges, if study indicates such are applicable. ST 3 Study ecology of all shallow coastal waters off populated areas of California to understand changes brought about by various degrees and methods of treatment and disposal of sludge and associated problems. 3 Table I-2 Functional Recommendations FINDINGS RECOMMENDATIONS The environment, including its quality aspects, is a dynamic system continually The State should centrolize its Solid Waste Program Management responsibilities and changing both in time and in space. A sound environmental quality program must authority for planning and program activities in a single, existing State agency: The be geared to this dynamism. All State policies and practices in the field should be Stote Department of Public Health. reviewed periodically and revised as appropriate. The State's Solid Waste Manage- ment Program should consider all of the significant factors that affect environmental quality. To do this, it will be necessary to substantially increase the magnitude and scope of planning efforts which must be fully coordinated with planning for the protection and development of natural resources. As the Stote's economy expands and the quontity of wastes becomes larger, knowledge concerning environmental quality must be expanded, ond a camprehensive approach involving all levels of government, industry and agriculture is required. Adequate basic data concerning quality and other matters are necessary prereq- The designated State agency should be directed to institute and maintain on accurate visites to the establishment af reasonable quality objectives and standards, ond for inventory and apprapriate projections of solid waste generation. An appropriate enforcement. Basic doto collection programs must be comprehensive and be inventory would include information on: (1) the generation of wastes by location of initioted for enough in advance of need to provide information cavering a wide point of generation; (2) amount of waste generated by type and degree of hazard; variety of conditions. Basic data callection must be a continuing program because (3) identification of company ownership and specific identification of the official of the dynamic nature of the system. The current bosic data programs of the federal, responsible for disposal; (4) description of current meons of disposal and identifica- state and local agencies are not odequate. tion of the points of disposal or discharge. A vested right cannot be acquired to generate or to dispose of waste into the The designated State agency should be directed to develop special standards of environment, or to continue to generate or dispase of wastes at any particular level design and/or operation for collection, storage, transport and/or for disposal sites of quality, once initioted. Periodic revision and upgrading of requirements will be receiving hazardous wastes and to periodically review and update these stondards. necessory to adapt to chonging conditions, and to occommodate new dischorges os the State's economy expands and its population increoses. The interrelotianships between woste generators and dischargers and the effects of their discharges must be recagnized in the setting of requirements and in other quality control actions. Current manitoring and surveillance progroms ore inadequate. Enforcement will be The designated State agency should be directed to develop methods of audit and a greater and more difficult problem in the future due to the much greater volume control to assure on adequate level of compliance with the standards. of waste thot will be generated, the greoter scope and variety of corrective octions required, the mognitude of the costs involved, and the far more complicated inter- relationships between the many kinds of waste discharges, and between the general population and the dischargers. In order to achieve odequate planning and to assure an adequote degree of enforce- A permanent advisory boord composed of informed citizens in the areas of sanitary ment of new environmental quality legislation, oll responsible porties involved in engineering, ecology, economics, public heolth, municipal planning, land use, the generation and production, collection, tronsfer, transport, and/or dispasal of disposol system operation, etc., along with representatives from other affected public hazardous wastes should be involved in the planning process. All waste dischorgers and private cancerns should be appointed by the Governor to assist the designated and others contributing to quality problems should share equitably in the costs of Stote agency in formulating guidelines and/or standards. achieving ond maintaining the requisite levels of quality. Ideolly, waste dis- chargers should pay the social and economic casts of any residual effects of their discharges, rather than having those costs passed on to others. In oddition to identifying all waste generators and personnel of responsibility in the As a minimum, licensing and inspection requirements should include the requirement waste generation process, to assure the adequate ond open development of public for complete disclosure of all parties at interest as individuals, partners, officers, policy and fair, impartiol and odequate enforcement of stondords and regulations, directors, or stackholders of more than 2 percent of any company, partnership, it is necessary to identify all persons of responsibility within the entire solid waste corporation, or business entity, engoged in the collection, transfer, transport or management process. disposal of waste material destined for introduction to the land or woter environment of California. Various wastes have been identified as possibly hazardous and os requiring further The designated State agency should undertake a survey of points of discharge, and information and possible development of special standards and controls (e.g., associated quontitotive and qualitative description of the dischorges, of hazardous segregation or separate collection, special equipment, and special records). One liquid wastes in order to evoluate the magnitude of the problem and as a basis for such waste is mognesium fines. It has been reported that for lack of o legal disposal the development of adequate standards and controls. site at the present time, some producers have been "bootlegging" these highly explosive materials into regular Class II landfills. This proctice has resulted in numerous fires and explosions during the past 12 months. Liquid, chemicol and oily wastes, injected into water courses in greater amounts than prescribed, con become cumulatively hozardous. Ta dote, lock of adequate numbers of enforce- ment personnel hos precluded Stote Water Quality Control Boards in industrially- impacted areas from mointoining adequate inspection of producers' premises, ond disposal practices. Acid and other mine drainage pollution has been suggested as O possible areo of concern and is currently under investigation by the Working Group. 4 II. GENERAL INTRODUCTION TO HAZARDOUS WASTES 1. BACKGROUND The Hazardous Wastes Working Group of the Governor's Task Force on Solid Waste Management is concerned with those wastes which present a hazard to human, animal, or plant life when not managed properly. These toxic or hazardous wastes often require special handl- ing and under most circumstances require disposal on a case-by-case basis. * Hazardous wastes are of both chemical and biological origin. In- cluded in the category of hazardous wastes are industrial chemicals and sludges; residues of chemicals, paints, dyes, solvents, adhesives, oils, plating and pickling liquors remaining on metal cuttings, sawdust, paper, wood or cloth, or remaining in discarded containers; explosives and flammable materials; fines and dusts from exotic materials; exotic liq- uids, and acids and caustic liquids and solids; leachings from mineral wastes; leachings from landfills, herbicides and herbicide containers; pesticides, by-products of pesticide production, and pesticide containers; pathological and infectious wastes, disposable syringes, pills, and drugs from physicians' offices, clinics, hospitals and veterinary facilities; radioactive materials, sewage treatment; and other similar materials. * See, for example, the Final Report of Study Panel to the California State Water Resources Control Board (March 1969): "Consideration was given to the problem of indiscriminate dumping by industrial [liquid] waste haulers in the Los Angeles and San Francisco metropolitan areas. Suggestions ranged from the regional board licensing of waste haulers to requiring the establishment of local ordinances for such activities. The regulation of waste haulers is a complicated subject involving local gov- ernment, regulation of the waste dumps, and policing. It is recommended that the State Water Resources Control Board, in conjunction with the regional boards, develop and implement a program for regulation of industrial waste haulers and make necessary legislative recommendations to the next session of the Legislature". 5 a. Chemical Contamination The rapid acceleration of industrial technology has resulted in the introduction of new and exotic materials into man's environment at an in- creasingly rapid rate. According to Charles C. Johnson, Jr., Adminis- trator of the Consumer Protection and Environmental Health Service of the U.S. Department of Health, Education, and Welfare, every year more than 500 new chemicals and chemical compounds are introduced into industry along with countless operational innovations. Little or nothing is known about the effects of many of these compounds, individually or in combination. Thus, researchers such as Hanks, McGauhey and others have pointed out the necessity for identifying and cataloging the industrial processes and specific agents generated by these industrial processes which may offer potential hazards in order to assure that the generation of these potential hazards does not result in harmful effects to man, nor to his environment. * Surveillance, evaluation and planning must be continuous. First, there is the standard problem of preventing deleterious concentrations of uncommon constituents and toxic compounds at authorized disposal activities and controlling the unauthorized disposal of toxic or hazardous industrial wastes. Second, there is the ever present possibility that a changing industrial process or a new chemical substance could cause long lasting damage to the environment within a relatively short time period, unless the problems were identified and neutralized promptly. To initiate corrective action before a problem becomes acute and forces are set in motion which may well be irreversible except over long time periods, potential problems must be anticipated, the necessary informa- tion and data must be obtained, and plans must be formulated in advance. Additional research is required in order to develop the necessary infor- mation. For example, there is a need to study: factors influencing leaching, movements of compounds through soil, chemical reactions of materials during soil migration, ultimate fate and nature of materials, determination of tolerable levels for those hazardous materials which may escape into the environment, safe limits of lifetime exposures to toxic materials, nature of injuries if excessive amounts are absorbed, means for detecting subclinical effects, and therapeutic measures. * Classification distinctions such as "liquid waste" and "solid waste" are not meaningful. The problem is pollution - no matter what the source. Once the pollutant is in the environment, it may never be known whether the original source was originally classified as a "liquid" or a "solid" waste. For example, the Report of the Committee on Public Works, United States Senate, 7 August 1969 (p. 20) contains an account of a spill of a hazardous substance. On July 9, 1969, about 450, 000 gallons of acid-leaching material was released into the San Francisco River; 50, 000 dead fish were counted in the first 4 miles of the river within 10 hours of the discharge. The Supervisors of Los Angeles County have also recog- nized this as a joint problem in their Motion on Liquid Waste, dated September 23, 1969. 6 Two types of chemicals are of special concern: carcinogens and pesticides. Most proofs of carcinogenesis in humans are limited to OC- cupational exposures but there is probably a general population exposure of unknown magnitude. Various reports substantiate this assumption in one way or another and give emphasis to the urgent need for comprehen- sive chemical, experimental, and epidemiologic studies to determine actual hazards. Pesticides may find their way into solid wastes by four principal routes: production wastes, containers containing pesticides, food wastes, and by direct application to wastes to control pests. Once in the wastes, they are subjected to leaching as are other compounds. Although there is little or no medical evidence that adverse effects have occurred, there is an immediate need for attention to the problem of buildup of persistent pesticides in the total environment. The Secretary of the Interior has been quoted as stating, "Not until we have a systematic monitoring scheme, designed to tell us how much of what is where, will we be able to detect incipient problems early enough to prevent damage. 11 Possible chemical changes in pesticide residues are of interest, and there is a definite requirement for better analytical methods and schemes for de- tection and identification. Studies are needed on the nature of trace element chemical pollu- tants and their physiological significance in terms of disease and nutritional problems. b. Biological Contamination Of primary concern (in regard to free biological agents of disease) is whether or not the method of disposal, or the products of treatment which are to be used in agriculture or other industries, permit survival and transmission of disease organisms to humans, plants, or animals. An important concern at disposal sites is the possibility that organ- isms may migrate through the soil, as a result of leaching and movement of ground water, and pollute water supplies. As early as 1927, E. coli. was known to remain viable for 31 months in experimentally polluted ground water. * Later studies provided data concerning movement of bacteria through soils and factors affecting it. A few investigations have indicated that detergents affect movement of bacteria through soil; how- ever this problem is one which should receive additional attention in research. Fecal or Escherichia coli constitute about 90 percent of the coli- forms discharged in fecal matter. 7 Sludge from various types and comprehensiveness of sewage treat- ment presents a solid waste problem of considerable magnitude. Sludge may be used in agriculure after a process such as composting. * When sludge is used as a soil conditioner, viable organisms may be carried to water supplies by surface runoff; the pathogens may offer an occupational exposure to agriculture or sanitation workers, or may contaminate food- stuffs. Because of these potential problems, additional information is needed on pathogen survival and methods for assuring their destruction, removal of pathogens by various treatment processes, and better methods for detection and enumeration of pathogens. Consideration should be given to certain marine aspects of disposal of sludges. In using ocean disposal methods, it is important to dilute the wastes and dispose of them so that they neither adversely affect the ecology adjacent to the outfall, nor return to shore. On the other hand, sewage treatment sludge could conceivably be used to supply nutriments to the shallow coastal waters which have had their ecology changed due to man-induced deprivation of such nutriments. ** Little is known of the benefits and costs of such processes. Research to gain an understanding of the action of waves, currents, tides, and winds in the dispersion proc- ess is thus important. Since the contribution of solid wastes to potential disease transmis- sion is not well defined, research is needed to develop models of the urbanization phenomenon (which include the ecologic aspects of zoonosis and wastes) for use in investigations of potential epidemic hazards. 2. RESPONSIBILITIES AND METHODS OF APPROACH The Hazardous Wastes Working Group was charged with responsi- bility for developing a quantitative and qualitative understanding of the problems related to the handling and disposal of hazardous waste * Fair and Geyer (Water Supply and Waste Water Disposal, p. 767) caution that such "utilization of sewage sludges is circumscribed by the hygienic hazards involved. Pathogenic bacteria, viruses, protozoa (cysts), and worms (eggs) can survive sewage treatment and be included in the sludge. There, they will persist for long times and cannot be fully de- stroyed by digestion or air-drying. Although the numbers of surviving organisms decrease appreciably in the normal course of events, only heat-dried sludge can be considered fully safe. 11 ** The damming of almost all California streams leading to the coast, the paving and subsequent sweeping of streets, coupled with the disposal of sewage treatment sludge either on land or deep at sea (as is done in Santa Monica Bay, at the edge of an underwater cavern, below the ther- mal incline) deprives the shallow coastal waters of their normal supply of nutriments. 8 materials and with evaluating: (a) the adequacy of the methods utilized to handle and dispose of the material; and (b) the degree of hazardous- ness to the public and the environment from these wastes. In evaluating these wastes, the Working Group was to consider the following: 1) What can be done to minimize the quantities of these wastes being produced? 2) To what extent should these wastes be incorporated with other domestic and commercial wastes and what would be the effect on existing solid waste systems? 3) What special precautions, regulations, or standards are needed to properly handle and dispose of these wastes? 4) Who should have the responsibility for the proper management, control, handling and enforcement of regulations regarding these wastes? The Working Group, in selecting which aspects of the general prob- lem area to explore in-depth, attempted to focus on problems which are unevaluated as environmental hazards. To accomplish this, many dis- cussions were held and a variety of reports and articles were reviewed. Two reports were utilized to provide the Working Group with its classi- fication framework: (1) Thrift G. Hanks, Solid Waste/Disease Relation- ships; and (2) Sanitary Engineering Research Laboratory (SERL), University of California Berkeley, Comprehensive Studies of Solid Wastes Management - Second Annual Report. The Working Group followed, in general, the objective and procedures outlined by SERL. Thus, a de- scription of the SERL objectives and procedures [as modified by the Working Group] is relevant. The principal objective was a systematic screening of data on the types and composition of solid wastes and on the processes of handling and disposal for the purpose of: 1) Identifying those fractions which might have environ- mental and public health implications. 2) Evaluating the public health significance and environ- mental fate of the various fractions in relation to wastes processing and disposal. 3) Identifying those constituents of the solid waste stream which merit intensive study. 4) Suggesting means of keeping those components shown to constitute a significant hazard from entering the environ- ment in such a manner as to cause damage to human, animal, or plant life. 9 Procedures were as follows: A series of tables was prepared by a survey technique involving five major steps as well as the exercise of value judgments of both qualitative and quantitative factors. These steps were sequential in nature and included: 1) Classifying of wastes as to source (e.g., domestic, industrial, etc. 2) Identifying of the individual components of each class (e.g., wood, iron, plastics, etc.) 3) Listing of the chemical nature of each component (e.g., cellulose, lignin, etc.). 4) Listing the chemical nature of any breakdown products to which each component might be converted in each of the several disposal processes (i.e., incineration, landfill, composting). 5) Assessing the environmental and public health signifi- cance of the components and their breakdown products. In making the evaluation necessary to Step 5), three criteria were utilized as a basis for value judgments: (a) magnitude of the component in the waste stream, (b) likelihood of a given component entering the environment, and (c) the effects of any given component if released to the environment. In applying these criteria, it is recognized that magnitude is a relative term in the context of environmental significance. Trace amounts of one class of substance might have a profound effect on public health were it released to the environment, whereas large amounts of other types might be present before they constitute a threat to the public health. An example of the former is cadmium. Ingestion of a milligram or two per kilogram of body weight is sufficient to have dire effects on an indi- vidual. On the other hand, an appreciable amount of iron is needed to constitute a hazard. In either case, however, the significance of any substance in any amount in solid wastes is dependent upon it being re- leased to the environment under circumstances which might injure man, either directly or through depletion of his crops or animal resources. Inasmuch as both original substances and their breakdown products may be involved and the long-term significance of dangerous materials se- questered in the ground are speculative, a considerable degree of sub- jective reasoning enters into an evaluation of the likelihood that any material will enter the environment even if it is present in the waste stream in significant amounts. Obviously, an insoluble material has a far less chance of entering the environment than one that is highly soluble. In assessing whether a particular waste product is to be considered as "hazardous, 11 the following criterion is used: If a material adversely 10 affects human health, or has significant adverse effects on plant or animal life if released to the environment at any stage in solid waste management, then it is considered hazardous. In some cases materials which occur in solid wastes have already been demonstrated as toxic. Thus, elements such as cadmium, lead, beryllium, and other metals, although normally present only in trace amounts, should be thoroughly followed from their entrance into the wastes stream until and including the time of their final disposal. The same should be done of other materials which, in their pristine state may be innocuous enough, but when subjected to certain treatment proc- esses form toxic substances. Plastics containing chlorine are a case in point. When incinerated, such plastics are converted to volatile chlorine products highly toxic in nature. Table II-1 lists various major industries by Standard Industrial Classification, describes the waste generating processes for each indus- try, and lists the hazardous wastes to be expected. The Appendix contains more detailed materials on sources of hazardous wastes, hazardous con- stituents of these wastes, means of treatment or disposal, and environ- mental fate of hazardous wastes in relation to disposal means. 11 Table II-1 Sources and Tvpes of Hazardous Industrial Wastes Standard Industrial Classification Group Code Group Classification Waste Generating Processes Expected Hazardous Wastes 19 Ordinance and Accessories Manufacturing ond assembling Metal filings, plastics, chemical residues 24 Lumber and Wood Products Sawmills, mill work plants, Metal filings, plastics, wooden container manufac- glues, sealers, paints, ture, and manufacturing of solvents miscellaneous wood products 25 Furniture, Wood Manufacture of household Those listed under Code 24 and office furniture, porti- tions, office and store fixtures, and mattresses 25 Fumiture, Metal Manufacture of household Metal filings, plastics, and office furniture, lockers, resins, adhesives bedsprings, ond frames 26 Paper and Allied Products Poper manufacture, conver- Chemicals, paper coatings sion of paper and paper- and fillers, inks, glues board, manufacture of paperboard boxes and containers 27 Printing and Publishing Newspaper publishing, Metal filings, chemicals, printing, lithography, inks engraving and bookbinding 28 Chemicals and Related Manufacture and preporation Organic and inorganic of inorganic chemicals chemicals, metal filings, (ranges from drugs and soups plastics, oils, paints, to paints and varnishes, and solvents, pigments explosives) 31 Leather and Leather Products Leather tanning and finishing; Dyes, oils, processing and manufacture of leather curing compounds 34 Fabricated Metal Products Manufocture of metol cans, Metal filings, slag, scale, hand tools, general hard- coatings, solvents, lubri- ware, non-electric heating cants, pickling liquors apparatus, plumbing fixtures, fabricated structural products, wire, farm machinery and equipment, coating and engraving of metal 35 Machinery (except electrical) Manufacture of equipment for Slag, metol scrap and construction, mining, eleva- filings, plastics, resins, tors, moving stairways, con- paints, solvents, petroleum veyors, industrial trucks, trailers, stackers, machine tools, etc. 37 Transportation Equipment Manufocture of motor vehicles, Metal scrap and filings, truck and bus bodies, motor fiber, plastics, paints, vehicle parts and accessories, solvents, petroleum products aircraft and parts ond boat building and repairing motor- cycles and bicycles and parts, etc. 39 Miscellaneous Manufacturing Manufacture of jewelry, Metal filings, plastics, silverware, plated ware, resins, adhesives, paints, toys, amusement, sporting and solvents and athletic goods, costume novelties, buttons, brooms, brushes, signs, and adver- tising displays 12 III. CHEMICAL AND PETROLEUM INDUSTRY WASTES 1. BACKGROUND a. Total The State Department of Public Health, in their Interim Report, Status of Solid Waste Management in California (1968), estimated that 463, 000 tons of chemical and petroleum industry wastes (126, 800 and 336, 800 tons, respectively) were produced in California in 1967. The major portion of these wastes (82.5 percent) were produced in Los Angeles and Contra Costa Counties. An additional 15 counties produced only between 200 and 13,600 tons (See Figure III-1 and Table III-1 and 2). b. Chemical Wastes Recent questionnaire surveys of chemical industry wastes, taken during the past 3 years by three different groups, show a variation in the waste generation factor of almost two-to-one, as shown in Table III-3. In 1966-67, the Manufacturing Chemists Association (MCA) conducted a survey of their membership which indicated that 120, 000 tons of solid wastes were produced by their members in California during 1966* The MCA represents only those companies that manufacture chemicals, essentially SIC Code 281, Industrial Chemicals, and SIC Code 287, Agri- cultural Chemicals. The MCA obtained information from 84 chemical plants employing 12,594 persons in California. These data indicated an approximate waste production rate of 9.5 tons per employee/year. In 1967, with the cooperation and assistance of the Chemical Indus- tries Council of Northern California, the State Department of Public Health *Manufacturing Chemists Association, "Environmental Management in the Chemical Manufacturing Industry - a 1967 Survey of the Members of the Manufacturing Chemists Association." 13 DEL NORTE SISKIYOU MODOC ANNUAL TONNAGE PRODUCED BY COUNTY GREATER THAN 150,000 TONS HUMBOLDT TRINITY SHASTA LASSEN TEHAMA 1000 TO 15,000 TONS (a) PLUMAS MENDOCINO GLENN BUTTE SIERRA YUBA LESS THAN 1000 TONS COLUSA NEVADA LAKE UTTER PLACER (a) NO COUNTY PRODUCES BETWEEN 15,000 AND 150,000 TONS SONOMA YOLO EL DORADO NAPA SACRA- AMADOR ALPINE MENTO SOLANO CALAVERAS MARIN CONTRA SAN TUOLUMNE COSTA JOAQUIN MONO ALAMEDA SAN MATEO MARIPOSA STANISLAUS SANTA CLARA MERCED SANTA CRUZ 8 MADERA SAN FRESNO BENITO INYO TULARE MONTEREY KINGS SAN LUIS OBISPO KERN SAN BERNARDINO SANTA BARBARA VENTURA LOS ANGELES ORANGE RIVERSIDE SAN DIEGO IMPERIAL Figure III-1. Distribution of Chemical and Petroleum Industry Wastes, 1967* *California Department of Public Health. 14 Table III-1. Chemical and Petroleum Industry Wastes in California 1967* (in tons) Area Los Angeles Contra Costa Restof Total for Type of Waste County County State California a a 126,800 d Chemical 25,000 Petroleum a 127,100ᶜ a 336,800 d Total 230,000 b 152,100 b 1,200 b 463,600d Symbols: a Not reported b From Table III-7, page III-29 of State Report. C 121,800 tons of waste from petroleum refining; 5300 tons, other. d From Table III-6, page III-27 of State Report. Table III-2. Chemical and Petroleum Waste Generation Factors - California State Department of Public Health 1968 SIC Code Industry Tons/Employee/Year Series 28 Chemical 0.5 (minus 281, 285) 281 Industrial Inorganic 10.0 and Organic Chemicals 285 Paint Manufacturing 2.25 Series 29 Petroleum 10.0 (minus 2911) 2911 Petroleum Refining 23.5 *Source: Status of Solid Waste Management in California (1968) 15 Table III-3. Recent Surveys of Chemical Industry Wastes in California Manufacturing California State Governor's * Bureau of Solid Chemists Association Department of Task Force on Waste Management - (MCA) Public Health Solid Waste National Survey Year 1966 - 7 1967 8 1969 1969 70 Number of 8 29 84 firms surveyed (Northern (Southern * (statewide) in California California only) California only) Total waste found in 120,000 24,000 80,000 * survey (in tons) Total number of employees 12,594 2,350 4,929 * in survey Waste generation factor** tons/ 9.5 10.1 16.1 * employee/year Total chemical industry wastes in California 120,000 126,800 200,000 * (in tons), based on each survey *Data not yet available. **This figure is included to show relative comparisons but is not particularly meaningful, since different segments of the chemical industry develop widely differing quantities of waste. Thus, specific multipliers must be developed, as appropriate, for various segments of the chemical industry. 16 conducted a questionnaire survey of chemical solid waste production and disposal in the San Francisco Bay Area. An industrial waste survey form developed by the Department was mailed by the Council to their membership. The returned forms from eight firms in Contra Costa County (representing more than 25 percent of the total statewide employ- ment in SIC Code 281, Industrial Inorganic and Organic Chemicals) were used in developing the waste factor of 10 tons per employee/year for SIC Code 281. These eight firms employed approximately 2350 persons and during 1967 produced approximately 24,000 tons of solid and semi-solid wastes. These wastes consisted of slurries, sludges, dusts, containers and other packaging materials, dunnage, and normal rubbish. Approxi- mately 23 percent of the wastes were disposed of by onsite landfilling, and 77 percent were either picked up by private refuse collectors or industrial waste haulers. The waste production factor of 2.25 tons per employee per year was used by the State for paint manufacturing firms (SIC Code 285) and the factor of 0.5 ton per employee for the remaining employment in SIC Code 28. It was considered reasonable that these plants would not have as large a waste factor as the large basic chemical processing plants; however, as the Department has pointed out, these two factors need further evaluation. An estimate of total statewide production of 126, 800 tons of chemical wastes for 1967 was determined by applying the above factors to statewide employment data. Approximately 100, tons were produced by the plants engaged in manufacturing industrial chemicals (SIC 281) and the remaining 26, 800 tons were pro- duced by the other plants listed under the classification, Chemical and Allied Products (SIC 28). The Governor's Task Force on Solid Waste Management, in cooperation with the Chemical Industrial Council (CIC) of Southern California, recently conducted a survey similar to that just mentioned. In order to derive results compatible with those obtained by the Depart- ment, the Hazardous Wastes Working Group used survey forms and related instructions identical to those used by the State. In this case, however, completed questionnaires were returned to an official of the CIC who assisted the Working Group in data reduction and analysis. Of 40 firms approached 29 completed their questionnaires. These firms represent 4929 employees and generate approximately 80,000 tons of solid and semi-solid wastes per year for an approximate waste produc- tion rate of 16.1 tons per employee/year. The Federal Government, specifically the Bureau of Solid Waste Management, has undertaken nationwide study of chemical industry solid wastes. * However, the Task Force has been informed that, although a *National Industrial Solid Waste Management Study - the Chemical Industry; Contract No. CPE 69-5; Awarded to Traveler's Research, Inc., Hartford, Connecticut; June 1969 to 1970, PHS Publication No. 1897, Supplement, p.12. 17 questionnaire survey will be mailed to chemical firms in California, there are no plans to conduct detailed field surveys of these firms in the State. Representatives of the State should monitor the California phase of this effort to ascertain that all data acquired and techniques developed will be made available to the pertinent State agency. This questionnaire survey may serve as a benchmark for the more compre- hensive State agency on-site surveys recommended below. C. Petroleum Wastes A survey of the four major petroleum refineries in Contra Costa County was conducted jointly by the Western Oil and Gas Association (WOGA) and the California Department of Public Health. A survey form was completed by each firm, and the data tabulated by WOGA. The 115, 655 tons produced by these refineries represented 95 percent of the petroleum refining wastes produced in Contra Costa County and 37 per- cent of that produced in the State. Based on these data, a waste produc- tion factor (23.5 tons per employee per year) was developed for SIC Code 2911 (Petroleum Refining). Inasmuch as industries that are related to petroleum refining are similar to the chemical industry, a similar factor of 10 tons per employee per year was applied to these employment data. These factors were used in determining the statewide total of 336, 800 tons of wastes produced from petroleum refining and related industries. The data on solid waste production, characteristics, and method of disposal for the four major refineries in Contra Costa County are shown in Table III-4. As shown, 46 percent of the waste is disposed of in a landfill on-site and 54 percent is disposed of via private industrial waste haulers and offsite landfills. To date, the California Department of Public Health has not obtained equivalent data for Southern California. The Hazardous Wastes Working Group of the Governor's Task Force has established lines of communication with WOGA in Los Angeles, and is in the process of con- ducting a joint survey. These findings will be presented in a supple- mentary memo. 2. PROBLEMS Because of their toxic nature special public health problems are associated with the handling and disposal of many chemical and petroleum wastes. A report to the U.S. Public Health Service* presents a dis- cussion of disease associated with chemical wastes. It is reported that hazardous chemical wastes can adversely affect the public health in a number of ways depending on the method of disposal, the nature of the end product, its concentration, and the effective dose in the population. *T.G. Hanks, "Solid Waste/Disease Relationships, IT PHS No. 999-UIH-6, 1967. 18 Table III-4 Petroleum Refining Solid Waste Production and Disposal Contra Costa County - 1967* Place of Disposal Characteristics Type of Waste Tonnage Produced (Percentage) Organic Inorganic Toxic Onsite Offsite Solids Cat. cracking catalyst 8,530 X 23 77 Other catalysts, clay, ond desiccant 8,260 X 85 15 Coke and carbon fires 80 X 100 0 Miscellaneous solids such as fly ash 2,500 X 12 88 Rubbish from 4 plant cleanup 6,700 X X 8 92 Semi-solids Sludges -- tank cleaning, water treatment, etc. 54,300 X X 13 87 Silt 35,000 X 100 0 TEL waste 270 X X 100 0 Acid tars 15 X X 0 100 Total 115,655 46% 54% *Data provided by Western Oil and Gas Association 19 Human beings can be subjected to the toxic action of chemical wastes by direct contact, inhalation of dust, drinking or contact with contaminated water, eating contaminated foods, and contact with or breathing the fumes from open burning or incineration. An example of the type of problem which can occur is one that was investigated during 1966 by the California Department of Public Health. In this case the reclamation, transportation, and disposal of chemical sludge containing tetraethyl lead caused illness to workers. In another incident, large quantities of chemical wastes were being disposed at a public disposal site, and although the tractor operator was required to mix the chemical wastes with other refuse, neither the site operator nor the industrial waste hauler knew much about the wastes other than its source was a large chemical company. A third example is the open dumping of toxic chemical wastes at a disposal site adjacent to San Francisco Bay. It is mandatory to determine, accurately, the quantities and characteristics of chemical and petroleum industry wastes generated in California. The results from the MCA and Department surveys were in very good agreement. Both, however, resulted in substantially lower waste generation factors than that obtained by the Working Group. Whether the previous two surveys reflected information supplied by the haulers for these firms is unknown. It is also unknown whether the results of the questionnaires were verified by on-site inspections. Some individual comparisons with waste haulers were made by the Working Group. These were in good agreement with the Working Group's survey results: that the estimates of the quantities of these wastes reported, as carried by the waste haulers, exceeded by a factor of almost two, the quantities of these same wastes reported as generated by the application of the Department's standard generation factors. In general, the use of questionnaires, as the sole basis for data gathering, can lead to underestimating. Detailed field surveys are required, throughout the State, by the Department of Public Health representatives in order to obtain an accurate estimate of chemicals and petroleum industry wastes. Both industries have shown a great willingness to cooperate with the Working Group. They recognize that the economic collection and disposal of their solid and semi-solid wastes will be a requirement for their continued growth. But, they also realize that stringent air, water and soil pollution standards on their wastes will probably have an inhibiting influence on their continued growth. For these reasons, major portions of the chemical industry, in Southern California at least, are considering relocation to sparsely populated areas, and an exodus has begun to San Bernardino and River- side Counties. Probably many additional sources of contamination should receive attention. For example, the U.S. Department of the Interior reports that used and uncollected motor oil presents a serious domestic problem. According to the Department, some 350 million gallons of used motor 20 oil must be disposed of annually by more than 210, 000 gasoline filling stations in this country. Since changes in labeling requirements and in the tax laws have put more than half the re-refiners of used motor oil out of business, the petroleum industry has no means for collecting the used oil, and the oil often finds its way into city sewers, simply because it is the easiest way to dispose of the material. In 1968 at hearings on some 20 bills dealing with the various pollution threats to this nation, Rep. George H. Fallon (D. - Md.) also pointed out this aspect of the oil pollution threat and the need for the control of used and uncollected motor oil. 3. RECOMMENDATIONS It is recommended that: a. A uniform system for the classification or coding of waste chemicals as to type and degree of hazard should be developed. b. A detailed field survey of the major chemical and petroleum waste generators and a questionnaire survey of the smaller chemical and petroleum waste generators should be under- taken to develop information on generation of hazardous wastes by location of point of generation, amount of waste generated by type and degree of hazard, company ownership, specific identification of the official responsible for disposal, and the current means and points of disposal or discharge. The questionnaire survey should be validated by on-site veri- fication of an appropriate sample and a further check with the haulers involved. C. Special standards of design and/or operation for collection, storage, transport and/or disposal sites receiving hazardous wastes should be developed along with methods of audit and control to assure compliance with the standards. 21 on IV. DRUGS, HYPODERMIC NEEDLES, MEDICAL SUPPLIES, etc. 1. BACKGROUND: THE DRUG MANUFACTURING INDUSTRY The drug industry has been growing steadily for many years, but its growth was greatly accelerated during the Second World War by the enormous demands of the Armed Forces for life saving products manu- factured by the drug industry. Acceleration of this industry continued during the following years. Each day many new products are being discovered and manufactured. The complexity of the problem is increased by the wide variation of products such as dry powdered extracts, liquid galenicals, volatile oils, dried herbs, etc. Because of the unknown nature of the wastes from the production of these products and their potential for water and air pollution, the Working Group deems it important to gather quantitative and qualitative information on all aspects of this industry's solid wastes. The Federal Government, through the Bureau of Solid Waste Management, has issued a contract "to study and evaluate the solid waste management practices of the drug industry, SIC 283, 11* This SIC code includes establishments primarily engaged in manufacturing, fabricating or processing of biological or medicinal chemicals and pharmaceutical products, and also establishments primarily engaged in the grading, grinding, and milling of botanicals. The Task Force has been informed that, although a questionnaire survey will be mailed to drug firms in California, there are no plans to conduct detailed field surveys of these firms in the State. Representatives of the State should monitor the Cali- fornia phase of this effort to ascertain that all data acquired and tech- niques developed will be made available to the pertinent State agency. This questionnaire survey may serve as a benchmark for the more comprehensive State agency on-site surveys recommended below. National Industrial Solid Waste Management Study - The Drug Industry; Contract No. CPE 69-7; Awarded to Litton Systems, Inc., Minneapolis, Minnesota; May 1969 to July 1970, PHS Publication No. 1897, Supplement, p.7. 23 2. BACKGROUND: THE LOCAL PROBLEM In September 1963, the California Congress of Parents and Teachers voiced concern with the problem of discarded syringes and other contaminated medical supplies coming into the hands of children and youths due to the inadequate disposal practices of hospitals, clinics and physicians offices. In June 1968, the Community Health Services Chairman of the Congress of Parents and Teachers reported that the Congress still found it appropriate to be concerned with this problem due to their continued receipt of numerous complaints of such incidences. On September 12, 1966, the City Council of Hawthorne, California unanimously adopted Ordinance 869 which regulated the disposal of unused, used, or partially used containers, bottles, hypodermic syringes, hypodermic needles, drugs, medicines, medical supplies and other simi- lar items including bandages and dressings. According to local reports, this ordinance resulted from frequent reported instances of children playing with such wastes and of adults scavenging for both medical use and drug abuse purposes. From 1966 to 1969 several articles appeared in the press through- out the State of California reporting similar incidences. Also, agencies such as the State Department of Vocational Standards, the Los Angeles Police Department, and the Sheriff's Office of Fresno, California, reported such incidents on the basis of their own direct investigations, as well as on the basis of parent's complaints to these agencies. In April 1968, the Los Angeles Supervisors ordered this problem reviewed by the Los Angeles County Health Department and the Chief Administrative Officer in cooperation with the Los Angeles Medical Association. As a result of this review, the Los Angeles County Board of Supervisors, on May 21, 1968, adopted an order supporting State legislation on the disposal of drugs, hypodermic needles, etc. During early 1968, a legislative request was made for answers to the following questions: Is there demonstrable need for providing State regulations regarding disposal of medical items? What problems have developed -- i.e., children having access to dangerous drugs, etc? Could regulation of receptacles be handled better and more easily through county health ordinances? Do some county health departments presently regulate the disposal of medical items? In partial response to these questions, a brief survey was conducted with the Chiefs or the Narcotics Detail Heads of 34 police 24 departments in the State of California. The following answers were obtained to the question of whether this problem existed in their jurisdiction: Yes 18 Yes, but limited 3 No 12 Problem given to Sheriff's Office 1 Of the 18 "yes" answers, eight cities described this problem as "major" or "important. 11 During the 1968 regular session of the legislature, Assembly Bill No. 1643 was introduced to require the State Department of Public Health to adopt regulations and standards with respect to the collection of, transportation for disposal, and disposal of discarded drugs, drug containers, syringes and other contaminated medical supplies as used by physicians, hospitals, clinics, etc. The bill stated that: (a) these regulations shall not apply to the disposal of drugs, containers, or devices acquired by retail consumers for their own use; and (b) these regulations shall have no force or effect until the board of supervisors of a county, by resolution, determines that such regulations are neces- sary for the public health and safety of the people of such county. The county may provide other resolutions to regulate the licensing of fran- chise holders to engage in the business of collecting such drugs, con- tainers, and devices; to inspect all facilities for the collection and disposal of such items; and to regulate, the location, maintenance, operation, and security of disposal sites. The State Department of Public Health, in commenting on this bill, advised that this bill would require staff augmentation at a cost of between $15, 000 to $20,000 for the 1968-69 fiscal year for a study of the magnitude of the problem and for the adoption of regulations, and that there would be no increased State cost thereafter. The bill received unanimous "do pass¹¹ recommendations by both the Public Health, and Ways and Means Committees of the Assembly but did not pass the Appropriation Committee. In commenting, the legis- lative analyst stated: "Currently the department has 35 technical positions involved in food and drug activities, including the drafting of regulations. We have been unable to determine the basis upon which the need for additional money to carry out the requirements of this bill is predicated." 25 In order to determine whether the problem, as reported, is sufficiently severe so as to require legislation, the Hazardous Wastes Working Group held extended discussions with some of their professional colleagues. These conversations indicated that there is a basic under- lying concern with the entire problem of drug disposal on the part of the medical profession and a willingness on the part of the profession to assist in developing and applying solutions. Hence, the members of the Hazardous Wastes Working Group will be glad to assist in conducting a detailed survey of the current practices and concerns of the medical and related professions in regard to drug, medical supply and associated disposal problems. 3. RECOMMENDATIONS It is recommended that: a. The designated State agency should conduct a survey to develop basic information on solid waste management practices within the drug industry in California to: (1) determine the number, location and size of drug industry production and processing centers in California; (2) deter- mine and evaluate the present practices, the needs, and the problem areas of industrial solid waste management within the industry; and (3) provide data by type on the quantities of solid waste generated by the various drug manufacturing firms, and information on the solid waste generation points within the production processes, other sources of solid wastes from the plants, storage practices, collection, dis- posal or treatment methods, and point of discharge or disposal. b. The designated State agency or another appropriate agency should conduct a survey to determine the nature and extent of the problems associated with the disposal of unused, used, or partially used containers, bottles, hypodermic syringes, hypodermic needles, drugs, medicines, medical supplies and other similar items, including bandages and dressings, in the State of California. C. Should this problem be reported as "major" or "important" by any significant number of jurisdictions in the State, enabling-legislation should be passed by the State Legislature which will require the designated State agency to establish standards and regulations in respect to the collection of, transportation for disposal, and disposal of discarded drugs, drug containers, syringes, and other contaminated or single- use medical supplies as used by physicians, hospitals, clinics, and similar health care facilities. 26 V. RADIOACTIVE WASTES 1. BACKGROUND Radioactive materials comprise all the isotopes, the nuclei of which undergo spontaneous disintegration. It is well known that extensive care and precautions must be observed in the use of such materials. The same care and precautions must also be exercised in on-site storage, handling, transportation, and final disposal of radioactive materials when they become waste. Even after it is buried or sunk, radioactive waste remains "alive;" in some cases this condition exists for thousands of years. Regulations for the handling, transportation and disposal of radio- active wastes are specific and strict. They require, in general, that all the radioactive waste materials must be handled, transported and dis- posed of in such a manner, and in such a location, as will result in no significant radioactive contamination of the environment. As little as 10 years ago, this category of waste would have had little impact on the State of California. However, with the exponential rise in the use of radioactive materials by power generation facilities, research laboratories, hospitals, industry, etc., a critical review of this category is necessary. For example, there are two power reactors currently operating in the State of California: Humboldt Bay [70 mega- watt] and San Onofry [450 megawatt]. Two more power reactors are under construction: Sacramento Municipal Utility District [850 mega- watt] and Diablo Canyon [1060 megawatt]. Six sites have been acquired to cover expansion for the next 20 years. There is only one hauler operating in the State of California capa- ble of handling high and intermediate level radioactive wastes. This hauler, Nuclear Engineering Company, Inc. of Walnut Creek, California, also handles low level radioactive and other exotic wastes. Hutchinson and Sons of San Pedro, California, handles Southern California low level wastes only. 27 2. PROBLEMS Many of the users of radioactive materials are known to the Department of Public Health, State of California. However, some of those users who had obtained radioactive materials prior to the enact- ment of legislation have not registered with the Department. * There may be still other users who obtained their radioactive materials in an illegal manner. The State Department of Public Health enforcement agency, or participating local Health Departments, audit the users of radioactive materials every 6 months, once a year, or every 2 years depending on the damage potential of the user. This is not of sufficient frequency to accurately assess the quantity, radioactive strength, etc, of the generated wastes. The disposal of radioactive waste in California is handled under the options listed in Table V-1. Table V-1. Options for Radioactive Wastes in California Applicable Paragraph Origin Transportation Disposal of Regulations Sewer system Ocean 30287 Stack, pipe, or Air or water 30269 similar conduit Generation None Burial in soil 30288 From any Truck Burial in Group 4 Source AEC-approved landfill at Beatty, Nevada, or at Richland, Washington *See Groups 1 and 2 of the California Radiation Control Regulations, Title 17, Chapter 5, Subchapter 4 "Public Health" of the California Administrative Code, 1968. 28 The ultimate disposal of high, intermediate and some low level radioactive waste is currently accomplished at either Beatty, Nevada, or Richland, Washington, both of which are operated by Nuclear Engi- neering Company, Inc. The low level wastes that are not transported out of the State are disposed of by burial, injection to air or water, or dumped into a sewer system. There have been abuses of the sewer system method observed by radiation-detector devices located in sewage treatment plants. However, the violators have not been apprehended because of the difficulty of identifying the source, It is probable that abuses of other disposal methods have also occurred without detection. There exists neither a comprehensive listing of all the users of radioactive material and their quantitative and radioactive levels gen- erated in the State of California, nor a comprehensive monitoring, sur- veillance and enforcement system for the management of storage col- lection, haul, and disposal. As an example, data maintained by the site operator accumulates 73 percent of waste received at the Nevada burial, facility under the single general heading of "Licensee. 11 3. RECOMMENDATIONS It is recommended that: a. The designated State agency should conduct a survey to determine current practices including: (1) generators of radioactive wastes; (2) the quantity and radioactive level of wastes produced; (3) the frequency and costs of collection; (4) equipment used; and (5) points of discharge or disposal. b. The designated State agency should conduct a field study and investigation to assure that all radioactive wastes that are generated within the State enter the formal collection and disposal system. C. The designated State agency should conduct a formal re-examination of their current standards and practices as well as monitoring and enforcement techniques to assure that they are adequate in meeting the current and future needs of California. 29 e & VI. SEWAGE TREATMENT SLUDGE 1. BACKGROUND In most sewage treatment processes, the liquid and solid portions of the sewage are separated, and the associated gases captured. The liquid, forming the effluent from the treatment plant is usually disposed of by dilution or, very infrequently, on land. The solids which form sludge or scum, are usually disposed on land and less frequently by dilution. The captured gases, unlike the liquid and solid portions of sewage, provide a useful by-product which is ordinarily partially recycled, with the remainder sold for power generation purposes. The disposal of sewage solids, not the water in sewage, is the most difficult problem faced by waste water treatment plants today. Whereas, the technology for treating the liquid portion of waste water has progressed to the point where direct human reuse is entirely feasible, no such methods have evolved for the ever increasing volume of the solid portions of liquid-borne wastes. * Many of the major prob- lems of waste water treatment such as odors, dust, and health hazards are associated with sludge disposal. Sludge disposal creates the most difficult portion of the disposal problem because the polluting potentia- lities, per unit of weight, are greater than those of the liquid effluent from the treatment process that produced the sludge. Three ultimate areas of sludge disposal exist: the atmosphere, the land, and the ocean. Cost of sludge disposal is usually a sizable portion of the total cost of waste water treatment. Sludge disposal costs alone range from *Testimony before the Los Angeles County Grand Jury. Appendix "D", Sale of Sewage Solids, 1967. 31 2 to 3 dollars per ton of dry solids, upwards to several hundred dollars per ton, depending upon the disposal method and the size of the opera- tion, the type and properties of the sewage, and the quality of the pro- cessed effluent and sludge. The benefits and costs associated with the Los Angeles City approach, implemented at the Hyperion treatment plant, however, are not yet fully understood. Of course, the physical proper- ties of the effluent and sludges are known and the costs of approximately $3.50/ton can be audited; the real problem in evaluation comes with the attempt to quantify the effect of interaction with the environment. 2. PROBLEMS The problems of waste disposal to the marine environment in California are intensified by the year-round recreational and other beneficial uses of the saline receiving waters. While in colder climates, many beneficial uses are limited by short seasons or restricted by rugged topography, in California the waters are utilized extensively throughout the year. The specific problems in California which are associated with sewage treatment sludges arise from a broad spectrum of sources. At one end of the spectrum, pollution control of sewage treatment sludge is "too good. 11 The damming of almost all the streams and rivers lead- ing to the coast, the paving and sweeping of the streets, coupled with the disposal of sludges either on land or in the ocean (e.g., Santa Monica Bay where sludge is inserted at the edge of an underwater cavern) at a depth where it will not be transported to the shallow coastal waters deprive these waters of their natural nutrients. This lack of nutrients has significantly modified the coastal ecology. Little is known about the extent of these changes, but it is postulated that the lack of nutriments possibly could be overcome by depositing the sludge from the Hyperion above the "thermal incline" which would enable the sludge to reach the shallow coastal waters. This problem requires additional research before it, and any possible solutions, can be assessed knowledgeably. At the other end of the spectrum of sludge pollution problems, the San Francisco Bay - Delta Area Study* indicated that observations, at several of the more objectionable fills located on land adjacent to bodies of water, showed that water draining from these sites had high popula- tions of fecal coliform and fecal streptococci. More than 125 California communities dispose of their sewage effluent, after varying degrees of treatment, through submarine outfalls. The location of major outfalls is shown on Figure VI-1. With the spread of suburban areas, the development of metropolitan districts, and the extension of trunk sewers farther inland, the magnitude of marine waste disposal in California is expected to increase markedly in the next few decades. ""Solid Wastes and Water Quality, 11 California Department of Public Health, 1968. 32 CRESCENT CITY ARCATA EUREKA SAN FRANCISCO NO. SAN MATEO CO. S.D. BEAST BAY M.U.D. SHARP PARK HALF MOON BAY SANTA CRUZ CAPITOLA CO. S.D. PACIFIC GROVE WATSONVILLE SEASIDE S.D. MONTEREY MORRO BAY - CAYUCOS S.D. PISMO BEACH SANTA BARBARA BILTMORE CARPINTERIA S.D. SANTA BARBARA PORT HUENEME S.D. LOS ANGELES CITY LOS ANGELES CO. S.D. VENTURA SUNSET BEACH OXNARD SAN CLEMETE ORANGE COUNTY S.D. OCEANSIDE AVALON CARLSBAD LAGUNA BEACH SAN DEIGO SO. LAGUNA S.D: DOHENY BEACH ST. PK JOINT INTERNATIONAL CHULA VISTA CORONADO Figure VI-1. Major Submarine Outfalls in California* * Ocean Engineering, III, compiled and edited by Richard D. Terry, North American Aviation, Inc., El Segundo, California, 1966. 33 3. RECOMMENDATIONS It is recommended that: a. The designated State agency should study the problem of the changes in the coastal ecology of Santa Monica Bay to assure that the changes induced by the reduction in nutriments reaching the coastal waters do not cause great damage to the ecological balance. Consideration should be given to the solu- tion to the problem of insufficient nutriments in Santa Monica Bay by (1) the treatment and insertion of sewer sludge from the Hyperion Plant into the shallow coastal waters and/or (2) other methods. b. The designated State agency should study the problem of contamination in the San Francisco Bay Area to determine the relationship of the disposal of sewage sludge in landfills and by other means in that area and reported contamination condi- tions in the Bay Area. The agency should establish standards and regulations with respect to the collection of transportation for, and disposal of sewage sludges, should study indicate that harmful effects are being generated by present sewage sludge disposal practices. C. The designated State agency should study the ecology of all the shallow coastal waters off the populated areas of California to obtain an understanding of ecological changes brought about by the various degrees and methods of treatment and disposal of sewage sludge and resulting problems. 34 VII. FEDERAL AND MILITARY 1. BACKGROUND Federal activities in California are important sources of environmental pollution. For example, it is estimated that 250 million gallons of shipboard and sanitary sewage are discharged into the San Francisco Bay - Delta Area each year from vessels using the 12 deep water ports, numerous port and docking facilities, and 250 small craft harbors. It has also been estimated that the 60 assigned military vessels operating in the Bay-Delta waters contribute approximately 90 percent of the annual wastes discharged from all vessels. Senator Murphy has requested that the Secretary of the Navy take steps to remedy the increasing level of pollution the San Francisco Bay-Delta Area. The Senator has also stated that as a member of the Senate Armed Services Committee, he stands ready to urge the Committee and the Congress to help the Department of the Navy in its efforts to stop the pollution. 2. PROBLEMS The generation, handling, and disposal of special chemicals, toxic gases, explosives and other hazardous wastes by Federal activities is of continuing concern. The Working Group made inquiry to the Secre- tary of the Army concerning shipment and disposal of chemical agents. General James Hebbler, in responding, reported that there have been no Department of the Army stocks of toxic chemical agents and/or munitions disposed of within the State of California or within the waters off the California Coast during the past 3 years. There have been small laboratory samples shipped to selected military installations during the past 3 years. However, shipments of commercially-procured poisonous material for installation use, such as chlorine for water purification, insecticides and pesticides, are continuing to be made. 35 Field visits by members and staff aides of the Working Group to several Army installations indicate that large quantities of vehicle lubricants and oils, solvents, paints, and other similar hazardous waste materials are generated. These do not appear to be subject to special handling or control. To date we have been unable to gather sufficient definitive information to access the situation, nor can we develop an adequate estimate of its impact on the environment. 3. RECOMMENDATIONS It is recommended that: a. The designated State agency, in cooperation with members of California's Congressional representation, should conduct a detailed survey of the Federal installations and activities in California to determine the quantities and charcteristics of the wastes that are generated and the provisions that are made for the collection, storage, and disposal of these wastes. b. For each classification or category of wastes where in the opinion of the designated State agency special procedures appear to be required for storage, collection, transport, or disposal, the agency should prepare recommended stan- dards, regulations, operating procedures, or control pro- cedures for issue in the public press and for possible incorporation in Federal legislation, C. The State of California should request the support of California's Congressional representation in preparing legis- lation which will: (1) require the Federal Government to clean up areas of Federally caused pollution or will authorize the State to do so and permit the State to recover the costs from the Federal Government, and (2) establish appropriate regulations and standards for Federal installations and activities which assure that the Federal Government ceases to cause pollution. 36 APPENDIX SOME HAZARDOUS SOLID WASTE SOURCES AND CONSTITUENTS MUNICIPAL REFUSE* Means of Treatment Source Waste Composition or Disposal Households, hotels, Special wastes Hazardous solids and liquids, Incineration, landfill, hospitals, institutions, explosives, pathologic wastes, burial, salvage stores, industry radiaactive wastes Sewage treatment Sewage treatment Solids from coarse screening Incineration, land- plants, lagoons, residue and grit chambers, sludge fill, camposting, septic tanks fertilizing INDUSTRIAL WASTES Means of Treatment Source Waste Characteristics Composition or Dispasal Textile mill Textiles, i.e., Highly alkaline, H2SO,, NaOH, oni- Neutralization, pre- products cotton, wool, and colored, high BOD line chlorine cipitation, trickling silk and temperature, Starch," malt, tin and filtration, aeration, high suspended iron salts, dyes recovery solids bleach, fibers, minerals Cooking Same as textile Far camplete list fibers, desizing mill products of chemicals used of fobrics in textile industry, see reference Rayon, other Acidic, alkaline, Sulfides and poly- Reclamation, neu- man-made mote- inorganic sulfides, colloidal tralization trickling rials, i.e., Acri- sulfur, NaOH, filtration, logoon- lon, Dynel, Orlan, H2SO4, ZnSO₄, ing Nylon, etc. HCI, NaHSO₄, H₂S, CaSO₄; acrylonitrile, phe- nol, HNO3i ammo- nia, adiponitrile, hexomethylene- diamine, sodium carbonate, alcohols, ketones Explosives TNT, colored, acid H₂SO₄, HNO3, Dilution, neutral- Washing TNT and adorous, and can- NO2SO3, picric ization, lagooning, guncotton for tains organic acids acid, TNT flotation, precipi- purification, and alcohol from isomers, capper, tation, aeration, washing and powder ond cotton, zinc, nitrogen, chlorination pickling of metals, acid, oils toluene cartridges and soops Phosphote and Washing, screen- Clays, slimes, Phasphorus, Settling, phosphorus ing, floting tallows, law silico clarification rack, condenser pH, high sus- fluoride (mechanical), bleed-off pended solids lagoaning Fertilizers Nitrogen, phos- phorus, potassium, sulfuric acid, traces of other chemicals **Adapted from: 1. Thrift G. Hanks, M. D., Solid Waste/Disease Relatianships, Aerajet General Carporation, 1967. 2. Sanitary Engineering Research Laboratory, College of Engineering and School of Public Health, University of Californio Berkeley, Comprehensive Studies of Solid Wastes Management Second Annual Report, 1969. 37 INDUSTRIAL WASTES (Continued) Means of Treatment Source Waste Characteristics Composition or Disposal Coke by-products Slag from ovens, Suspended solids, Ammonia, benzene, Discharged to ammonia still volatile suspended H₂SO₄, phenol sewers, dumped, woste, spent acids solids, organic and incineration and phenols NH3-N, phenol, cyanide, acids, alkalis Industrial, not Inorganic indus- Metals and com- Na, K, Ca, chlo- otherwise iden- trial waste or pounds thereof rides, sulfates, tified stabilization bicarbonates, nitrates, phos- phates, fluarides, borates, chromates, etc. Metallic fumes Pb, Va, As, Be and dusts and compounds thereof Industrial Mineral fines Chromates, Underground wastes heavy metals aquifers Treating See "Distillation" See "Distillation"; Reclamation, also lead, copper, settling, filtration, calcium evaporation, neutralization Recovery See "Distillation"; See "Distillation"; See "Treating" also organic esters also iron Leather and Tanneries Organic and inor- Chromium, sulfuric Sedimentation, leather products ganic, high BOD- acid, nitrogen, lagooning lime sludge, hair, CaCO₃, D₂O₅, fleshing, tan liquor, K₂O, Fe bleach liquar, salt, blood, dirt, chrome Energy Fly-osh Hollow spheres of Silicates, Sold for use in producing fused or partially iron oxide, concrete, industry fused silicate glass silica landfills, etc. or as small solid Pulverized coal- spheres of fused fired plants; stoker- silicates, iron fired, cyclone- oxides or silica, fired plants; and unburned carbon wet-bottom and mineral pulverized coal- fired plants Electrical Ash Dust Silicates and industry aluminates of Fe, Cu, Mg with small percentages of Na, K Metal finishing Pickling and Toxic, waste Cu and Cu Sewage industry washing waters alloys liquors Acid wastes Harmful to Cu, Ni, Zn, Cr, Sewage aquatic life, Fe salts of metals 38 INDUSTRIAL WASTES (Continued) Means of Treatment Source Waste Characteristics Composition or Disposal Rubber and Rubber High BOD, odor, Sulfuric acid, tri- Aeration, chlorina- miscellaneous high suspended chlorethylene, tion, sulfonation, plastic products solids, variable pH, xylene, amyl biological high chlorides alcohol, aniline treatment benzene, chromium formaldehyde Aircraft Cd and Cr+ Traces of Cd and Cr+ Leaching pits manufacturing metals industry Waste Well-digested Blackish, amor- Mg, Ca, Zn, Anaerobic decom- treatment sludge phous, nonplastic Cr, Sn, Mn, Fe, position of organic plants material Cu, Pb waste solids Petroleum Spent Liquid wastes with Clays, H₂SO₄, Streams industry chemical oil, acid and alka- H3PO4 line solutions, inorganic salts, organic acids and phenols, etc. Drilling Oil, brine, Sodium, calcium, Separation, chemicals magnesium, evaporation, chlorine, SO₄, lagooning bromine Storage Muds, salt, oils, Separation, natural gas evaporation, lagooning Distillation Acid sludges, Insoluble organic Na₂CO₃, (NH₄)₂S, Settling, filtrotion, miscellaneous and inorganic salts, Na25, sulfates, acid reclamation, oils sulfur compounds, sulfates, H₂S, evaporation sulfonic and nap- NaOH, NH4OH, thenic acids, insol- Ca(OH)₂, uble mercaptides, (NH₄)₂50₄, oil-water emulsions, NH4CT, phenols soaps, waxy emul- sions, oxides of metal, phenolic compounds Laboratory Metallic ions, Landfill or dump wastes phenolics, cyanides, oils, synthetic fibers, pharmaceu- ticals, rubber chemicals Industrial wastes Toxic metals Pb, Be Insecticides Washing and High organic matter, Carbon, hydrogen, See Chemical purification of toxic, acidic Chlor- chlorine, carbon plants (general) products inated hydrocarbons: disulfide, carbon toxaphene, benzene, tetrachloride hexachloride, DDT, aldrin, endrin, dieldrin, lindane chlordane, meth- oxychlor, heptachlor Organic phosphorus compounds: parathion, Malathion, phosdrin, Phosphorus, oxygen, carbon, hydrogen, tetraethyl, pyrophosphate carbon disulfide, carbon tetrachloride Other organic compounds Carbonates, dinitrophenols, organic sulfur compounds, organic mercurials, rotenone, pyrethrum, nicotine, strychnine Inorganic substances Copper sulfate, arsenate of lead, compounds of chlorine and fluorine, zinc phosphide, thallium sulfate, sodium fluoracetate 39