Document LK3xY2zxxJY0dQNKbxG4KkQj3

(ArcirffoTtududU) BOX 538 ALLENTOWN, PA. 18106 .PHONE 215-398-8339 from tht tftsk of ANTHONY J. DIGLIO 15 February 1980 TO: RE: "Hunt the Dump" Campaign Environmentalists launch a "Hunt the Dump" campaign to create public and government awareness o potentially hazardous disposal sites. Organic Manufacturing is at the top of the list of their targeted industries. AP00025t25 1 * t hunt the dump an Environmental Action, Inc., and Sierra Club campaign to locate and expose the nation's unsafe hazardous waste sites In July, 1979, the Massachusetts Department ofEnvironmental Quality Engineering ordered the W.R. Grace chemical company to eliminate the dumping ofhazardous wastes at its plastic plant in Acton, Massachusetts. The order was the culmination of excdlfillLllalMliiaa^afld^ilizeiLaclMsinJfidJa-a-COfe -ffoumfSierra duT mem^rs._Tj^rJerwasttiefirst that the state had issued to control_hazajjoiisjwas?fe^se^^^^j^rts|^ It all start3"wHgiraiBrHBtnB8BBgSTTIWH!gBH!llgBBS!SS5!!3Kst!iatMaT!58nHBeS3n5cal residents, hiked a long a railroad spur and photographed colorful open lagoons into which odorous chemicals from the plant were being discharged These photos were shown to the public, press, and town officials, raising public awareness of the possible dangers of an operation which had previously been unknown to most residents. And they didn't stop there. When samples of water from a well which supplied the town's drinking water revealed the presence ofvmyfchloridejavhulentcmme^ausingaeent, W.R. Grace claimed it was no longer using the chemical. Citizens mlced backT^Ju^fiE^ItJuneporter^mcfipnotographed tank cars stencilled with the words vinyl chloride on the side. This is iustone ofmany stories that illustrate what citizens can do to ri|odyjiMicgffici|laeaiIliaaiihliaatIarge into addressing the serious threats posed by the improper dispOT^of^HaRmRRemlcal wastes. Citizens must organize and force government and industry to act to protect our public health and environment To help enable citizens to dojust that the Sierra Club and EnyimainailaL&filiflilJiay&iaunched a national HmmhdBmnn. _tfgSE3SmT5es^ne3togIv^i3zensffle,tooIs to track down thesecherrucanngntmarosHKPCJ^^Wgiwillfoou^ national attention on the real culprits -- the polluters themselves. But before we look at the Campaign, let's first take a looRffTB^rSBIBHP"TM-" ton upon toxic ton How big a problem is hazardous industrial waste? The U.S. Environmental Protection Agency (EPA) esti mates that approximately 77 billion pounds ofhazardous waste are generated annually. While EPA has the authority to regulate ftitiire hazardous waste disposal, the disasters at Love Canal, Valley of the Drums, and elsewhere raise major concern about the threats from the billions of pounds of hazardous wastes disposed in the past. EPA estimates that there are roughly 32,000 abandoned or closed (inactive) dumpsites. However, since over 90 percent of all hazardous industrial waste disposal occurs at the site of generation, no one knows how many dosed sites exist or how many threaten health or the environment. The House Commerce Committee's Subcommittee on Oversight and Investigation was so concerned with the lack of information that it conducted its own survey of 1,605 facilities owned by the 53 largest chemical companies. The survey revealed that 762 million tons of chemical process waste, not all of it hazardous, have been disposed at 3,308 facilities since 1950. Thirty-two percent of these facilities are closed and are not being monitored for possible health and environmental hazards. The survey did not reveal how safe anyofthe sites are, particularly the closed sites where encroachment by resi dences and human activity is more likely. Citizen inquiry about the sites used by hazardous waste generating companies in their communities will help ensure that these companies shoulder their respon sibility to safeguard disposal facilities. Citizens can focus public attention on potential problems and encour age remedial action before additional Love Canals, on a more modest scale, can occur. We urge you to use the Hunt the Dump Campaign to target the hazardous waste generators in your community that may be improperly disposing of their wastes. AP00025126 Cjoals of the huiht * The basic objective of Hunt the Dump is to determine where past and present haz ardous waste sites are and whether the sites are likely to leak dangerous chemicals that could cause health or environmental problems. Government officials arc moving very slowly to ad dress the hazardous waste problem, partly because they fear the problem is too big to handle with existing re- The Hunt the Dump Campaign involves four parts: 1. Targeting manufacturing companies for the survey 2. Submitting a questionnaire to each company 3. Evaluating each company's disposal sites 4. Creating public and governmental awareness of potentially hazardous disposal sites sources. By using the en closed questionnaire to ask local hazardous waste gen erators about their disposal practices, citizens can pro tect themselves by identifying actual and potential hazard ous disposal sites long before the government will. In addi tion. by sending the ques tionnaire to us, you can assist in defining the seriousnes s of the hazardous waste problem nation-wide. A TOXICS LEXICON Amides. Amines, and lmides are Kisi: chemical building blocks in chemical and plastics production. Various members of this class of chemicals cause cancer, birth detects and genetic damage in test animals or test organisms. Many are toxic to acqualic life at low concentrations. Arsenic is used in the production of boric add and pharma ceuticals. Arsenic can cause brain damage, nervous system damage, gastrointestinal damage, and skin lesions. There is epi demiological evidence of carcinogenic action of arsenic in skin and lung of humans. Arsenic causes birth delects and genetic damage in test animals. Benzene is used widely as a solvere in chemical processes. Benzene exposure to humans in the wot k place is known to cause leukemia. Cadmium is used in industry, principally in electroplating, cadmium-silver oxide battery production, in pigment manu facture. and as a plasticizer, chiefly in polyvinylchloride. Low level intake of cadmium over a long period of time is known to cause damage to kidney function. Cadmium has also been associated with hypertension, it has caused tumors in rats and is also known to be teratogenic (cause birth defects) In rats. Carbon Tetrachloride is used in numerous chemical processes, dry cleaning and degreasing operations. Carbon tetrachloride has caused acute poisoning through liver and kidney damage. It is a carcinogen in laboratory animals and a suspected human carcinogen. Chromium is principly usedinelectroplatingprocesses and paint pigments. Hexavalent chromium has king been recognized as a toxic substance. It produces hemorrhages of the gastrointestinal tract after ingestion. Airbom chromium has caused cancer ofthe respiratory tract in occupationally exposed humans. Copper is a gastrointestinal tract irritant and can be highly toxic. Acute episodes have been reported from ingestion of carbonated beverages that were in contact with copper vessels. Ester and Ethers are a family of hydrocarbons, most commonly used in pesticides and herbicides, and generated during petro leum refining. Some have caused cancer in test animals and arc highly toxic to mammals. Land farming is the application onto land or incorporation into the surface soil, including the use of waste as a fertilizer or soil conditioner. Landfill is a land area whichmay or may not be excavated, where solid, semi-solid or liquid wastes are emplaced for permanent deposition. Such wastes may or may not be compacted or segregated by soil barriers. Leachate istheliquidthathas percolated through ordrained from hazardous waste and contains components removed from the waste. Lead is used in the manufacture of pigments, lead acid batteries and is found as a by-product in metal smelting. While acute lead poisoning is extremely rare, exposure to low levels of lead over long periods of time can cause brain and bone damage. Lead has caused malignant tumors in test animals. Manganese is found in metallurgical processes Including steel, making, aluminum manufacture, and also in electroplating. Chronic exposure may result in permanent crippling. Symptoms include sleepiness, leg cramps, increased tendon reflexes, emo tional disturbances, and spastic reflexes. Chronic manganese poisoning results in progressive deterioration of the central nervous system. Mercury is used in the production of chlorine, caustic soda, electrical apparatus, as a plasticizer, in metallurgical processes and chemical production. Hex avalent mercury is known to cause brain damage and damage to the central nervoussystem. It is also teratogenic and can cause genetic damage in humans. Pits, Ponds, and Lagoons are a natural topographic depression, artificial excavation, or dike arrangement above, below, or par tially in the ground for holding, treating, or storing waste. Selenium is used in manufacture ofelectronics equipment, steel, pigments, glass, and ceramics. Acute exposure to selenium can cause eye. lung, and heart damage. Trichloroethylene (TCE) is used as a solvent TCE is toxic to both aquatic organisms and humans. It has been shown to be an effective carcinogen in test animals. AP00025127  he House of Representatives' Tsurvey provides the best starting point for your hunt however, surveys of facilities not listed are of greater value. (For copies of the House lists, write to A. Blakeman Early. Sierra Club. 330 Pennsylvania Ave.. S.E., Washington, D.C. 20003.) Most chemical waste disposal occurs at the site ofgeneration. Therefore, those enterprises that are located near routes step #1: of human exposure pose the gravest threat. The box at right lists the cate gories and the standard industrial code targeting numbers of those industries that EPA has found to generate the most hazard ous waste. Using various sources manufactu r i ng (Thomas Register of American Manu facturers, Dalton's Directory, local Chamber of Commerce publications, companies publications of state and local govern ment economic agencies, etc.), you should be able to find out if any ofthese industries operate in your locale. With the aid ofa zip coded street map, you can then pinpoint the enterprises and deter Category Organic Chemicals Manufacture Standard Industrial Code # 2861 mine just where you might find a haz ardous dump. Pesticides Manufacture Explosives Manufacture 2865-2869 2892 .... v. . fter this list of targets is identi Afied. water supplies and com munity activity centers require special detective work. Ferrous Metals Electroplating Inorganic Chemicals Manufacture 3312,3313,3399 3471 2812-2819 Surface Water -- First check where your source of public water supply is lo cated. If it is a river, concentrate on those enterprises located up-river from the drinking water in-take. Also target facilities located on the banks of major tributaries. If your municipality uses a reservoir for drinking water, the job is more complicated, for you wilt need to target facilities located in the reservoir's "watershed," or water collection basin Local drinking supply officials should be able to help you identify all major sources ofwater supply. Also ask these officials for information regarding.what contaminants have been identified in your drinking water. Non-ferrous Metafs. . Textile Mill Products. Petroleum Refining Plastics 3b Synthetics Manufacture Special Machinery Leather Tanning Paint & Allied Products Pharmaceutical Manufacture Petroleum Rpfihigjg,, ttubberOrioda Electronic Components Battery Manufacture _ 3331-3341 2201-2294 ` 2911 2820-2829 3550,3570 r' 3111 v 2851 . 2831-2834 2992 ' ... -- 3011,3021.3031,3041,3069 3670 ......... . ; 3691,3692 Ground Water-- Yourdrinkingwater may come from wells drilled into under lying ground waters. Find out where these wells are located. Identify target companies that are "upgradienf' (the equivalent of up-stream) from these wcils. Also learn how deep this ground water is and where the "re-charge" zones arc located. Recharge zones are the areas which allow surface water to enter the ground water. Leam where nearby private wells arc located. Ask local drinking supply and public health officials ifowners of these private wells have complained of contamination. Questions that local drinking water of ficials either will not or can not answer should be directed to state water survey or geological survey organizations. Also check with the U.S. Geological Survey and state universities--some of these officials may be able to identify target companies for you. Ask state water pol lution control agencies and the regional U.S. EPA for the location of target companies that have waste water discharge permits. Often these com- patties are dumping on the land the haz ardous wastes that these agencies have prohibited from being discharged di rectly to the water. CommunUyActivitlej -- You will also need to determine areas of your com munitywhere residential or recreational facilities are in close proximity to indus trial companies. These areas are where direct human contact with hazardous waste is most likely. L.' AP00025129 step submitting the questionnai ne he next step involves present the questionnaire to the target companies. While this can ob viously be done by mail, we suggest that an interview be arranged with the plant manager or other appropriate official to review the concerns you and other rep resentatives from the community may have. Gather as many prominent citi zens as you can interest. The nature of the response is dependent upon a num ber of factors. The company wants to maintain a favorable public image. On the other hand, it does not want to reveal information that will be of use to com petitors or subject it to civil action from governmental authorities. The more in formation you have gathered about the target company, the less likely it is that you will be persuaded to accept phony information. During the interview, let the official know that: 1) there is a real need to ascertain the size and scope of the hazardous waste problem to avoid over and under reacting; 2) there is a need to reduce public paranoia regarding hazardous waste disposal by forthrightly investigating and addressing the problems. This will help reduce public resistance to the sit ing of new disposal facilities; 3) you have information about the enterprise and you are aware that more can be researched; 4) enterprises that are viewed as un cooperative will be subject to greater scrutiny. The enclosed questionnaire focuses on toxic wastes which are regarded as among the most dangerous in terms of human toxicity. Included are chemical categories that appear on numerous governmental "most dangerous" lists. You may wish to broaden the list to include substances of particular con cern to you or your community. If you wish to add to the questionnaire, please do so in section 10. (Please do not reorder the substances currently on the list, or we will have difficulty merging the information on your questionnaire with others.) The glossary of terms in cluded here briefly describes many of the priority substances appearing on the questionnaire. *> s * step #3: evaluating a company's disposal site he Toxics Lexicon also briefly most important characteristics of any Tdescribes the type of disposal site are those which prevent water from facilities that are in the question penetrating the site, coming into contact naire. Obviously, you can not make an with hazardous waste, and then escap expert assessmentofthe adequacy ofan ing the site. The principles here should enterprises' disposal practices unless you have professionals advising you. be incorporated in any land disposal site. (We recommend a search for volunteer experts at local universities and among community organizations.) You should be able to raise some hard questions and prod governmental officials into ensur ing that adequate answers arc obtained. 1) The bottom of the site should be a minimum of five feet above the under ground water table. If the site is located in sandy type soils, it should be at least 10 feet above groundwater, especially if the groundwater is a source of drinking Hazardous waste generators can minimize the amount of waste water. Active sites over aquifers that provide the sole source of public drink created initially through ing water should be eliminated. changes in production processes and 2) No site should be in contact with waste recycling. The amount of waste any surface waters, including seasonal destined for land disposal can be further streams and springs. Sites located on a minimized by offering wastes for re flood plain represent an obvious hazard. 3) No site should fail to have an im cycling by other enterprises and by in cineration. Where feasible, hazardous permeable "cover" made of eighteen wastes should be neutralized. The ir- inches of clay soil or some plastic or reducable amounts of hazardous waste other man-made material. In addition, remaining must be encapsulated so it the surface of the site should be graded to drain rain water away from the site. will not threaten human health or the environment The following describes the safety needs for those types of land Ponding on the surface of the site is a sure sign of trouble. 4) Sites without a cover or located in disposal. sandy soil should have a leachate col LamUitl-- Water is the biggest enemy lection and treatment system. Such a in ensuring that land emplacement of system catches contaminated water, or hazardous waste will remain safe The "leachate," as it penetrates the bottom AP00025129 STOPPING FUTURE HAZARDS The "technical" response needed to safeguard an actual or potentially threateninghazardous waste'sitc is highly dependent upon the individual circumstances. Most remedies are not remedies at all, but minimize damage. The ultimate solution to a problem site is the removal of the waste for neutralization, destruction or encapsulation in a safer site. However, often this option will be too costly. The alternative is a combination of actions to contain further waste escapes and monitorfor leaking wastes to warn those who may come into contact with them. Containment usually involves digging around and under the site and emplacing leachate collection and pumping devices. All too often, containment involves little more than placing an impermeable "cap" on the site to prevent further infiltration ofsurface water. The latter effort in most cases is unacceptable because usually large volumes ofliquids are already within the site and will escape. The major strategy should be to press for the most effective containment and monitoringsystem feasible. The monitoring system is key because it can warn of escapes that have already occurred as well as future escapes which indicate a failure ofthe containment structure. Once ground water has been contaminated, remedies are limited. Under some conditions, it is possible to "counter pump" the contami nated water from the aquifer, assuming the underlying structure has not allowed widespread contamination of the "plume." Pumping out the water may be used to either slow the movement of the contaminated plume toward down-gradient drinking water wells, or to remove the major part of the contaminants. This option is most viable in circum stances where alternatives to the threatened wells are difficult and costly to acquire. In all cases, the "writing-off" ofan aquifer should be resisted Every effort should be made to maintain the highest quality feasible of underground supplies, for they remain our only hedge against future shortages. of the site and pumps it to the surface for neutralization before it is discharged 5) Sites located in sturdy soil without a leachate collection system should have a groundwater monitoring system. Such a system consists of wells sur rounding the site from which ground water samples are periodically taken and tested for organic and inorganic chemical contamination. Other signs of more gross contami nation can be foundin the form ofoily or discolored surface waters, withered vegetation, and yellow streaks in foliage (a sign of cadmium and zinc toxicity) nearby the site. Other factors which should cause concern are: 1) The proximity of a disposal site to residential areas where lateral move ment of escaping waters either above or below ground result in direct human contact. 2) The absence of any financially viable owner of a site who can he pressed to prevent or abate hazardous waste releases. .t) If the disposal site accepted a \ ariety of wastes without testing then, lor reactivity and segregating incompatible wastes, concern should be raised con cerning possible adverse chemical re actions if wastes escape and mix. Pits. Ponds, and Lagoons-- Because of the high water content ofthese wastes at their inception, pits, ponds, and la goons pose an inherently greater threat ofescape. Many ofthese sites have been created to comply with water pollution control requirements. The ponds allow some `pollutants to settle out and others to oxidize during long-term exposure to the air. Fewofthese sites were built with impermeable bottoms or sides because the underlying soil acts as a sponge, absorbingpollutants as the waste passes through. Unfortunately, just as a sponge stops absorbing when it is full of water, the soil stops absorbing pollutants. Groundwater monitoring around these facilities should be established to measure the movement ofpollutants out of the ponds. A special case is that of carcinogens, which are a threat to humans even when diluted, pit and pond owners should be encouraged to empty those sites con taining carcinogens. LandFarming -- The principle in land fanning is similar to pits, ponds, and lagoons in that the wastes mix with soil and degrade naturally. In land farming the microbial action in the soil enhances the degradation process. Again,' how ever, the disposal technique is used with highly liquid wastes which can run offor percolate to underlying groundwater. In either case barriers are desirable. Where barriers do not exist, groundwater monitoring is advisable. Storage -- Land emplacement is over whelmingly the most common type of disposal used. Hazardous waste storage must meet ftmdamentally the same re quirements. Surface run-off tends to be the great est problem of concern. Waste is not in place long enough to penetrate groundwaters; however, continuous, changeover may mean there is equal danger. Storage of quantities ofwaste greater than the treatment or disposal capacity of a facility is a sure alarm signal. It may indicate that the site owner is inten tionally, or because ofinsolvency, aban doning responsibility for the site soon. AP00025130 step #4: raising public awareness I* 1 nce "problem" hazardous Owaste sites are identified, citizens' options vary greatly. In the ideal situation the site owner will cooperate in investigating the po tential threats. While the potential lor liability for a toxic waste release does exist, unfortunately it is not great. Even assuming the site owner is held strictly liable, or liable regardless olTault. plain tiffs have difficulty proving that the re lease was the cause of their injury. The most effective tools to encourage coop eration from the site owner are adverse publicity, public pressure, and rigorous state or local enforcement of pollution control laws. If you have questions about the safety of a site, you must raise them with other citizens, local officials and local media. Start with citizens' groups. Where a nucleus of groups assisted in the initial survey, work with them to expand your network. Familiarizing the media with potential problems before a network of community groups has been established can help in the creation of the net work. Sometimes, however, it is not until community interest has been dem onstrated that media interest can be raised. The rest of the process is simply de pendent upon the persistence and in genuity of the individuals and organiza tions involved. You can make a difference on the safeguarding of haz ardous waste disposal sites in your community and nation-wide. Please don't forget to send copies of responses to the questionnaire to either A. Blakeman Early Sierra Club 330 Pennsylvania Ave., S.E. Washington, D.C. 20003 (202)547-1141 or Marchant Wentworth Environmental Action 1346 Connecdcut Ave., N.W. Washington, D.C. 20036 (202) 833-1845 Finally, be sure and involve Congress men and Senators from your state. They can assist in obtaining action at all levels of government, but acquainting them with problems of hazardous waste in their own communities will improve the chances of obtaining their support for comprehensive national legislation. FOR MORE INFORMATION U.S. Environmental Protection Agency 401 M St., S.W. Washington, D.C. 20460 rnurvnmertal regulations development andenforcement -- most regklaton efforts ere directed by Regional Administrators in the tenfederal regions headquartered in Bone*. New Yori City. Philadelphia, Atlanta. Kansas Cits. Dellas, Chicago. Denver. San Franetsee and Seattle National Cancer Institute 9000 Rockville Pike Bethesda. MD 20014 (301) 496-5615 conducts cancer research Occupational Safety and Health Administration 3rd St. and Constitution Ave.. N.W. Washington. D.C. 20210 (202) 523-9362 dealt with miri fUivV Man,lards in cmttrnl lMi\ National Solid Waste Management Association 1120 Connecticut Ave., N.W. Washington, D.C. 20036 (202) 659-4613 represents the majorcommercial hazardous icaste ditposalflrms -- good source on disposal technology National Institute of Environmental Health Sciences P.O. Box 12233 Research Triangle Park. NC 27709 (919) 541-3345 rortrfiKVt research on cm tronmental hazards National Institute for Occupational Safety and Health Park!awn Bldg. 5600 Fishers Lane Rockville. MD 20857 (301) 443-2140 U.S. Geological Survey Water Resources Division National Water Data Exchange Rcston. VA 22092 X6l> 7444 or 860-6031 t.nt'uh'diis'siNc "it tm/trifi and i;n"i>id < nali-ai ide AP00025I31 AP00025132