wastes

Screening of incoming loads to prevent the disposal of hazardous wastes in solid

waste landfills is important business.

he presence of hazardous wastes in the municipal solid waste (MSW) stream has become a well-recognized waste manage- ment issue. Recognition of the issue has been brought about by a variety of factors including the results of environmental

monitoring at landfills; the increased sensitivity of lab- oratory instrumentation; the results of solid waste char- acterization studies; observations made in load-checking programs at MSW landfills; and hazardous incidents involving refuse workers and equipment.

Concern over problems that can occur from haz- ardous waste in MSW has led to the development of such alternative hazardous waste management programs as household hazardous waste (HHW) collection pro- grams and smallquantity generator (SQG) management

Karpinski and Glaub are Senior Project Supervisors In response to the environmental threat posed by the with EMCON Associates in Sun Jose, Cali$, and disposal of hazardous wastes in MSW landfills, the US.

spoke on the subject ofscreening for hazardous wastes EPA introduced a new operational requirement as part at the WusteTech conference held this past February. of the revised Subtitle D criteria for the disposal of solid

Bv Gail KarlihsBi and John Glannb programs.

A U G U S T 1 9 9 4 WASTE AGE 91

. .

Screening Hazwaste Contd.

waste. Section 258.20 of Subpart C, 40 CFR 258, includes procedures for random inspections of incoming loads and for the training of facility personnel in the recognition and handling of hazardous wastes. These operating criteria are modeled closely after similar California requirements that have been in effect since 1984 under the direction of the state’s Water Resources Control Board.

The following presents data from environmental monitoring programs at solid waste landfills, discusses the possible contributing factors to the presence of hazardous constituents at these sites, and describes the components of load-checking programs that have been implemented to deter the disposal of hazardous wastes in solid waste landfills.

Environmental monitoring A number of waste characterization studies have pro-

vided estimates of the quantity of hazardous waste in MSW. The results vary considerably. Measurements of the amount of hazardous waste in the residential waste stream range from 0.0045% to 0.4%. Estimates for hazardous waste in the total solid waste stream range from approx- imately 0.1% to 0.4%.

The impacts of hazardous waste in MSW landfills can be evaluated by examining the leachate and landfill gas generated at these sites. For purposes of comparison, 10 organic constituents were selected for this discussion:

W benzene; W carbon tetrachloride; W chloroform;

W 1,2-dichloroethane; W ethylene dibromide; W methylene chloride; W tetrachloroethylene; W l,l, l-trichloroethane; W trichloroethylene; and W vinyl chloride. The 10 compounds were chosen because of the

Leachate data from 53 MSW landfills has been cor- related by the EPA. The concentrations of various haz- ardous organic constituents are shown in Table 1. All 10 chemicals were detected in MSW leachate. Methylene chloride was found at the highest concentrations (220,000 parts per billion) and at the greatest number of sites (60%).

Landfill gas constituents Analysis of landfill gas also reveals the presence of

hazardous wastes in landfills. The results of extensive testing of landfill gas in California are presented in Table 2. The table summarizes results from 288 sites (271 non- hazardous waste sites and 17 hazardous waste sites). The California Air Resources Board (CARB) uses the terms “hazardous” and “non-hazardous” to distinguish between sites that are known to have accepted hazardous waste and sites that are not known to have accepted hazardous waste.

The analyses were conducted on samples of landfill gas drawn from wells within the landfill. All of the 10 spec-

extensive data available on them.

Concentrations of Selected Organic Constituents in Municipal Solid Waste Leachate’

Number of Detected Promulgated Municipal Landfills Concentration Standards of

Characteristic Where Detected Range (PPW Criteria (ppb)

Acetone Benzene Chloroform Methyl Ethyl Ketone Methylene Chloride Trichloroethylene

12 18 8 13 32 17

8 - 1 1,000 4 - 1,000 27- 31 1

1 10 - 27,000 2 - 220,000

1 - 1,300

4,0002 53

5.94 2,0002 4. 84 53

1. Source: U.S. EPA, October 1988 [3] 2. Concentration based on EPA-verified reference list for systemic toxicants and the assumption of a

70-kg (1 54-lb.) adult consuming 2 liters of water per day. 3. Maximum contaminant level ( E P A s drinking water standard). 4. Constituent is considered a carcinogen by the oral route. Concentration i s based on a unit risk

of 1 x IO“, except where noted.

92 WASTE AGE A U G U S T 1 9 9 4

ified chemicals were detected in the landfill gas. The lowest value observed is approximately equal to the detection limit for that compound. Benzene, methylene chloride, tetrachloroethylene, and trichloroethylene were found in more than half of the non-haz- ardous waste landfills; l,l, 1- trichloroethane and vinyl chlo- ride were found in just under 50% of the non-hazardous sites.

Some interesting compar- isons may be noted between the leachate and landfill gas analy- ses. Methylene chloride was found at the highest concentration in leachate, as well as in landfill gas, at non-hazardous waste sites. Ethy- lene dibromide and carbon tetra-

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Screening Haswaste Contd.

chloride were found at the lowest percentages of sites in both the leachate and landfill gas analyses.

CARB concluded that the “overall composition of landfill gases from hazardous and non-hazardous sites appear to be similar, with no major distinguishing char- acteristics, which would indicate from what type of land- fill the sample was obtained.” The Board further states: “The data show that, based on landfill gas testing, there is hazardous waste in 86% of the landfills tested, regard- less of what type of waste the site is known to have accept- ed. The landfill gas testing results show that non-hazardous landfills may contain concentrations of toxic gases equal to, or exceeding, those of hazardous landfills.”

These strongly-worded conclusions-in a report from a major regulatory agency to its state legislature-pre- ceded the load-checking requirements in Section 258.20 of the revised Subtitle D regulations issued by the EPA in October 1991.

A review of the California programs is instructive as a preview of how the Subtitle D operational criteria for loadchecking might impact landfill owners and operators in other states where such programs have not yet been implemented.

Section 2523(b)(2) of the California Subchapter reg- ulations state: “A periodic load-checking program approved by the Department of Health Services and the [California] Regional [Water Quality Control] Board shall be implemented to ensure that hazardous materials

are not discharged at Class I11 landfills.” Note that the California regulations do not specify

how such a load-checking program should be conducted; the frequency of the inspection; or the performance standards by which the programs are to be evaluated by the regulatory agencies.

In spite of the limitations of the regulatory language, since the mid”80s hazardous waste exclusion programs have been developed in California to alert landfill dis- posers, both private and public, that hazardous wastes from whatever source are not acceptable at solid waste landfills. The major intent of these programs is to serve as a deter- rent to improper disposal.

Creating effective programs There are five basic components of effective haz-

ardous waste exclusion programs: customer notification; visual inspection of incoming wastes at facility

waste inspection documentation and record keep-

enforcement; and training of facility personnel.

The first component of these programs, customer notification, consists of informing and educating cus- tomers concerning the dangers associated with the improper disposal of discarded household products that

checkpoints;

ing;

Concentrations of Organic Constituents in Gas From MSW landfills

Non-Hazardous Waste Sites’

Concentration Range ( p p b ~ ) ~

500 - 29,000 5 -2,100

2 - 171,000 20 - 34,100

1 - 2,000 60 - 260,000 10 - 62,000 10-21,000 10 - 20,000

500 - 120,000

Hazardous Waste Sites2

Chemical

Benzene Carbon Tetrachloride Chloroform 1,2 - Dichloroethane Ethylene Dibromide Methylene Chloride Tetrachloroethylene 1,1,1 - Trichloroethane Trichlorothylene Vinyl Chloride

1 , 271 Sites. 2. 17 Sites. 3. ppbv = parts per billion by volume.

94 WASTE AGE AUGUST 1 9 9 4

Percent of Sites Where

Detected

51 8

27 18 7

56 72 49 68 47

Concentration

Range (PPbV)

500 - 79 1,000 <5

2 - 200 20 - 12,000

1-55 60 - 42,000 10 - 10,000 10 - 14,000 10 - 5,700

500 - 60,000

% of Sites Where

Detected

82 0 29 24 12 59 88 59 82 53

contain hazardous constituents. The educational process consists of: 1.) pro- viding the public with examples of household products that are hazardous, such as cleaners, sol- vents, and pesticides; 2.) describing proper handling and dis- posal methods for these products; and 3.) identifying non- hazardous alterna- tives to hazardous products. Public out- reach techniques for educating users include enclosure of informational pam-

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CIRCLE NO. 19 ON READER SERVICE CARD

Screening Huzwurte Contd.

phlets within monthly bill statements, distribution of fly- ers at the landfill, and posting of signs prohibiting disposal of hazardous wastes at the landfill.

The second step in the program-visual inspection of incoming loads-refers to random inspection of incoming wastes by landfill personnel trained in the identification of hazardous wastes. Random, rather than pre-sched- uled, inspections are an important feature of these pro- grams since they serve to make the load checks unpre- dictable, thereby deterring attempts by haulers to conceal prohibited wastes in the loads. The driver of the truck tar- geted for inspection (either a commercial hauler or mem-

ber of the public) is asked to discharge waste in a desig- nated location by pulling forward while off-loading. The narrow windrow created by the discharge is then torn down using a rake or shovel. A trained inspector then care- fully checks the windrow for: plastic jugs; labels indicat- ing the contents include hazardous materials (i.e., pesti- cides or flammable materials); and odor indicators for materials such as petroleum, caustics, chlorine, or other chemical odors. Typical categories of household wastes found include cleaners, batteries, solvents, and brake fluid.

In addition to randomly inspecting incoming loads,

Hazardous Materials in Commercial Products

I Chemical I 1 Potential Products Containing Chemical

Benzene

Carbon Tetrachloride

Chloroform

1,2-Dichloroethane

Ethylene Dibromide

Methylene Chloride

Tetrachloroethylene

1 , 1 , l -Trichloroethane

Trichloroethylene

Vinyl Chloride

Dry Cleaning Fluids, Fumigants, Gasoline, Insecticides, Motor Oil, Paint Remover, Rubber Cement, Solvents (var- ious), Spot Removers

Degreasers, Fumigants, Propellants, Refrigerants, Solvents (various)

Anaesthetics, Fluorocarbon Refrigerants, Fumigants, Insec- ticides, Pharmaceuticals, Solvents (various)

Degreasers, Finish Removers, Fumigants, Gasoline, Paint Removers, Penetrating Agents, Scouring Compounds, Soaps, Solvents (various), Wetting Agents

Fumigants, Gasoline, Solvents (various), Waterproofing Preparations

Aerosol Propellant, Degreasers, Dewaxers, Fumigants, Furniture Refinishers, Hair Spray, Oven Cleaner, Paint, Paint Brush Cleaner, Paint Remover, Septic Tank Cleaner, Shoe Cleaner, Shoe Polish, Solvents (various), Suede Renewer

Degreasers, Dry Cleaning Solvents, Drying Agents, Heat Transfer Medium, Paint Removers, Spot Removers

Aerosol Propellant, Degreasers, Drain Opener, Furniture Pol- ish, Oven Cleaner, Paint Remover, Pesticides, Rug Clean- er, Septic Tank Cleaner, Shoe Dye, Shoe Polish, Solvents (various), Spot Remover, Upholstery Cleaner

Adhesives, Degreasers, Dr Cleaning Fluids, Dyes (solvent- based), Fumigants, Fur C Y eaner, Paint, Pharmaceuticals, Shoe Cleaner, Shoe Polish, Solvents (various)

Adhesives for Plastics, Intermediate in Polymer Production

96 WASTE AGE A U G U S T 1 9 9 4

I _

trained workers also screen loads at other landfill checkpoints, including the main gatehouse and the working face of the landfill. Effective screening is dependent on a trained, alert, and aggressive staff that will confront the hauler of any suspicious load.

The third component of hazardous waste exclusion programs is the docu- mentation and record keeping of load- checking inspections. Section 258.20 (a)(2) of Subtitle D simply specifies “records of any inspections,” leaving the details to the state and local agen- cies. In existing hazardous waste exclu- sion programs, the load-checking inspector typically records:

v

date; time;

W the hauling firm or vehicle owner’s name;

driver’s name; telephone number; vehicle license plate number; and source of the waste (as stated by

the driver). The information is recorded on a

form that is dated and signed by both the inspector and the driver. In the event of finding prohibited wastes, the inspector forwards the data to the appropriate regulatory agencies. Records of all inspections are kept on file at the landfill for a minimum of three years.

Prompt enforcement of hazardous waste exclusion requirements has been a key component of existing programs.

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CIRCLE NO. 31 ON READER SERVICE CARD

Screening Hazwaste Contd.

Parties responsible for attempting to dispose of haz- ardous wastes are required to properly dispose of the p r e hibited waste in accordance with state and federal regu- lations, and to submit proof to the appropriate local enforcement agency that the prohibited wastes were prop erly disposed of.

In cases where prohibited wastes are detected after the responsible party has left the site, the landfill opera- tions manager will either temporarily store the wastes in a hazardous waste storage locker until it can be properly disposed of, or contract with a hazardous waste hauler for the removal and ultimate disposal of the prohibited wastes. Parties responsible for the unacceptable wastes are billed for the costs of handling, transport, and disposal.

Customers who have been found attempting to deliv- er prohibited wastes to the facility are subject to inspec- tion in subsequent trips to the facility. Repeat offenders will be banned from continued use of the disposal site.

Supervisors, gate workers, equipment operators, and spotters should be instructed in one or more of the fol-

lowing, depending on their responsibilities: 1.) physical indicators of prohibited wastes, 2.) typical commercial sources of prohibited wastes, 3.) load-checking proce- dures, 4.) notification requirements in the event unac- ceptable wastes are identified, 5.) record-keeping proce- dures, and 6.) proper handling and/or storage of detect- ed prohibited wastes.

A relatively recent addition to environmental control at solid waste landfills, hazardous waste exclusion pro- grams can be expected to become increasingly sophisti- cated. The RCRA Subtitle D requirements for load check- ing will bring increased attention to the importance of reducing the volume of hazardous wastes that are improp erly disposed of in solid waste landfills. The effectiveness of these programs ultimately depends on a well-trained staff, informed customers, and immediate follow-up with offenders. In many ways, these programs can be compared to preventive health programs: they don't guarantee the elimination of problems, but they improve the odds for a healthy service life for solid waste landfills. I

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98 WASTE AGE AUGUST 1 9 9 4