EPA draft guide addressing the management of industrial nonhazardous wastes

• By Mike Butler
• Oct 01, 1999

Availability of guide and CD-ROM

Each year, industrial facilities generate and manage 7.6 billion tons of nonhazardous industrial waste in surface impoundments, landfills, waste piles and land application units. Generated by a broad spectrum of U.S. industries, industrial waste consists of process wastes associated with manufacturing industries. This waste usually is not classified as either municipal waste or hazardous waste by federal or state laws. Although state, tribal and some local governments have regulatory responsibility for ensuring proper management of industrial waste, their regulatory programs vary widely. For this reason, the U.S. Environmental Protection Agency (EPA) collaborated with states, industry and environmental groups to provide voluntary guidance that defines a baseline of management practices that protect human health and the environment.

EPA announced in the Federal Register (64 FR 31576, June 11, 1999) the release for public comment of a draft guide and CD-ROM addressing the management of industrial nonhazardous wastes. EPA is accepting comments on the guide and CD-ROM until Dec. 13, 1999.

The purpose of the voluntary Guide for Industrial Waste Management is to assist facility managers, state and tribal environmental personnel, and the public in evaluating and choosing protective practices regarding the management of industrial nonhazardous wastes. The draft guide recommends best management practices and key factors to take into account when siting, operating, designing and monitoring units, performing closure and post-closure care, and when corrective action may be necessary. The draft CD-ROM version of the guide incorporates user-friendly groundwater and air models to evaluate potential risks and choose appropriate unit controls.

The draft Guide for Industrial Waste Management and CD-ROM were developed by EPA, with assistance from state representatives from the Association of State and Territorial Solid Waste Management Officials (ASTSWMO), industry and public interest stakeholders. Two separate groups worked on the development of the draft. One group was composed of EPA and state personnel. The second group was composed of EPA, state, industry and environmental representatives who met six times over a two-year period in open meetings to discuss all the issues.

Who can use the guide
Facility managers, state, tribal and local environmental agency staff, and the public can all use the draft guide and CD-ROM.

• Facility managers
: Safe waste management is ultimately in the hands of facility managers. The guide can help facility managers make the decisions necessary to ensure environmentally responsible unit siting, design and operation in partnership with state, tribal and local personnel, and the public.
• State, tribal and local environmental agency staff
: The guide provides a handy implementation reference that may help to complement, or address any gaps that may exist in, a regulatory program.
• Public
: The guide can help the public become more informed partners in addressing waste management issues in local communities.

EPA hopes the guide will facilitate communication and the development of partnerships among stakeholders. It provides a wealth of valuable reference materials in addition to the simple-to-use modeling tools to assess potential air and groundwater impacts. It will give all stakeholders a common technical framework for environmental assessment, as well as for planning and implementing a comprehensive waste management system.

The guide reflects four underlying principles:

1. Protect human health and the environment, emphasizing all environmental media;

2. Tailor management practices to risk in this enormously diverse universe of waste using the innovative, user-friendly modeling tools provided;

3. Reaffirm state and tribal leadership; and

4. Foster partnerships among facility managers, the public and regulatory agencies.

Here are the basics of the approach the guide suggests:

• Understand and comply with all existing federal, state, tribal and local regulations, permits, and operating agreements that apply to the facility.
• Thoroughly characterize waste constituents and concentrations, paying special attention to groundwater and air risks.
• Take advantage of waste reduction opportunities to minimize reliance on waste disposal, reduce disposal costs and conserve raw materials.
• Build an ongoing partnership among the public, regulatory agencies and facility managers.
• Tailor management practices to the wastes and the environmental setting of the unit. The guide recommends tiered, risk-based approaches to choose appropriate management practices.

Major components of the guide and CD-ROM
Building partnerships. The guide recommends that stakeholders develop a partnership to build trust and credibility between a company that generates and manages wastes, the community in which the company lives and works, and the state agency that regulates the company. The guide recommends various principles designed to build partnerships. These principles embody sound business practices and common sense, and can be adopted throughout the operating life of a unit, not just during the permitting phase.

Characterizing wastes. The guide emphasizes the importance of understanding the chemical and physical properties of a waste and the need to understand sampling and analysis procedures. Knowledge of the chemical and physical properties of a waste is crucial in gauging what risks a waste may pose to groundwater, surface water or air, and in identifying waste reduction opportunities.

Integrating pollution prevention, recycling and treatment. The guide, although focused on waste disposal, highlights the need to consider pollution prevention, recycling and treatment options when designing a waste management system. Pollution prevention and recycling reduce waste disposal needs and can minimize impacts across all environmental media. Treatment can reduce the volume and/or toxicity of a waste.

Considering the site. Many hydrologic and geologic settings can be effectively utilized for protective waste management. There are, however, some hydrologic and geologic conditions that should be avoided, and if they cannot be avoided, special design and construction precautions should be taken to minimize risks.

Hydrologic and geologic conditions to avoid include:

• 100-year floodplains;
• Wetlands;
• Seismic impact zones;
• Unstable areas;
• Active fault areas;
• Sites in the vicinity of airports; and
• Wellhead protection areas.

In addition to avoiding certain locations, the use of buffer zones and compliance with local land use and zoning considerations are important to address when selecting a potential new site for an industrial waste management unit.

Protecting air quality. Health effects from airborne particulates and toxic air emissions can range from minor to chronic. Units should implement controls to address particulate emissions because particulate emissions can have immediate and highly visible impacts on surrounding neighborhoods. For toxic air releases, a facility may be subject to regulations under the Clean Air Act, but if not, the guide contains software to determine if toxic air releases are a concern and should therefore be controlled. The software is called the Industrial Waste Air Model (IWAIR).

Site-specific information necessary for IWAIR includes:

• Unit location;
• Waste management unit characteristics;
• Waste characteristics; and
• Receptor information.

The IWAIR is an interactive computer program with an emission, a dispersion and a risk model to calculate either the risk to exposed individuals or the waste constituent concentrations that can be protectively managed in a unit. The program requires only a limited amount of site-specific information highlighted in the text box.

Protecting surface water. The guide recommends that facility managers limit the discharge of pollutants into U.S. waters. It focuses on reducing stormwater discharges by complying with Clean Water Act regulations and implementing best management practices (BMPs).

Site-specific BMPs include:

• Flow diversion structures;
• Exposure minimization practices;
• Sediment and erosion prevention;
• Infiltration practices;
• Other prevention practices; and
• Mitigation practices.

BMPs should be used in conjunction with engineering and physical mechanisms to control stormwater run-off and reduce or eliminate contaminant releases to the environment.

Protecting groundwater. Protection of groundwater resources can be accomplished by assessing the risk associated with the waste management activity and tailoring management controls accordingly.

The guide recommends tailoring protective liner systems to the wastes that are managed in a unit and evaluating whether land application is appropriate using a three-tiered approach to groundwater modelling and risk assessment.

• Tier 1 - National evaluation
• Tier II - Location-adjusted evaluation
• Tier III - Comprehensive risk assessment

The type of assessment depends on the complexity of the site and the characteristics of the waste. All three tiers rely on groundwater modeling. The modeling software for Tiers I and II is called the Industrial Waste Evaluation Model (IWEM).

The IWEM makes recommendations as to the type of liner system to consider. Liner systems are employed to minimize groundwater contamination. Appropriate liner system designs may include in situ soils, single liners or composite liners. The use of leachate collection and leak detection systems is also appropriate in certain circumstances.

• Clay liners have a minimum thickness of 2 to 5 ft with a maximum hydraulic conductivity of 1 x 10-7 centimeters per second (cm/sec).
• Synthetic or flexible membrane liners (FML) have a minimum thickness of 30 mil (except for high density polyethylene (HDPE), which needs to be a minimum of 60 mil).
• Composite liners have two components: a top FML over a clay layer where the component layers have the same minimum specifications as an individual single liner.

The IWEM also helps a user to determine if land application of a waste should be considered. The guide presents an evaluation framework to account for a variety of waste parameters, constituents that may present a risk, and other factors such as soil properties and plant and microbial nutrient use.

Operating the waste management system. A waste management system should include procedures to monitor and measure the performance of the unit. A waste management system should also have operational elements in place to achieve environmental goals and to allow for continual improvements in the waste management operations.

Operational aspects of a waste management system include:

• Operating plan waste analysis;
• Waste inspections climate considerations;
• Employee training recordkeeping;
• Emergency response plans; and
• Addressing nuisance concerns.

Monitoring considerations. A waste management unit needs to have carefully designed and implemented monitoring programs in place. These monitoring programs are used to evaluate whether a unit meets performance objectives and whether there are releases and impacts on the surrounding environment that need to be corrected. Effective monitoring programs protect the environment, improve unit performance, and help to reduce long-term costs and liabilities associated with industrial waste management. The guide discusses monitoring programs for groundwater, surfacewater, soil and air.

Corrective action. The guide discusses the need to take appropriate steps to remediate any contamination that is detected at a waste management unit. Corrective action includes an evaluation of potential corrective measures and the selection of a remedy that is designed to attain a cleanup standard. The correct action process includes unit assessment, unit investigation, interim measures, corrective measures evaluation and corrective measures implementation.

Closure and post-closure care. Providing closure and post-closure care is an integral part of a unit's overall design and operation, helping to reduce or eliminate threats and the need for potential future corrective action. The guide recommends that closure be accomplished by one of two mechanisms: closure by use of a final cover or closure by waste removal. In order to properly plan and accomplish the goals of closure and post-closure care, waste management units also need to provide adequate levels of funding for planned activities. Mechanisms that may be used to provide adequate funding include prepayment surety, guarantees insurance, corporate guarantees and financial tests.

This article originally appeared in the 10/01/1999 issue of Environmental Protection.