NOVEMBER 30, 1982

    Mr. Chairman and Members of the Subcommittee, I am William Sanjour, Chief of the Hazardous Waste Implementation Branch of the Environmental Protection Agency (EPA). I am testifying today at the request of the Subcommittee on my own views of EPA's regulations of hazardous waste land disposal facilities of July 26, 1982(1).
    I have been with EPA for ten years, and before that I had been a management consultant and had spent several years working on environmental problems. I have a master's degree in physics and have completed advanced studies in operations research. Prior to joining EPA, I spent twelve years doing operations research in the Navy and in private industry with particular emphasis dn the analysis of technological systems.
    In 1974, I joined the newly formed Hazardous Waste Division as Chief of the Assessment and Technology Branch. My duties were to supervise the branch in the conduct of studies to assess the breadth and depth of the hazardous waste problem in the U.S. and to evaluate the technology for handling it. This work culminated in October 1976 with the passage of the Resource Conservation and Recovery Act (RCRA). The approach taken in this Act to regulate hazardous waste was basically that approach developed by EPA's Hazardous Waste Management Division as an outgrowth of these studies. The heart of this Act was the mandate for EPA to write standards for the management of hazardous waste so as to "protect human health and the environment".
    For the first two years after the passage of RCRA, I was in charge of writing the standards for the treatment, storage and disposal of hazardous waste. I have previously testified in the Senate(2)  of how those regulations were sabotaged by the Administration, how I refused to collaborate with this sabotage and how I was subsequently transferred.
    As a result, in addition to my official duties, I have on my own time become a technical advisor to the Citizens Clearinghouse on Hazardous Waste. This organization, founded by Lois Gibbs of Love Canal fame, helps citizens organize to protect themselves against hazardous waste facilities. I have spoken with and advised groups of citizens around the country who are faced with the prospect of hazardous waste dumps in their communities. In doing this I have gained insight into how government and industry actually function in the real world which bears little resemblance to the view from EPA Headquarters.
    One of the major problems with hazardous waste is the way it is disposed. Over 90% is dumped either in surface lagoons or buried in what are euphemistically called "landfills". Unlike garbage and human wastes, most of these wastes do not degrade and much of it remains poisonous forever. When hazardous waste is disposed of in or on the ground, it can be carried by rainwater through and over the ground and off the property of the disposer and may eventually end up in or on someone else's property and in public water supplies.
    Therefore, because of the widespread use of dumping, one of the first studies I had done was to determine the degree to which this was actually happening in existing industrial disposal sites. The resultant study(3) showed that most, if not all, the existing industrial waste "landfills" and lagoons in America were leaking their contents, frequently toxic, into the environment. David Miller, the principal investigator on this study, is scheduled to be on this panel and can speak to this study in greater detail. The conclusion we drew was that most existing land disposal sites would eventually turn out to be imminent hazards to public health (which later turned out to be the case) and that unless something was done to modify the practice of hazardous waste dumping, this problem would get worse.
    It was at first hoped that "landfilling" could be made more reliable by use of "attenuation", that is the natural tendency for some soils to adsorb some chemicals, but research soon demonstrated that this was a transient and unpredictable phenomenon(4). The next great hope was liners and then leachate collection systems.
    At first confidence in clay liners was so high that a member of my staff was sent in 1977 to testify in behalf of Earthline Corporation when the citizens of Wilsonville, Illinois tried to close down their "secure" clay lined hazardous waste "landfill". Later research at Wilsonville and elsewhere showed that the citizens were right and that we experts were wrong again and that the imperviousness that clay liners showed in the laboratory could not be duplicated in the field(5)(6)(7)(8). In particular, when Love Canal burst onto the national scene, a little reported fact was that the clay lined canal far exceeded our thinking at the time at EPA as to what was required to line a hazardous waste "landfill".
    Plastic liners also were unpredictable and what little field data existed did not prove otherwise(9). Professor Kirk Brown who has been EPA's principal investigator in this area is also scheduled to be on this panel and can give you far more details on the ability of liners to assure protection of public health from dumps.
    New schemes for pumping out liquids from "landfills" called "leachate collection" were also proposed. Again what little field data exists(10) shows this to be still another gimmick which doesn't work.
    Two studies in particular, are very important to this issue and to these hearings because they report on field investigations of some of the few hazardous waste "landfills" built within the last few years with much of the high technology gimmickry on which EPA has based its hopes. In a sense these two studies are a continuation of the field study referenced earlier3 by David Miller as they represent the attempted answer to the widespread failures found in that earlier study. Because of their importance I have attached copies of these papers to my testimony. The first of these studies, by Peter Skinner(10), reports on several "secure landfills" in New York State which take in huge quantities of industrial toxic wastes from all over the country. The second study is by Peter Montague9 deals with four even newer "high technology landfills" in New Jersey. Some specific findings of these studies of particular interest are:

  • The New York study shows that the leachate collection systems at the "landfills" are not working thus creating an underground dam where the pressure of poisoned liquids is building up.

  • One of these "landfills" is one of the largest recipients of hazardous waste from the clean up of other hazardous waste sites around the country under "Superfund".

  • In New Jersey both clay and plastic liners were penetrated by the wastes in a matter of months.

  • The State of New Jersey was unable to require the "landfills" to comply with the performance they had promised.
  • In testimony before the Assembly of California(11) Peter Skinner summarized the consequences of these studies of "secure landfills":
    . . . . these quasi-engineered pits are no more than in situ repository experiments, backed up by neither defensible scientific proof of adequate on site performance nor component by component laboratory testing. Turning over our toxic waste to "secure" landfills operators, therefore, is little wiser than sending it to halls of the medieval alchemist. It is clear to me that the costs of repairing the inevitable cap failures and mitigating the probable migration plumes for each landfill will be million dollar propositions. Since these difficulties will occur years or perhaps decades after closure, the likelihood is low that the facility developer or even adequate funds in trust for the job will be available. Like Love Canal today, taxpayers will be forced to shoulder the burdens industry should have prepared for long before.
        Thus, by end of the seventies it was obvious to everyone who had been involved with technical issues of land disposal that no one knew how to build a "landfill" that worked. In a rare moment of candor EPA published an excellent summary of the problem in the FEDERAL REGISTER on February 5, 1981(12). I have attached this discussion at the end and I would like to quote one paragraph here.
    There is a good theoretical and empirical evidence that the hazardous constituents which are placed in land disposal facilities very likely will migrate from the facility into the broader environment. This may occur several years, even many decades after placement of the waste in the facility, but data and scientific prediction indicate that, in most cases, even with the application of best available land disposal technology, it will occur eventually. (emphasis mine)
        The "landfill" owners and operators confirmed this conclusion by lobbying Congress intensively for years to get legislation which would absolve them of any liability for damages caused by their "landfills" five years after they close. (I think it is one of the blackest pages in the history of this body that such relief was granted(13) and as part of the "Superfund" law which was ostensibly written to aid victims of hazardous waste disposal.)
        Not only were government and industry aware of the fact that they didn't know how to make "landfills" work, but insurance companies as well. At the Congressional hearings for "Superfund" insurance companies testified that they would not provide long term insurance for "landfills", and the Department of the Treasury's fiscal service submitted comments concluding the premiums for liability insurance would be prohibitive and that individual insurance companies offering such coverage might go out of business(14).
        After the passage of "Superfund" it became clear that most of the cost was not going to clean up after "midnight dumpers" but rather that 80% of EPA's priority sites were legitimate legally operated "landfills"(15). Since these dumps do not differ in any way but age from 900 dumps currently permitted under Federal law, one could conclude that "Superfund" may be eventually called upon to clean up most of these at an estimated cost of $4 million apiece, not including liability costs.
        In the face of all this scientific and engineering and other data it was well within EPA's authority and mandate to "protect human health and environment" to simply ban the land disposal of all or most hazardous wastes. Yet they did not. They kept looking for ways to allow "landfilling" to continue. (I could devote several pages of testimony on this loophole making activity). This determination might make sense if there were no alternatives to land disposal, but this is not the case. As early as 1973, EPA had written in a report to Congress:(16)
    The technology for hazardous waste management generally is adequate. A wide array of treatment and disposal options is available for management of most hazardous wastes. The technology is in use today, but the use is not widespread because of economic barriers in the absence of legislation.

     . . . legislation which mandates adequate treatment and disposal of such wastes is absent or limited in scope. The consequence is that generators of hazardous wastes can use low-cost but environmentally unacceptable methods of handling these residues.

        Many studies since then by myself and others(17)(18)(19)(20)(21)(22)(23) have confirmed the availability of alternatives to the dumping of hazardous waste and since a spokesman for many of the firms which offer such alternatives is one of your scheduled speakers, I won't belabor the point except to quote from a recent study from the State of California(24).
    The costs of securing or cleaning up past disposal sites are rapidly approaching such a magnitude that government and industry together cannot afford them. Unless we permanently detoxify or encapsulate the most toxic and long-lived wastes, we are risking future cleanup costs that make land disposal a very bad bargain." And that technologies "are commercially avail able today, but have not been utilized in California due to the availability of inexpensively priced land disposal.
        In other words, not only are "landfills" dangerous and not only are there safer ways of handling hazardous waste than by "landfilling" and not only will "landfills" have to be eventually cleaned up at great public expense but the very existence of "landfills" prevents the better methods from being widely used. Why then does EPA continue to push these dumps?
        To answer that question I think we have to look at the reasons why we should have dumps rather than the reasons we should not have them. Dumping is popular because it is cheap. It is cheap because unlike the competing alternatives, the real cost of dumping is not borne by the producer of the waste or by the disposer but by the people whose health and property values are destroyed when the wastes migrate onto their property and by the taxpayers who pay to clean it up.
        There are now about 900 hazardous waste dumps in the United States permitted by Federal law. The list of companies which own them reads like the "Fortune five hundred". Companies like General Motors, Dupont, General Electric, United States Steel, Exxon, Martin Marietta, Eastman Kodak, Union Pacific etc., etc. However, the largest single owner and operator of hazardous waste dumps in America is the United States Government. The Defense Department alone owns about 30 hazardous waste dumps.
        Therefore, when a minor agency like EPA, run by third-string political appointees of an unsympathetic Administration is faced with a decision which on one hand is supported by logic and science and is beneficial to the health and financial well-being of the American public and which on the other hand is opposed by the wealthiest most powerful and most influential interests inside and outside the government--it will look for a third way. The July 26, 1982, land disposal regulations, which we are here to discuss today, is that third way, it will look to those in the career civil service who are willing to pervert their knowledge and experience to provide the third way.
        To start with, the preamble and background documents to the regulations admit that "landfills" don't work. To do otherwise would force the Agency to contradict its own research results. But there is not the forthright discussion of the issues as took place in the preamble to the February 5, 1981, proposed regulations12. For example:
    EPA's view of the function of a liner contrasts somewhat with that of some members of the public and the regulated community. Some have argued that liners are devices that provide a perpetual seal against any migration from a waste management unit. EPA has concluded that the more reasonable assumption, based on what is known about the pressures placed on liners over time, is that any liner will begin to leak eventually1.

    Therefore, EPA has concluded that its regulatory strategy should seek to provide long-term protection, but it should not profess to provide protection for infinity. EPA considered whether it should specify some fixed time period that would provide an outer bound on how long it can reasonably expect to assure ground water protection. At this time, EPA simply has not been able to develop an adequate rationale for such a time frame.1

    Essentially complete but temporal containment is practical using the synthetic liners developed over recent years. However, experience with synthetic liners in contact with chemicals is relatively recent. As a result, EPA has no experience base from which to predict the life of these materials. However, predictions based on chemistry, and limited recent real world experience are sufficient to convince the Agency that with proper selection for resistance to chemicals at the site and proper design and installation (tight seams and no tears), containment for at least 30 years or more is practical, utilizing a single synthetic liner (some believe that such liners will last in excess of 100 years)(25).
        By a very perverted logic, this grudging admission leads to a strange conclusion. Since they cannot rely on the technology of "landfilling" to protect human health and the environment, the regulations, therefore, will rely instead on measures to control the damage done by failure of the "landfill". The preamble considers the land disposal facility as being only "the first line of defense".
    The other element of the general strategy is a groundwater monitoring and response program that is designed to remove leachate from the ground water if it is detected. The monitoring and response program serves as backup to the liquids management strategy1.
        This is a very frightening concept. Regulations which instead of preventing disaster, knowingly allow it by promising to provide disaster relief. Can we expect EPA to carry this line of thinking into other areas by issuing gas masks as a means of regulating air pollution? Or by stockpiling canned fish and tetanus injections to regulate water pollution?
        But if the concept is bad, what is worse is that it is unworkable. For many different reasons, which I will go into, it is unreasonable to expect that these regulations can provide that second line of defense and therefore, there is no way that these regulations can protect human health and the environment as required by law. It is as if the Federal Aviation Administration were to issue an airworthiness certificate to an aircraft based not on the ability of the aircraft to stay up in the air but on the availability of crash control equipment and then welshing on the crash equipment.
        The reasons why this disaster relief approach cannot work are:

    1) Monitoring for groundwater pollution is unreliable.

    2) Cleaning up groundwater pollution is almost impossible.

    3) EPA does not have sufficient staff to implement such a scheme.

    4) There are no standards on how this groundwater protection plan is to be administered. It is left to the discretion of political appointees.

    I will elaborate on these points in the next few paragraphs.
        The first reason why this second line of defense cannot work is because it depends on groundwater monitoring to trigger the process. Groundwater monitoring is difficult and unreliable. Unlike surface water, pollution moves through groundwater in narrow stripes or plumes which are difficult to detect. There are numerous instances of polluted groundwater going undetected by groundwater monitoring systems. David Miller, who is an expert on this subject, can tell you much more about it. In addition, the groundwater monitoring system is run by the operator of the dump and depends on him to discover his pollution and to turn himself in. While no doubt there will be many honest operators, there is also no doubt there will be many dishonest ones. One need only review the record of criminal prosecutions in hazardous waste management in the last several years.
        I have spent many years studying damages done by hazardous waste. The most common way of detecting groundwater pollution plumes is in the drinking water taps of nearby houses. The most common monitoring device is people. The typical pattern(26)(27)(28) is that citizens' complaints about their drinking water are met with a bureaucratic run-around from the health authorities for years and only by organizing and by making a thorough nuisance of themselves can they get the authorities to act. And often the action consists of shutting down the wells and charging the citizens to connect up to water pipes.
        This brings us to the second issue which is the cleaning up of polluted groundwater. I'm sure David Miller's testimony will go into this in great detail so I will just quote the conclusion of EPA's own scientists in reporting on a survey of the past history of hazardous waste remedial action activities(29).

    The survey and case histories indicated that remedial measures were usually confined to containment and/or removal of the hazardous wastes with a primary goal being to prevent further contamination of the environment rather than complete cleanup. Complete environmental cleanup of groundwater or surface water can require sophisticated technologies, large sums of money, and/or long periods of time. Therefore, a responsible party with sufficient funds and expertise must be located to effect complete cleanup. In most cases, sufficient funds have not been available for effective remedial action. The EPA is available to provide only limited remedial funding under Section 311 of the Clean Water Act. Further, State and local governments cannot typically provide sufficient money for total cleanup since any one site may require millions of dollars to correct its problems.

    Based on the case studies and survey, the present state-of-the-practice for remedial actions does not look favorable when considering that the applied remedial actions was ineffective 46 percent of the time and only a portion of all uncontrolled sites have received some form of remedial action. In addition, remedial action applied at a site experiencing problems was totally effective only 16 percent of the time.

        Real world experience has shown that when government officials allow a "landfill" to be built and then filled with thousands of tons of waste and then find it is polluting the groundwater, it is too late to force the "landfill" owner to do any meaningful clean up. If it is a commercial facility the operator will argue that if the government requires him to do a thorough clean up he will have to go bankrupt and the government will be stuck with the remedial costs since the regulations do not require financial assurance for such costs. If it is a manufacturing facility they will say that they will have to close down the plant and put hundreds of people out of work.
        In either case, enforcement officials lose all of their clout when they allow matters to get so bad that they are only left with draconian solutions. In practice they end up doing things to get themselves off the hook like raising the drinking water standards to the level of the pollution; or suddenly finding out that they cannot determine the unique source of pollution; or they will reach a compromise solution for some lesser form of remedial action, which historically has meant that the dumps continue to operate and continue to pollute; or they use the good old stand-bys that they need more studies or more money or more people or more time etc., etc.
        The third issue is that these regulations are not really standards but bureaucratic procedures which will require a large bureaucracy to implement. In the regulations governing the lining of the "landfill" for example: they do not specify a design standard which would say something like a "clay liner must be at least two feet thick and have a permeability of not more than 10-7 centimeters per second" but rather that EPA in evaluating the permit application will make a determination of whether sufficient information has been provided to demonstrate that the "landfill" has a liner designed to prevent leakage during its operating life. And rather than the regulations specifying what chemicals to monitor for in the groundwater, EPA will make a case by case determination for each "landfill". If the "landfill" leaks into the groundwater, there are no regulations requiring that the people drinking the water be given alternative water supplies or that they even be notified or that the dumping be stopped, or that remedial clean up action be taken. The only requirement is that EPA be notified and after due deliberation EPA will decide on the appropriate action to be taken. Thus, as is likely, if EPA has a larger backlog than it can handle, the pollution continues unabated until EPA can get around to it.
        In other words these regulations do not tell anyone what and what not to do but instead tells them when to come to EPA and EPA will decide in each and every case what should be done. All actions are funneled through the bureaucracy and nothing is done until EPA says so. The EPA permit system is the sole means of regulating dumps, supplanting even common law.
        EPA anticipates that issuing land disposal permits will be very labor intensive. But because the technology of "landfilling" is inherently unworkable, once the permits are issued they generate even more paperwork and personnel requirements. An unworkable system generates a lot of work; including monitoring reports, compliance reports, corrective action programs, and revised financial assurance plans, closure plans, post closure plans, contingency plans. . . ad infinitum.
        While the regulations place great demands on EPA staff they make no provision for assuring that they will have sufficient staff. EPA is asking the public in communities where their lives and property are at stake to take on faith that an administration which is pledged to reduce the regulatory burden on industry and to slash away at the size of the bureaucracy, will nevertheless give its full support to these highly bureaucratic regulations and their ever increasing demands.
        The final reason why the "second line of defense" is unworkable is that the regulations do not specify the level of protection to human health and the environment to be achieved. This is left to the discretion of the EPA Regional Administrators, unless the program is transferred to the states. To illustrate this, I have extracted excerpts from just one section, Subpart F - Groundwater Protection.
    264.90(b)(4) "The owner or operator is not subject to regulation under this subpart if the Regional Administrator finds that there is no potential for migration of liquid from a regulated unit..."
    264.93(b) "The Regional Administrator will exclude an Appendix VIII constituent from the list of hazardous constituents specified in the facility permit if he finds that the constituent is not capable of posing a substantial present or potential hazard to human health or the environment."
    264.94(a) "The Regional Administrator will specify in the facility permit concentration limits in the groundwater for hazardous constituents..."

    264.94(b) "The Regional Administrator will establish an alternate concentration limit for a hazardous constituent if he finds that the constituent will not pose a substantial present or potential hazard to human health or the environment..."

    264.96(a) "The Regional Administrator will specify in the facility permit the compliance period during which the groundwater protection standard.. .applies.

    264.98(a) "The Regional Administrator will specify the parameters or constituents to be monitored..."

    264.99(a) "The Regional Administrator will specify the groundwater protection standard...

    264.99(c) "...the Regional Administrator will specify the concentration limit .

        The standards could be very protective of human health and the environment or not very protective at all. There is no way to tell in advance since there is no "bottom line" in the regulations. Therefore, we cannot evaluate the regulations without evaluating the people to whom the regulations have delegated their authority.
        Regional Administrators are usually appointed by a newly elected administration from the ranks of loyal party workers as a reward for their efforts on behalf of the winning candidate. Most have no environmental experience and many in this administration are outspokenly pro-business, anti-regulation and anti-environment. EPA is telling the American people that what these 114 pages of regulations boil down to in the end is that the final decision the degree of security of their life, health and property will be made by someone who got his job through the "spoils system" and is not subject to any hard and fast standards of human health protection
        In those states with an authorized hazardous waste program, these decisions are delegated to the state rather than the EPA Regional Administrator. Therefore, every authorized State will be free to set its own level of human health and environmental protection Some states will set high levels and some States which wish to attract industry from the States with high levels, will set low levels. This is precisely the state-of-affairs which existed before Congress passed RCRA for the purpose of setting minimum standards which would be applied throughout the country.
        That is the extent of my review of the new EPA land disposal regulations. I would like to make a few miscellaneous comments on related subjects before I conclude.
        First, I would like to address the comment I often hear that while liners may not stop leakage from a "landfill" they have the virtue of slowing it down. This is not a virtue. If a dump is going to leak sooner or later then it is better for the adjacent community that it leak sooner. The longer it takes to leak the less wary they will be and the more likely they will have built houses and schools near the site and slack off on monitoring and maintenance. The sooner the pollution is discovered the better chance they have of finding a responsible party to clean up and pay for damages.
        Thus, I have to take exception with some of my friends in the environmental movement who have advocated retrofitting liners on existing dumps. This technology will not only cost enough to retire the national debt but it doesn't work and it will do the neighboring community more harm then good. The only ones who benefit by liners and by delaying the inevitable are the polluters and the environmental officials who both hope to be long gone when the problem is discovered.
        In regard to long-gone officials, the credibility of EPA and the government is frequently compromised by persons in high levels who leave the Agency for the payroll of the very people they were supposed to regulate. In particular, one of the largest dump operators in America is now paying for the services of the principal author of these land disposal regulations to promote the safety of their dump sites. This is still one more reason for the people living near these dumps to question the honesty and sincerity of their government.
        Lastly, in contrast to the convoluted and tortuous logic of EPA's land disposal regulations, I would like to propose a three sentence law which I think would resolve the land disposal issue for all time.
    Any person who has a technique for treating a hazardous waste or class of hazardous waste so as to render it non-hazardous may petition the Administrator to certify that technique for that waste or class of waste. One year after certification, land disposal of that waste or class of waste is forbidden. The Administrator may grant a one year waiver to a generator of such waste if there are no treatment facilities within five hundred miles of the site of generation.

    1. "Environmental Protection Agency, Hazardous Waste Management System; Permitting Requirements for Land Disposal Facilities", FEDERAL REGISTER, July 26, p. 32274.
    2. "Oversight of Hazardous Waste Management and the Resource Conservation and Recovery Act", Hearings Before the Subcommittee on Oversight of Government Management of the Committee on Governmental Affairs United States Senate, Ninety-Sixth Congress, First Session July 19 and August 1, 1979 (pp 330-385).
    3. "The Prevalence of Subsurface Migration of Hazardous Waste Chemical Substances at Selected Industrial Waste Land Disposal Sites", U.S. Environmental Protection Agency (EPA/530/SW-634), Washington, October 1977.
    4. "Pollution Prediction Techniques for Waste Disposal Siting; a State-of-the-Art Assessment", U.S. Environmental Protection Agency (SW-162c), Washington, 1978.
    5. David E. Daniel, "Problems in Predicting the Permeability of Compacted Clay Liners", Symposium on Uranium Mill Tailings Management, Fort Collins, Colorado, October 26-27, 1981, Geographical Engineering Program, Civil Engineering Department, Colorado State University.
    6. Allen Morrison, "Hazardous Waste Landfills--Can Clay Liners Prevent Migration of Toxic Leachate?", Civil Engeering-ASCE, July, 1981, p. 60.
    7. David Anderson, K.W. Brown and Jan Green, "Effect of Organic Fluids on the Permeability of Clay Soil Liners", published in "Land Disposal of Hazardous Waste", U.S. Environmental Protection Agency (EPA-600/9-82-002), Cincinnati, March, 1982.
    8. William J. Green, G. Fred Lee and R. Anne Jones, "Final Report on Impact of Organic Solvents on the Integrity of Clay Liners for Industrial Waste Disposal Pits: Implications for Ground water Contamination", U.S. Environmental Protection Agency, Ada, Oklahoma, June, 1979.
    9. Peter Montague, "Four Secure Landfills in New Jersey--A Study of the State of the Art In Shallow Burial Waste Disposal Technology", Department of Civil Engineering and Center for Energy and Environmental Studies School of Engineering/Applied Science, Princeton University, Princeton, NJ, Draft of February 1, 1981.
    10. Peter N. Skinner, "Performance Difficulties of 'Secure' Landfills for Chemical Waste and Available Mitigation Measures", American Society of Civil Engineers, October 1980.
    11. Peter H. Skinner, Testimony before the Assembly of California, February 2, 1982
    12. "Environmental Protection Agency, Hazardous Waste Management System; Standards Applicable to Owners and Operators of Treatment, Storage, and Disposal Facilities; and Permit Program", FEDERAL REGISTER, February 5, 1981, p. 11126.
    13. Public Law 96-510, "Comprehensive Environmental Response, Compensation and Liability Act of 1980", December 11, 1980, 107(k) (1).
    14. Richard L. Hanneman, "Post-Closure Liability Fund Endorsed", Waste Age, January 1982, p. 21.
    15. William Sanjour and Hugh B. Kaufman, "Superfund Priority List", U.S. Environmental Protection Agency Interoffice Memoranda, Washington, November 2, 1981.
    16. "Report to Congress--Disposal of Hazardous Wastes", U.S. Environmental Protection Agency (SW-115), Washington, 1974.
    17. "Physical , Chemical , and Biological Treatment Techniques for Industrial Wastes, Executive Summary", U.S. Environmental Protection Agency (SW-148c), Washington, 1977.
    18. "Alternatives for Hazardous Waste Management in the Inorganic Chemicals Industry", U.S. Environmental Protection Agency, Washington, 1977.
    19. "Alternatives for Hazardous Waste Management in the Organic Chemical, Pesticides and Explosives Industries", U.S. Environmental Protection Agency (SW-151c), Washington, 1977.
    20. "Alternatives for Hazardous Waste Management in the Metals Smelting and Refining Industries", U.S. Environmental Protection Agency, Washington, 1977.
    21. "Alternatives for Hazardous Waste Management in the Petroleum Refining Industry", U.S. Environmental Protection Agency (SW-172c), Washington, 1979.
    22. S. Kent Stoddard et al, "Alternatives to the Land Disposal of Hazardous Wastes--An Assessment for California", Office of Appropriate Technology, State of California, 1981.
    23. Edward J. Martin, E. Timonthy Oppelt and Benjamin P. Smith, "Chemical, Physical, Biological (CPB) Treatment of Hazardous Wastes", U.S. Environmental Protection Agency, Washington, September, 1982.
    24. "Discussion Paper: State Action to Reduce Land Disposal of Toxic Wastes", Department of Health Services, State of California, Sacramento, January, 1982.
    25. "Draft RCRA Guidance Document -- Landfill Design, Liner Systems and Final Cover", U.S. Environmental Protection Agency, Washington, July, 1982.
    26. Michael Brown, "Laying Waste, The Poisoning of America by Toxic Chemicals", Washington Square Press, New York, 1979.
    27. Lois Marie Gibbs, "Love Canal: My Story", Grove Press, New York, 1982.
    28. Samuel S. Epstein, Lester O. Brown and Carl Pope, "Hazardous Waste in America", Sierra Club Books, San Francisco, 1982.
    29. N. Neely, D. Gillespie, F. Schauf and J. Walsh, "Survey of On-Going and Completed Remedial Action Projects", U.S. Environmental Protection Agency (EPA-600/S2-81-246), Cincinnati, January, 1982.

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