Hazardous Waste Dumping in
Solid Waste Landfills
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well as its references to outdated regulations.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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