Hazardous Waste and Nuclear Waste

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Class #6

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Homework:

Homework #5 due before move on to Class #7. Submit to Professor Auberle and me. Class #7 Professor Auberle will discuss special problem of Nuclear Waste.

Case study report due before Class #8. Should be nearly finished with that.

Research paper due before take final.

Any questions, contact Professor Auberle and me.

Class #6 Slide Show:

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SARA Title III; the public’s "right to know".

1. Announcements

2. Current Events

3. How to Reduce the Amount of Hazardous Waste Produced

RCRA some reduction (also indirect reduction because of increased costs), but focus is on management (tracking)

CERCLA some reduction (also indirect because of liability concern), but focus is on cleanup

Is another approach that has had more impact on waste reduction. Bit of background:

Work for Syntex March, 1985. December 1984 Union Carbide plant in Bhopal, India explosion, release methyl isocyanate killed thousands. Syntex Board wanted to make sure couldn’t happen their chemical plants. Emergency Prevention and Response Program: Investigation and reports potential each plant with recommendations for corrections. Board approved money and set up committee to monitor changes. Audit team (including me) to each plant several times to audit progress, audit reports to committee. Included information for community about plants and what to do in emergency.

EPCRA: Congress also responded to Bhopal tragedy. Superfund Amendments and Reauthorization Act of 1986. One part, Title III, what is called Emergency Planning and Community Right to Know Act (EPCRA).

Two parts:

Develop emergency plans for responding to unanticipated releases of "extremely hazardous substances"

Collect and disseminated information on toxic releases to environment

Covered businesses: required to notify state and local emergency planning entities of presence and quantities in inventory certain chemicals and to notify federal, state and local authorities of planned and unplanned releases to environment. Heavy penalties for failing to comply.

EPA using data collected as building blocks other substantive regulatory programs and citizen groups using data for public disclosure and litigation

EPCRA Emergency Planning: First Part: Emergency Planning: enables states and community to respond to releases of certain hazardous substances

State Emergency Planning Committee (SERC) and Local Emergency Planning Committees (LEPC) responsible for developing and implementing emergency response plans required by EPCRA.

Facilities at which specified "extremely hazardous substances" are present in excess of "threshold planning quantities" required to do two things:

Must notify SERC that those substances present and provide their LEPC with name facility rep who will participate in planning process

Must report releases of extremely hazardous substances in excess of "reportable quantities" as well as releases of other CERCLA substances in excess of RQs to LEPC, SERC, and National Response Center

Note: CERCLA has separate release reporting requirement for CERCLA substances:

CERCLA Reporting Requirements:

Person in charge of facility

Immediately

CERCLA Hazardous Substance

In excess of reportable quantity

Notify NRC.

Regulations list hazardous substances and RQ for each substance.

EPCRA Reporting Requirements: Second Part: Reporting Requirements:

Facilities at which "hazardous chemicals" are present in excess of specified thresholds are required to submit copies of Material Safety Data Sheets (MSDSs) or list of substances with MSDSs to SERC, LEPC, and local fire department.

Notice to emergency planners and responders

Annually must also submit yearly and daily inventory information on quantities those materials and locations at facility (Form R)

Annual reporting to EPA and state on environmental releases of listed "toxic chemicals" manufactured, processed, or otherwise used at facility in excess of specified threshold quantities (note includes releases to all environmental media). (Note also only for listed toxic chemicals and only if above threshold quantities). See below for reporting of unplanned releases under CERCLA.

b and c based on "reasonably available data", including monitoring and emission measurements but if no such data exists reasonable estimates may be used. If estimates, must state basis for estimate (monitoring data, mass balance data, emission factors, or best engineering judgment).

Covered businesses for Release reporting:

Covered Businesses:

1. Manufacturing operations (SIC codes 20 through 39)

2. 10 or more full-time employees, and

3. Manufactures, imports, processes, or otherwise uses any of toxic chemicals on EPA list of 651 chemicals in amounts greater than "threshold"1 quantities.

1992 manufactures in US reported release 3.1 billion pounds of toxic chemicals into environment. Also transferred 4.3 billion pounds off-site for disposal. Information from toxic release reports available to public. Citizen groups regularly publish data to try to bring pressure on companies to reduce releases.

Syntex Graph

Caveat: Not all facilities covered and reports not include all, or even most of pollution.

Known problems in data collection methods:

1. Some facilities may not be complying, either by failing to report or reporting only for some of covered chemicals. (EPA survey estimated 66% compliance 1987: EPA believes better now because of outreach and enforcement.)

2. Much of reporting based on estimated data; does not require monitoring of releases.

3. EPA limited number of data quality inspections; otherwise data not independently verified. (EPA survey 1987 over 75% facility estimates within factor of 2 of EPA engineer’s best estimates.

EPA actions to improve data, including outreach, inspections, enforcement, sharing data with states to make sure receiving same data.

Some release amounts estimated using monitoring data or measurements for process; may also be calculated using mass balance, published emission factors, or other approaches such as engineering calculations or best engineering judgment.

Known problems in measurement methods:

1. Reflects releases of chemicals, not exposures of the public to those chemicals.

2. Release estimates aggregate annual estimates and do not provide information about peak concentrations

3. Estimation techniques not exact science; needs further research and development.

But TRI certain advantages:

Multi-media (air, land, water, underground separately and how much sent off-site

All quantities in pounds

Congressionally mandated to be publicly available

Example RTK NET on Internet; EDF on Internet. Will discuss more in Class #8.

Reminder:

Current event reports important part of class. Welcome at any time.

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brback.gif (1060 bytes) ENV 410C - Lectures

ENV410 - Environmental Regulations
Last Updated:  12/16/98