October 16, 1984

EPA Journal
US Environmental Protection Agency
Office of Public Affairs (A-107)
Washington, DC 20460

Dear Editor:

I was very disappointed to read the article by Administrator Ruckelshaus entitled "Putting the Hazardous Waste issue in Perspective" which appeared in your October 1984 issue. In this article, Mr. Ruckleshaus does not seem to be aware of the very significant hazardous waste management program in EPA in the 1970's.

In the second paragraph Mr. Ruckleshaus states that "ten years ago, for all practical purposes, we were unaware that there was a hazardous waste problem". Yet eleven years ago, in response to a 1970 Congressional mandate, EPA submitted a 110 page report to Congress on the "Disposal of Hazardous Wastes". There is very little said in your October issue on the hazardous waste problem that you would not find in that report. (The report is still available from the Office of Solid Waste as SW-115.)

The article goes on to say that. "those concerned with solid waste in the mid-seventies" did not become aware of the hazardous waste problem until "the revelations of the late seventies, when the careless disposal practices of the past began to turn places like Love Canal and the Valley of the Drums into images of environmental calamity."

This is a curious statement to make in light of the fact that the Federal law mandating EPA to regulate hazardous waste practices (RCRA) was passed in 1976, two and a half years before the first Congressional hearings on Love Canal. And for several years before the passage of RCRA, EPA had testified in Congress on the horrors of past hazardous waste disposal practices which is reflected in the legislative history of RCRA. Indeed, by 1975 EPA had collected a dossier on over 400 hazardous waste disaster sites, which had grown to over 600 by 1978, most of which are now on the National Priorities List.

Mr. Ruckelshaus next says that "in the late seventies when we began to write regulations for the control of hazardous waste disposal required by RCRA, we didn't know where the generators were; we didn't know what was in their waste streams, or how much there was of it or how hazardous it might be; and we didn't know where it was going."

In fact, starting in the early seventies, in anticipation of legislation, EPA spent tens of millions of dollars gathering just such information. By the late seventies one could literally fill up a wall of shelves with all the reports generated on these subjects including a mailing list of hundreds of thousands of potential hazardous waste generators. Granted, the information was not always complete but it was a far cry from the vacuum suggested by Mr. Ruckelshaus.

Rather than being taken by surprise as suggested by Mr. Ruckelshaus, EPA had anticipated the hazardous waste problem and was working towards a solution when the problem came to national attention in the late seventies. Indeed EPA's efforts helped bring it to national attention. It is a pity that a decade of good work by some very dedicated people at EPA is being written out of history.

                                                                                     Sincerely yours,
                                                                                     William Sanjour
                                                                     Policy Analyst, Office of Solid Waste

William Ruckelshaus

William Sanjour's home page

Free counters provided by Honesty Communications.