Definition of Discipline Activities: Hazardous
Waste Management
Definition of Discipline Activities: Hazardous
Waste Management
Waste management is not a new activity for the U.S. There have been a large
number of laws, regulations, ordinances, etc., about solid
and hazardous waste management over the years. Waste management terminology
has correspondingly changed over time to reflect the state of waste management
at the time of the new law, regulation, ordinance, etc.
The Federal Government passed the Resource Conservation and Recovery Act (RCRA)
in 1976. It was the latest Federal update on solid and hazardous waste management.
The implementing regulations should have quickly followed. They did not. The
reason for their four-year delay was the complexity of developing regulations
that were fair to the diverse stakeholder community while still meeting the
intent of the law.
As the time dragged on past 1976 without the enabling RCRA regulations, the
U.S. Environmental Protection Agency (EPA) became concerned about assuring
enough disposal capacity for commerce in the U.S. In 1979, they published
"Siting of Hazardous Waste Management Facilities and Public Opposition," SW809,
Washington, D.C. November 1979. The EPA felt that the major difficulty in
ensuring present and future hazardous waste disposal capacity was public opposition
to the local siting of a disposal facility. Past negative publicity on hazardous
waste landfills had increased the opposition to new disposal sites.
A 1980 public opinion survey regarding waste management facilities conducted
by the White House Counsel on Environmental Quality reported that " . . .
a majority of the respondents endorsed new secure, regularly
inspected facilities but only if located over 100 miles from their home."
In 1980, the EPA published "Hazardous Waste Generation and Commercial Hazardous
Waste Management Capacity, An Assessment," SW894, December 1980. This document
stated " . . . in 1981, most areas of the country will have sufficient offsite
capacity to manage hazardous waste, but some areas are likely to face shortages
. . .". It went on to say " . . . demand for offsite capacity is difficult
to estimate because it will depend on government regulatory activities and
the industry's response to the regulations."
States responded to this potential shortage of hazardous waste disposal capacity
for their industries by implementing strategies to hopefully assure sufficient
capacity. A 1982 Texas Report "Siting of Hazardous Waste Disposal Studies
in Texas" noted that " . . . other states facing the same problems of increasing
waste, public opposition, and administrative fragmentation, have reacted in
different ways. Twenty-one have passed special siting legislation that gives
them additional control over the siting process. Although each law is different,
we can distinguish three dimensions among which states can make policy choices,
state initiative, local power, and public participation." The report went
on to show that fourteen states had chosen to establish separate siting boards,
as the first step in taking control of the siting process.
One result of the potential capacity shortage was for waste management firms
to try to secure more disposal capacity. The waste management industry was
in an explosive growth period with revenues that had increased four to five
times in the 1971-1980 period (reference EPA SW-894 dated December 1980).
Terminology:
Waste, by its very nature, is not a uniform product and as such the terminology
dealing with waste has always had to deal with its non-uniform nature. Over
the past 28+ years, the terminology used in the waste management community
has come from a wide variety of governmental, regulatory and environmental
entities such as cities, counties, agencies, boards, authorities, associations,
districts, councils, State and Federal agencies, etc. This diverse community
of waste management stakeholders across the U.S. has used a multitude of terms
describing the various facets of waste management in their laws, regulations,
rules, guidance documents, etc. Some examples include:
Waste
Solid Waste
Hazardous Waste
Hazardous Substance
Hazardous Material
Hazardous Constituent
RCRA Hazardous Waste
Non RCRA Hazardous Waste
Extremely Hazardous Waste
Extremely Toxic Liquid or Solid
Highly Toxic Liquid or Solid
Special Waste
Carcinogenic Wastes
Incompatible Waste
Imminently Hazardous Chemical Substance
Toxic Pollutant
Pollutant Contaminant
Flammable Liquids
Flammable Solid
Ignitable Waste
Corrosive Waste
Reactive Waste
Toxic Waste
Oxidizing Material
Corrosive Material
Combustible Liquid
Irritating Material
Disposal Facility
Facility
Existing Hazardous Waste Management Facility
New Hazardous Waste Management Facility
Transfer Facility
Hazardous Waste Management Unit
Operable Unit
Miscellaneous Unit
Landfill
Land Treatment Facility
In many cases, there were and still are different systems and protocols relating
to a single word or term. For example, the EPA published a document in 1975
called "A Summary of Hazardous Substance Classification Systems," which described
the 23 systems that were being used primarily for regulatory purposes to define
a "hazardous substance."
Technology:
Just as the terminology related to hazardous waste management has changed over the years, so has the technology that has been used to manage wastes. Some technology that was in the past fully approved by the regulatory community is now not felt to be "best practice". In some cases the results of certain technologies that have been used in the past are not as effective as hoped. Legal disputes therefore arise.
Stakeholder Response to Terminology/Technology:
The inherent exhaustive nature of waste management terminology caused and
still causes a certain amount of confusion (and legal disputes) among people
actively involved in the waste management process (i.e. the stakeholders).
Similarly, changing technology and expected versus achieved results over time
can also lead to disputes. When disputes arise (related to waste management
practices in the past) it often takes a number of technical specialists to
analyze the regulatory and technical components of the dispute and to find
the appropriate resolution. Such ELA disciplines as: hydrogeology,
environmental geology, chemistry,
toxicology, health and safety,
microbiology, epidemiology, as well as civil and metallurgical
engineering are often called into action in many such disputes. Any of the above
activities also can be involved in litigation. Inappropriate or misrepresented
data or methods are, in many instances, the basis of litigation involving activities conducted
within competing disciplines, practiced in some cases by unqualified individuals not having appropriate training and experience and the associated professional certifications and/or state licenses that are required by various States.
Substantial information is available from the numerous federal agencies involved in hazardous waste management activities. One of the principal sources of technical information is the searchable database produced over the years since 1972 by the National Ground Water Association. For the cost of membership only, more than 70,000 papers, publications, and texts are searchable by key words.
For further information on the discipline, the Institute
of Environmental Technology sponsors an Internet Resources Portal, click (here).
The ELA Principal responsible for the above activities is:
Note: The environmental field is multi-disciplinary by nature and, for maximum effectiveness, ELA incorporates input from complimentary disciplines, when appropriate, in most projects undertaken.
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Last Update: October 8, 1999