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States Must Close the Gaps HAZARDOUS WASTES MUST BE PROPERLY IDENTIFIED AND KEPT OUT OF MUNICIPAL SOLID WASTE LANDFILLS AND INCINERATORS In 1996 EPA completed a Hazardous Waste Characteristics Scoping Study to determine whether the tests for hazardous wastes fully protect public health and the environment. The study clearly shows that the current federal testing program allows some hazardous wastes to be disposed of as ordinary solid waste. But EPA has failed to implement the changes recommended by the Scoping Study. Wastes that are ignitable, corrosive, reactive or toxic are being disposed of in solid waste landfills. The EPA identified major failures in hazardous waste protection. The Scoping Study found that the tests and criteria used to determine if waste are ignitable, corrosive, reactive or toxic omit important factors, leading to incomplete assessment of hazardous waste. Ignitability The Study found that a gap exists in the present criteria because the EPA excludes liquids with flash points between 140 degrees and 200 degrees. Corrosivity The Study notes gaps exist because there is no test for solids and no test addresses corrosion of non-steel materials. The report noted in the inherent limitations of the pH test for corrosivity. Reactivity The Study finds gaps due to the lack of specificity in the definition of reactivity as well as its references to outdated regulations. Toxicity Most importantly, the Scoping Study concluded that the test for toxicity fails to consider hundreds of chemicals that cause waste to be hazardous to public health. EPA’s regulations require use of the Toxic Characteristic Leaching Procedure (TCLP) to identify wastes that are toxic. Of the hundreds of toxic chemicals that are used by industry, only 43 are subject to the TCLP test. If none of the 43 specific chemicals are found, but other dangerous toxic chemicals are present, the waste is not considered hazardous and is sent to municipal landfills and municipal incinerators. North Carolina regulations now accept the TCLP tests. The TCLP test fails to accurately duplicate conditions commonly found in landfills and does not accurately predict long-term mobility of organic contaminants in wastes. Further, the toxicity test only addresses the health risks from drinking water contamination. Chemicals that are toxic through inhalation or would contaminate surface waters such as persistent and bioaccumulative toxics are not covered by the TCLP. The study notes that groundwater-modeling techniques used to set the toxicity characteristic levels have changed significantly since the TCLP was promulgated and that many states use more accurate alternative tests. State waste management public health agencies must develop rules which require better tests to protect citizens from hazardous wastes BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE www.BREDL.org
~ PO Box 88 Glendale Springs, North Carolina
28629 ~ Phone (336) 982-2691 ~ Fax (336) 982-2954
~ BREDL@skybest.com
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