BUSINESS MANAGEMENT: EPA Publishes Industrial Solid Waste Management Guide

Currently, environmental regulations covering the industrial facilities that generate and manage 7.6 billion tons per year of industrial non-hazardous solid waste (ISW) vary from site-to-site, depending on the state, local and Native American tribal governments that oversee them.

To provide states with guidance and technical assistance in developing their regulations for industrial waste landfills, surface impoundments, waste piles and land application units, the U.S. Environmental Protection Agency (EPA), has developed a voluntary "Guide for Industrial Waste Management" in both hard copy and CD-ROM formats.

Working in partnership with 12 state agencies and numerous industry and environmental representatives for more than two years, "we tried to recommend a baseline of protective management practices for industrial waste units that people can use when designing and operating their units," says Paul Cassidy, an environmental engineer with the EPA's Municipal and Industrial Solid Waste Division, Crystal City, Va. The document is a guide for individual states, industries and people in the environmental community - both novices and experts - to use when making decisions regarding appropriate industrial waste management, he says.

The guide focuses on disposal, but it also includes chapters on public involvement and pollution prevention. Concrete examples of where to get technical assistance also are provided.

According to the guide, when designing and operating an ISW unit, managers should thoroughly characterize waste constituents and concentrations, and pay special attention to potential groundwater and air risks. Units also should take advantage of waste reduction opportunities to minimize reliance on waste disposal, reduce disposal costs and conserve raw materials, taking into account the waste generator's environment.

A range of management issues, such as siting a unit, operating a unit, making liner system recommendations and monitoring a unit at closure are discussed. A tiered, risk-based approach is suggested when choosing the appropriate liner system.

For example, when choosing a liner system design, managers should choose a recommended system that protects groundwater. The CD-ROM's software uses a three-tiered approach to analyze the waste transport system through subsurface soils to groundwater and to evaluate the proper liner system.

Tier 1: Generic Recommendations. Once concentrations of constituents in waste are known, "lookup tables" will recommend appropriate liner designs. If the waste contains several constituents, managers are directed to choose the most protective liner. Implementing pollution prevention or treatment to remove problem constituents so that a less costly liner is necessary also is suggested.

Tier 2: Location-adjusted Assessment. Managers then are directed to use their own data regarding a limited set of sensitive and site-specific variables to assess whether a liner system is protective.

Tier 3: Comprehensive Risk Assessment. This tier relies on a comprehensive analysis of specific waste and site characteristics to assess whether an alternative liner design is protective. A number of models are identified in the guide for this detailed analysis. For instance, the software will look at your type of waste and expected leachate concentrations to recommend a liner system. The guide and CD-ROM also contain a chapter on protecting air and contain software that allows users to determine whether volatile organic compounds could be a problem and suggest where you might need air quality controls.

Overall, the guide is designed to provide easy-to-use modeling tools to assess a site and gives states, environmentalists and industry professionals a common technical framework for environmental assessment. The guide also should help users plan and implement a comprehensive waste management system while fostering partnerships among facility managers, the public and regulatory agencies.

The EPA released the draft guide in hard copy along with the CD-ROM, which will include both the groundwater and air software, for public comment in March 1999. All interested parties can evaluate it and provide feedback for improvements. Contact Paul Cassidy at (703) 308-7281 for information.