Section Eleven
WASTEWASTER MINIMIZATION AND REUSE
32    THE DEVELOPMENT OF TREATMENT
ALTERNATIVES THROUGH AN UNDERSTANDING OF
WASTE CHEMISTRY
Thomas F. Stanczyk, Senior Vice President
Recra Environmental, Inc.
Amherst, New York 14150
INTRODUCTION
The 1984 amendments to the Resource Conservation and Recovery Act (RCRA) prohibit the land
disposal of regulated hazardous wastes over a scheduled period through 1990 unless the EPA determines that a waste can be made safe for disposal through a technological treatment process. Under the
law, final treatment standards were established for solvent and dioxin-containing wastes, and by July
1987, performance standards must be established for specific liquid forms of waste containing acids,
cyanides and volatile halogenated organics. EPA plans to complete reviews of at least two-thirds of all
waste groups (40CFR Sec. 268.10) subject to the new disposal rules by June, 1989.
In retrospect of the proposed as well as existing land disposal bans, EPA has based treatment
performance standards on available technologies that demonstrate substantial reduction of toxicity or
mobility of listed and characteristic waste types prior to land disposal. Treatment requirements will be
set at levels designed to assure that land disposal of treated wastes poses no significant risks to human
health or the environment.
Federal and state landfill bans are resulting in stringent landfill waste acceptance criteria and design
performance standards. In addition to the requirements for sophisticated design safeguards, emphasis
has been placed on waste acceptance criteria, which encompass, among numerous chemical control
protocol, waste restrictions based on chemical content, solubility, volatility, flammability, toxicity
and compatibility. In response to EPA's land disposal prohibitions, certain waste types are governed
by treatment performance standards verified by the Toxic Characteristic Leaching Procedure
(TCLP). Unlike EP Toxicity, TCLP differs in analytical procedure on the basis of variances in
extraction protocol and the addition of 38 organic compounds to the original EP parameters. Treatment standards for listed waste categories will likely be expressed as waste concentrations (40CFR
268.43) rather than as "specific technologies" (40CFR 268.42). In most cases, industry will find that
the chemical content, as well as properties of a waste, will need to be well understood to ensure
acceptance and optimum treatment performance.
With the realization of stringent landfill acceptance criteria, rising disposal costs, on-going regulatory enforcement and awareness of environmental liabilities, industries are reassessing existing waste
management policies and procedures in an effort to reduce and/or minimize waste generation and,
where feasible, become self-reliant in treatment. Waste minimization, as defined within the context of
this discussion, must deal not just with the reduction of waste volume but also the reduction and
potential elimination of waste mobility and hazard potential. In this regard, industry's approach to
waste treatment must reflect an overall change in philosophy that concentrates on the understanding
of waste chemistry and its application to engineering principles dictating the feasibility of chemical
substitution, reclamation/reuse and source segregation and treatment effective in by-product detoxification and immobilization. The changes in philosophy and approach are resulting in innovative
treatment alternatives applicable to source control rather than the conventional "state-of-the-art"
approaches that are designed primarily for "end-of-the-pipe" pollution control. In many cases, the
alternatives are practical and cost effective; however, poor performance can be recognized if the
properties of individual constituents are not well understood.
In retrospect, industry may find that there is an immediate and/or short-term need to reassess
treatment requirements and alternatives in order to either eliminate waste or meet new performance
standards and landfill acceptance criteria. Oily residues, solvent-laden still bottoms, brine sludges.