U. S. House of Representatives Committee on Science and Technology Subcommittee on Natural Resources,
Agriculture Research and Environment
Statement of Dr. Robert A Michaels Senior Project Scientist Toxic Substances Project Natural Resources Defense Council
26 June 1985
https://bulk.resource.org/courts.gov/juris/j3464 03.sgml
U. S. House of Representatives Committee on Science and Technology
Subcommittee on Natural Resources, Agriculture Research and Environment
Statement of Dr. Robert A Michaels Senior Project Scientist
Toxic Substances Project Natural Resources Defense Council
(Pages 97 To 111)
Mr. TORRICELLI. Thank you for your presence today. Our next witnesses are Dr. Henry Cole, science director, National Campaign Against Toxic Hazards, and Dr. Robert Michaels, senior project scientists, Toxic Substances Project of the Natural Resources Defense Council.
Welcome, Dr. Cole, Dr. Michaels. If you could provide us with either a copy of your testimony or a summary at this point for the record we would appreciate it.
Dr. MICHAELS. OK. I have given 16 copies to the staff. Dr. COLE. I have done likewise. Mr. TORRICELLI. It's not nearly enough. (Laughter.)
Would you like to proceed? Given how late it's become and how long we have held you, if you could be brief in your testimony we could perhaps then save some
time for questions.
Statement of Dr. Robert A. Michaels Senior Project Scientist Toxic Substances Project Natural Resources Defense Council
Dr. MICHAELS. I am Bob Michaels, and I represent the Natural Resources Defense Council, which is an organization of public interest, a nonprofit organization of some 50,000 members also supported by a somewhat smaller population of philanthropists, and dedicated to the protection of environmental and public health. As such, we are concerned about developing permanent solutions to hazardous waste problems, and, just going through this as quickly as possible, we have addressed basically three issues, of which some of the previous witnesses have also
addressed the same issues.
One, whether available hazardous waste management technologies are adequate; second, whether the proposed act constitutes an effective means of increasing their adequacy and availability; and third, whether the Superfund law is an appropriate vehicle for addressing the issues of research and demonstration of waste management technologies.
So with regard to the first issue of adequacy of available hazardous waste management technologies, my detailed statement is a little longer than what I have to say, principally that we are in favor of waste control technologies. These are direct applications on the wastes themselves as opposed to environment control technologies. What is conspicuously missing in those environment control technologies is the removal and treatment of those wastes, and therefore they are allowed to decay naturally and pose risks for very long periods of time, hundreds to thousands of years in the case of some wastes, whereas the _ institutional mechanisms for dealing with those appear to extend up to, perhaps, 30 years of post-closure care.
Fundamentally inadequate -- EPA's Handbook for Remedial Action at Waste Disposal Sites says, of waste control technologies... Many of these direct treatment methods are not fully developed and the application and process reliability are not well demonstrated. Use of these techniques for waste treatment will require considerable pilot plant work.
Waste control consists of several alternatives; one, according to EPA, is placing the wastes in a better engineered or environmentally less sensitive location. Another is stabilization by solidification or encapsulation; third, destruction by, usually, incineration means; and lastly, chemical waste treatment within the site, as by neutralization and solution mining.
Essentially, the first two strategies -- the better engineered environments -- is just putting the wastes in another place. It's not really a permanent solution. Stabilization changes the time scale of waste migration but does not fundamentally change the fact that a permanent solution has not been obtained, except in some cases where you may be dealing with glassification or some very long-term stabilization processes.
Even incineration, although it is permanent, is ineffective for some substances such as fairly noncombustible liquids, and also it's not that effective for metals, which will not degrade. And there are improvements needed in incineration technologies, and I think that the proposed act would be very helpful in addressing those.
Another very important issue is the issue of biological processes to decay hazardous wastes, and I think that we should characterize those as being numerous
technologies. Biological processes are very diverse and are an especially important area of concern which would be promoted by the proposed amendment.
Now, as an illustration for the need for research and demonstration of waste management technologies, I want to present an experience I had last week at Wood's Hole, attending a conference on waste reduction sponsored, in part, by EPA and principally by the League of Women Voters of Massachusetts in which 21 major corporations listed in my statement here presented their formal waste reduction programs. Among them, not a single one addressed the issue of toxicity reduction. They all addressed the issue of volume reduction, volume reduction principally obtained by no longer combining waste streams -- essentially, diluting hazardous wastes -- but now segregating waste streams, essentially creating more concentrated hazardous waste streams but of lower volume but of higher toxicity. And there is an especially great need -- again, which I think the proposed act would address -- for developing methods of not only waste volume reduction, but toxicity reduction.
With regard to the issue of effectiveness of the proposed act at increasing adequacy and availability of waste management technologies, I -- clearly, the act does contain provisions for doing that. I'm not wedded to the specific procedures that you have in this act. I am sure there are other alternative methods that could be envisioned to do the same thing. But this is not an issue that I've examined.
What I have looked at is some of the constraints on the idea of having 10 sites. We don't need sites that do things redundantly, necessarily. What we need are sites that address the needs of people, especially those in academia, scientists and engineers, who would be limited by the need to arrange for demonstration of their technologies at great distance from their home bases. There do need to be enough sites so that these people can demonstrate at sites close to home. I think that's less applicable to the more expensive technologies where transportation costs would constitute a much smaller percent of the total demonstration project.
Another consideration that mandates that you have several sites -- and I don't know if 10 is the number -- is the need for climatological diversity, particularly for processes that depend upon climate for their effectiveness. And here I mean, principally, the bio-degradation. You would not want to demonstrate that in Alaska in the winter.
Some 60 percent of all hazardous wastes are liquids that are disposed to deep wells underground, and we at NRDC regard this as a major technology need that also would be addressed by the proposed act through motivating people to develop liquid waste detoxification technologies. Superfund generates groundwater contamination, the solution to which is frequently pumping of groundwater, and that generate a lot of liquid wastes. And we recognize a cross-fertilization of the technologies that might be promoted by this act, which would also be applicable to underground injection situations.
And if I could have your permission, I would like to enter into the record an exhibit that would go along with my testimony. It's called -- it's a book that was done by two members of NRDC, Wendy Gordon and Jane Bloom, called "Deeper Problems: Limits to Underground Injection as a Hazardous Waste Disposal Method"
Mr. TORRICELLI. I am told, Dr. Michaels, that that appeared in the record of our committee at our last hearing. We have it.
Dr. MICHAELS. OK. In that case
Mr. TORRICELLI. Thank you for bringing it.
Dr. COLE. You can give it to me.
Mr. TORRICELLI. Let the record show that it was given to Dr. Cole. Dr. MICHAELS. And that he did not pay for it.
Mr. TORRICELLI. And he did not pay for it. (Laughter.)
Dr. MICHAELS. That is correct. Consistent with the philosophy of NRDC, a non-profit organization.
The third issue is appropriateness of the Superfund law as a vehicle for addressing the issues of research and demonstration of waste management technologies.
I have a question -- NRDC has a question -- of whether the proposed Act goes far enough by being placed in the Superfund Program and focusing on the issue of cleanup. Hazardous wastes need to be managed when they are generated, and frequently at the stage of manufacturing processes, before they are ever disseminated into an environment that needs to be cleaned up. We feel, however, that the Superfund Act is still a good place to put this particular proposal because, again, of the cross-fertilization where technologies such as the one I proposed would be addressed for underground injection for treatment of liquid wastes -- would also be utilizable on waste streams coming out of factories. However, just as a general conclusion of NRDC, the needs, for hazardous waste management are very diffuse, whereas the proposal is a little more focused.
So in summary, we support the Superfund Clean-up Technology Research and Demonstration Act of 1985. We base our support on our belief that currently available technologies are inadequate to permanently manage hazardous wastes. Further, we believe the proposed act will promote the adequacy and availability of much-needed waste control technologies such as technologies to reduce and/or detoxify hazardous liquid wastes, now constituting the bulk of all hazardous wastes.
Last, we regard the Superfund law as an appropriate vehicle, though not the only potential vehicle, for promoting alternative hazardous waste management technologies, and we encourage the broadest interpretation of the proposed act to encompass not only cleanup of hazardous wastes in contaminated environments but also treatment of hazardous wastes which are manufacturing process outputs.
(The prepared statement of Dr. Michaels follows: )
Assessment of the "Superfund Clean-Up Technologies Research and Demonstration Act of 1985"
Testimony of the Natural Resources Defense Council
Before the Subcommittee on Natural Resources, Agriculture Research and Environment
Committee on Science and Technology U.S. House of Representatives
Presented by Robert A. Michaels, Ph.D. Senior Project Scientist Toxic Substances Project
26 June 1985
James H. Scheuer, Chmn. Subcommittee on Natural Resources, Agriculture Research and Environment Committee on Science and Technology
U.S. House of Representatives Rayburn House Office Building, Suite 2321 Washington, D.C. 20515
Dear Mr. Scheuer,
Thank you for inviting me to testify on behalf of the Natural Resources Defense Council (NRDC) regarding the "Superfund Clean-up Technologies Research
and Demonstration Act of 1985." NRDC is a non-profit, public interest organization
supported by 50,000 members and philanthropists dedicated to protecting public and environmental health. As such, NRDC is interested in promoting sound hazardous waste management practices, particularly those which permanently manage rather than simply defer the need to manage wastes, and by deferment often transfer the burden of management to segments of society not responsible for initially generating the wastes.
With the above interests in mind, I examined the provisions of the proposed Act with regard to the following issues:
--whether available hazardous waste management technologies are adequate,
--whether the proposed Act constitutes an effective means of increasing their adequacy and availability; and
--whether the Superfund law is an appropriate vehicle for addressing the issues of research and demonstration of waste management technologies.
My testimony on behalf of NRDC focuses upon these three issues in turn.
Adequacy of Available Hazardous Waste Management Technologies
The objectives of hazardous waste management technologies are either to manage contaminated environments or to directly manage the wastes. Environment management consists of containing the wastes to preclude migration and human contact, for example by constructing an underground barrier, capping the surface with membrane or clay liners, and pumping groundwater to reverse outward flows from the source of contamination.
What is conspicuously missing is waste removal and treatment. As a result wastes, many of which exhibit half-lives of hundreds to thousands of years, are allowed to decay naturally. Inasmuch as our institutional mechanisms survive fractions of a decade, as in the case of elected governments, to several decades, as in the case of the 30-year post-closure responsibility for hazardous waste landfills, environment control technologies are inadequate to permanently address the hazardous waste management issue and, though relatively inexpensive initially, they are more expensive in the long term.
Based upon the fundamental shortcomings of hazardous waste management technologies focusing upon the environment control objective as described above, the principal objective NRDC advocates is direct treatment ("waste control"). EPA's
Handbook for Remedial Action at Waste Disposal Sites* says of waste control:
"Many of these direct treatment methods are not fully developed and the application and process reliability are not well demonstrated. Use of these techniques for waste treatment will require considerable pilot plant work" (p.283).
Waste control consists not only of containment to preclude migration, as in the case of environment control, but physical removal. Upon removal, EPA lists the following available waste control technology options, placing the wastes in a "better engineered or environmentally less sensitive" location, stabilization, as by solidification and encapsulation, destruction by various means; and chemical waste treatment within the site, as by neutralization and solution mining.
The first two strategies -- relocation and stabilization -- are not permanent solutions, although some methods of stabilization, such as glassification, may approach this goal. Destruction usually means incineration which, though permanent, is expensive for many wastes, such as liquids, and ineffective for others, such as metals. Incineration technologies are also in need of improvement. Destruction can also include microbial degradation, but this strategy is in its infancy, and is in special need of research and demonstration opportunities.
As an illustration of the need for research and demonstration of waste management technologies, consider the presentations of 21 major corporations that have formal waste reduction programs.* These were discussed at a conference on Waste Reduction sponsored by the League of Women Voters of Massachusetts and the EPA (19-21 June). In every case, corporate presentations emphasized the reduction of landfilling and volume of hazardous wastes generated. Principally these accomplishments were achieved by finding uses for the wastes, or by segregating waste streams that were once combined, effectively diluting a hazardous waste stream, while increasing its volume. The result of waste stream segregation is to reduce the volume of the hazardous waste, but increase its concentration and toxicity. This result illustrates the need to develop ways of reducing not only the volume, but the toxicity of hazardous wastes -- an area universally omitted from the waste reduction programs described by the 21 corporations at the conference.
*Allied Corporation, American Cyanamid, Amoco Chemicals, AT&T Technologies, Chevron Chemical Company, Chrysler Corporation, Dow Chemicals, Eastman Chemical Division/ Eastman Kodak, E.I. Du Pont de Nemours & Co., Exxon Chemical Americas, Hewlett Packard, IBM, ICI America, Inc., 3 M, Monsanto Company, Occidental Chemical Corporation, Olin Corporation, Rohm & Hass, Shell Oil Company, Union Carbide Corporation, Velsicol Chemical Corporation
*EPA-625/6-82-006, June 1982
Effectiveness of Proposed Act at Increasing Adequacy and Availability of Waste Management Technologies
The proposed Act clearly contains provisions for promoting required research and opportunities for demonstration of alternative technologies for use by EPA, its contractors, and others in the waste management field. I have no comments regarding the issue of whether there may by other ways of accomplishing the same goal, presumably there are. For example, it is possible that the establishment of ten regions for essentially the same function is unnecessary for demonstration of expensive technologies, which could be sited anywhere on a pilot basis. However, lower-budget technologies, such as those that might be developed by academic scientists or engineers, might suffer from the need to arrange demonstration further away from their home bases. Moreover, there is an obvious need for climatological diversity for demonstrating technologies whose performance might depend upon climate -- such as microbial degradation technologies. This constraint clearly justifies establishing several, if not ten, such locations.
Because some 60 percent (some 10 billion gallons) of all hazardous waste disposed consists of liquids that are injected to deep wells, NRDC assigns high priority to liquid hazardous waste reduction and detoxification.
Because Superfund clean-up characteristically involves groundwater contamination and groundwater pumping, the proposed Act is likely to be particularly effective at increasing the adequacy and availability of technologies to reduce and/or detoxify such wastes. A more complete description of the particular technology needs for addressing the underground injection issue can be obtained from the exhibit accompanying this testimony -- "Deeper Problems: Limits to Underground Injection As A Hazardous Waste Disposal Method" (1985) by Wendy Gordon and Jane Bloom, both of NRDC.
Appropriateness of Superfund Law As Vehicle for Addressing Issues of Research and Demonstration of Waste Management Technologies
The proposed Act emphasizes clean-up at Superfund sites as the major technology objective to be promoted. There is a question, however, of whether the proposed Act goes far enough to promote hazardous waste management technologies applicable to wastes which have not yet been disseminated to the environment, and which do not, therefore, have to be "cleaned up." The need to develop and demonstrate technologies for waste detoxification, cited earlier in this testimony, applies equally to contaminated environments and manufacturing process outputs which are hazardous wastes.
In general, NRDC finds that the needs for research and demonstration of hazardous waste management technology are diffuse. Relative to these needs, the proposed Act is somewhat more focused on clean-up in particular. Nevertheless, NRDC believes that Superfund is a good place for the proposed Act, despite its narrow focus on clean-up. Principally, this finding arises from the close resemblance of waste management needs under, say, RCRA, Superfund, and TSCA, giving rise to the likelihood that technologies demonstrated as adequate for Superfund use would also be recognized for other waste management uses. This point was illustrated earlier by the example of reducing and/or detoxifying liquid wastes instead of or prior to underground injection into deep wells.
In summary, NRDC supports the "Superfund Clean-up Technologies Research and Demonstration Act of 1985.” We base our support upon our belief that currently available technologies are inadequate to permanently manage hazardous wastes. Further, we believe the proposed Act will promote the adequacy and availability of much needed waste control technologies, such as technologies to reduce and/or detoxify hazardous liquid wastes now constituting the bulk of all hazardous wastes.
Lastly, we regard the Superfund law as an appropriate vehicle -- though not the only potential vehicle -- for promoting alternative hazardous waste management technologies. We encourage the broadest interpretation of the proposed Act to encompass not only clean-up of hazardous wastes in contaminated environments but also treatment of hazardous wastes which are manufacturing process outputs.
Respectfully submitted,
Robert A. Michaels, Ph.D. Senior Project Scientist Toxic Substances Project
Mr. TORRICELLI. Thank you, Dr. Michaels.
Publication citation
Michaels, RA. Testimony supporting the proposed Superfund Clean-Up Technologies Research and Demonstration Act of 1985 (H.R. 2802, 99th) before the U. S. House of Representatives, Committee on Science and Technology, Subcommittee on Natural Resources, Agriculture Research and Environment. Dr. Robert A Michaels, Senior Project Scientist, Toxic Substances Project, Natural Resources Defense Council (New York City), doi: 10.13140/RG.2.2.26025.19047, U. S. House of Representatives, 10 pages, 26 June 1985b;