Integrated Waste Management to ensure protection of...

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copy Conference for Industry and Education Collaboration American Society for Engineering Education

February 2-4 2011 San Antonio Texas

Integrated Waste Management to ensure protection of MSW Landfills

Albert V Condello III University of Houston Downtown

Engineering Technology Department Houston Texas

Abstract

In this paper the author helps to transform education of engineering technology students

to be aware of the precautions implemented with regard to the recovery efforts related to

the BP Deepwater Horizon Crude Oil Spill This incident of national consequence

required the collaboration of EPA State Environmental Agencies and US Coast Guard to

ensure the protection of groundwater aquifers from contaminated sludge Unique insight

is shared with regards to successful practice involving environmental and civil

engineering principles to address this challenge The overall goal of this paper is to

identify those critical success factors necessary to put into practice during any man-made

or natural disaster

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Introduction

The goal of this research paper will be to provide insight into how coordination is

being achieved for each of the municipal solid waste (MSW) landfills These MSW

landfills could be adversely affected from the BP Oil Spill vis-agrave-vis resulting in further

long-term risks to human health resulting from this environmental catastrophe

To assure that solid wastes are handled properly waste management plans have been

prepared and have been reviewed by the US Coast Guard (USCG) the US

Environmental Protection Agency (EPA) and the involved state environmental protection

agencies of Alabama Florida Louisiana Mississippi amp Texas BP has contracted with

Waste Management (for Alabama Mississippi amp Florida) amp Heritage for Louisiana as

the two waste handlers for activities associated with the collection and management of

the waste streams

This research paper will discuss how such USCG amp EPA Directivesrsquo have ensured that

statersquos regulations are being followed by BP and its contractors amp allows each of the

states to provide further oversight and impose more specific requirements Lessons

learned will be shared in how to provide a quality environment for future generations

Specific examples as well as discussion on what options are available will be cited

Insight into how to make linkage with an integrated solid waste management program

will also be discussed

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Background

The concerns of the citizens of Alabama Florida Mississippi amp Louisiana that

oily amp dispersant soaked debris might end up untreated and improperly buried at their

sanitary municipal waste (MSW) landfills could happen Such concerns are warranted as

if this is allowed to be done the result could be pollution to groundwater and soils

allowing further contamination of drinking water aquifers Solid wastes recovered oil

oily fluids oiled debris and other waste and recyclable materials collected during the

Deepwater Horizon response are being handled safely and in accordance with existing

federal state and local regulations

A recent NBC News Investigation by Lisa Myers into BPrsquos extensive use of dispersants

in the Gulf of Mexico totaling 18 million gallons suggest that when mixed with crude

oil the dispersant may prove to be more toxic to marine life than the weathered crude oil

itself (NBC Nightly News July 30 2010)

Per Deepwater Horizon Response Website Operations and Ongoing Response as of July

30 2010 Oily water recovered more than 347 million gallons Amount estimated burned

111 million gallons

Surface dispersant used 1 072514 gallons

Subsea dispersant used 771272 gallons

Total dispersant used 1843786 gallons

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According to Luis A Soto a deepwater biologist with the University of Miami ldquoCrude

oil does contain toxic compounds known as PAH ndash lsquopolycyclic aromatic hydrocarbonsrsquo

which are not easily absorbed by bacteriardquo As Dr Mervin Fingas states ldquoCurrently

restrictions under HSWA 40 CFR 268 prohibit the land disposal of hazardous waste

unless the waste meets treatment standards established by EPArdquo (Cox amp Borgas p 676)

Dr Stephen Humphrey with University of Florida says ldquoOne of the striking

controversies about the massive BP Deepwater Horizon oil well blowout has been alarm

raised about chemical dispersants used to hold spilled crude oil deep in the Gulf of

Mexicordquo

Dispersants are chemicals that can be used to break up oil and speed its natural

degradation They are generally less harmful than oil and biodegrade more quickly than

untreated oil In the case of the Deepwater Horizon oil spill dispersants have been useful

in breaking up the oil offshore and preventing more oil from reaching fragile coasts and

wetlands

ldquoUse of dispersants on the BP spill reportedly began on April 27 2010 but Corexit

9527A (which contains 2-butoxyethanol) and has acute toxicity (eg hemolysis and

tumors in rats) was soon discounted in favor of Corexit 9500Ardquo (kerosene based)

(Lustgarden ProPublica) The exact makeup of the Nalco dispersants is kept secret under

competitive trade laws but a MSDS worker safety sheet for one product called Corexit

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9527A says it includes 2-butoxyethanol a compound associated with headaches

vomiting and reproductive problems at high doses (Lustgarden) Since the well was

capped on July 15 2010 dispersant use has ceased

According to Michael Condon Environmental Unit Leader (Houma LA) ldquoall waste

streams from the BP Oil Spill can be classified into four categories recovered product

from skimming operations oily water ndash taken for injection at a certified facility oiled amp

non oily solid wasterdquo (BP Video)

The added concern is that the weathered crude oil-contaminated (oiled) waste has mixed

in with it dispersant Typical operations that result in crude oil-contaminated waste

include shoreline cleanup skimming booming and decontamination of vessels or

equipment

The oiled waste may be solids or liquids and the common forms of wastes are as follows

1 From shoreline cleanup tar balls oiled vegetation oiled sand oiled debris used

personal protective equipment (PPE) and disposal equipment

2 From oil containment capture and skimming operations oil and oily water oiled

debris and sorbent materials

3 From vessel and other decontamination operations oily water oiled sorbent

materials and personal protective equipment (PPE)

One might ask what is Integrated Waste Management amp how can it be applied to the BP

Oil Spill situation According to the EPA ldquoIntegrated Solid Waste Management (ISWM)

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is a comprehensive waste prevention recycling composting and disposal programrdquo

(EPA Fact Sheet 2010)

An effective ISWM system considers how to prevent recycle and manage solid waste in

ways that most effectively protect human health and the environment ldquoISWM involves

evaluating local needs and conditions and then selecting and combining the most

appropriate waste management activities for those conditions rdquo(EPA Fact Sheet 2010)

How ISWM is being achieved related to the BP Oil Spill is that reducing waste at the

source means that oily covered solid waste is kept separate by the cleanup crews Reuse

is not an option as all of the marketable light ends of the weathered crude oil have

volatilized The oil sludges cannot be put back into production

Land farming is not an option according to Dr Mervin Fingas with Environment Canada

Recycling of the sand and water once oily sediment is separated is an option Frac trucks

at the locations where boom is decontaminated allow for this All pits are HDPE lined

with sumps to pump and capture any leachate and solvent uses Combustion to treat oily

covered sand to rid it of hydrocarbons and allowing the sand to be returned is a thermal

treatment is being done No use of chemicals methods such as Corexit 9580 for shoreline

cleanup is being allowed

In retrospect all waste management activities related to the BP Oil Spill do coincided

with those major ISWM activities as they are equally concerned about waste prevention

recycling and composting and combustion and disposal in properly designed

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constructed and managed landfills (EPA Fact Sheet) ldquoThe explosion and collapse of

the BP-owned Deepwater Horizon oil rig on 20 April 2010 uncorked an underwater

geyser that for 85 consecutive days shot an estimated daily load of 147ndash252 million

gallons of crude oil1mdashand possibly moremdashinto the Gulf of Mexicordquo (Schmidt 2010)

Table 10 Example of Common LDR Treatment Technologies Specified in 40 CFR 26840 Technology Name Technology Code Description Waste Treated

Biodegradation BIODG

Chemical breakdown of organics nonmetallic inorganics by microbes

Many dilute organics phosphorus nitrogen or sulfur-containing inorganics

Chemical Oxidation CHOXD

Oxidation with hypochlorite chlorine peroxide ozone or other oxidizer

Many organics alternative specified technology for many organic wastewaters and some non-wastewaters

Combustion CMBST

Treatment in 40 CFR 264265 Subpart O incinerators and 40 CFR 266 Subpart H Boiler and Industrial Furnaces (BIFs)

Many dilute and concentrated organics specified technology for many non-wastewater organics

Deactivation DEACT

Removal of the hazardous characteristics usually by chemical means (eg neutralization open burning detonation)

Ignitable Corrosive Reactive (ICR) Wastes specified technology for D002 - Corrosivity D003 - Reactivity except cyanides

Stabilization STABL

Immobilization of metals or inorganics in Portland Cement limepozzolans or similar matrices

RCRA metals inorganics (eg metal containing sludge from industral wastewater treatment facilities (WWTFs) incinerator ash

Source Chap 41 RCRA Overview A Generator Perspective Primary LDR Treatment Standards P 679 Gregory C DeCamp

Hazardous Materials Management Desk Reference 2nd Edition ACHMM (2005)

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Methods

To the extent possible water is separated from the oil treated and reused or

disposed at permitted disposal facilities The recovered oil is sent to facilities that recycle

or re-process the oil Recovered oil that is not suitable for recycling or re-processing may

be disposed at properly permitted facilities such as underground injection disposal wells

According to the EPA-Coast Guard directive on the waste management plans the work

must be done in accordance with all relevant regulations of localstate health and

environmental agencies the EPA and the Coast Guard Before moving treating or

disposing of this material all solid wastes are reviewed for their contents in advance of

being hauled away to any of the MSW landfills (Refer to All States Solid Waste

Sampling results for the month of July 2010 discussed in Results p14)

According to Waste Management (WM) they compare what is coming into their sanitary

landfill to that which is allowed by state and federal regulatory and permit requirements

to ensure that requirements for safe handling and disposal of this material are carefully

followed Waste Management receives the cleanup waste material from BPrsquos shoreline

crews at a ldquodrop zonerdquo At the drop zone the individual state environmental agencies

characterizes whether or not the waste is hazardous or non-hazardous

The oil material Waste Management is collecting and bringing to the permitted landfills

is considered by the EPA to be non-hazardous special waste Once the waste has been

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characterized as non-hazardous Waste Management then transports the approved

materials to the landfill site

Generally solid wastes are transported by roll off yard container to solid waste landfills

by truck Liquid wastes are transported in tankers vacuum trucks or via barge to the

recycling or disposal facilities

There are two types of booms being used sorbent boom and barrier boom which could

pose the greatest risk to human health if not properly handled as solid waste Barrier

boom can be decontaminated and reused whereas sorbent boom generally is not reusable

The job of sorbent boom is not to block the oil but rather to absorb it so that it can be

removed from the water along with the boom itself Improper disposal of sorbent boom

into MSW landfills could contaminate leachate resulting in groundwater pollution

To prevent oily contaminated boom from being improperly disposed techniques are used

at staging areas to remove oil to the maximum extent possible from barrier booms Used

sorbent booms may be either sent to permit landfills for disposal if not too oily or sent to

an appropriate facility to be burned as fuel if very badly oiled Barrier boom is intended

to channel the oil into areas where it can be skimmed While barrier boom is intended to

be reused it may at times become damaged to the point that it must be disposed of in a

landfill

The used boom is placed into watertight covered roll-off boxes at a decontamination

station It is taken to a staging pad where the boom is pressure-washed with hot water and

a cleaning solution (if needed) Recovered oil is collected for treatment re-use or

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disposal The wash water is treated on site and either recycled or sent to a permitted

disposal facility Decontaminated boom that can be reused is redeployed to the response

or returned to the owner If the boom cannot be reused it may be disposed in a landfill

Oiled sorbent materials and other oily debris are bagged and placed in watertight

containers for transportation to permitted solid waste landfills EPA is currently

collecting and analyzing water and sediment samples to help states and other federal

agencies understand the immediate and long-term impacts of oil contamination along the

Gulf coast EPA is tracking the prevalence of potentially harmful chemicals in the water

because of this spill to determine the level of risk posed to fish and other wildlife While

these chemicals can affect ecosystems drinking water supplies are not expected to be

affected The oil itself can cause direct effects on fish and wildlife for example when it

coats the feathers of waterfowl and other types of birds In addition other chemical

compounds can have detrimental effects Monitoring information allows EPA to estimate

the amount of these compounds that may reach ecological systems When combined with

available information on the toxicity of these compounds EPA scientists can estimate the

likely magnitude of effects on fish wildlife and human health

Before the Deepwater Horizon explosion ldquodispersantrdquo was hardly a household word The

two products used in the spill Corexitreg 9500 and 9527 are manufactured by Nalco a

company based in Sugar Land Texas The Material Safety Data Sheet (MSDS) for each

dispersant indicates they contain one of two solvents 2-butoxyethanol (2-BE) found in

Corexit 952711mdashan older product dating back to the 1970smdashor petroleum distillates

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found in the newer Corexit 950012 product The Corexit dispersants also contain organic

sulfonic acid salt (a surfactant) and propylene glycol (a stabilizer) (Schmidt 2010)

Citing results mainly from animal studies the MSDS for Corexit 9527 claims 2-BE may

cause hemolysis (destruction of red blood cells) or kidney or liver damage with repeated

or excessive exposure whereas the formulated dispersant also may cause skin or

gastrointestinal irritation11 The MSDS also states that ldquohuman red blood cells [exposed

to 2-BE] have been shown to be significantly less sensitive to hemolysis than those of

rodents and rabbits These effects are transient and when exposure is discontinued these

effects subsiderdquo11 In contrast to the MSDS for Corexit 9527 which assigns a ldquomoderaterdquo

human health risk to this compound11 the 9500 MSDS lists the human health risk as

ldquoslightrdquo12 (Schmidt 2010)

Source BP Personal Exposure Monitoring Results Summary Health Monitoring

Summary Reportmdash27 April 2010 to 15 July 2010 Available httptinyurlcom39gm29l

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In summary these plans do take into consideration what is allowable by

reviewing of applicable federal state and local regulations help in planning for waste

characterization and comply with BPrsquos proposed locations for waste management

activities in order to consider the suitability of specific sites and the impacts on the

surrounding communities

Given the unprecedented aspects of the BP oil spill these plans may be updated as

necessary to minimize any unforeseen environmental and human health impacts I have

not personally been able to perform observations as now BP is scaling back operations

and I am not sure when will be the next time that I will be deployed on the BP Oil Spill I

plan to conduct interview with WM and Heritage personnel at each of the MSW landfills

when I will be deployed

As for the treatment of the rinse water used from the steam cleaning and ldquohotseyrdquo pressure

washing of oily barrier boom with citrus-based degreaser please refer to Appendix H -

Decontamination Water Treatment System found on page 35 of this research paper PES-

51 is the preferred solvent but CitrusStar was used at the Grand Isle Shipyard in Louisiana

Such degreasers are be used for cutting through the weathered crude oil which might be

clinging to the barrier boom amp other equipment such as the vessels used to support near

shore skimming operation

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Results

US EPA is reviewing the sampling data to provide up-to-date listing of the

contaminants found in the captured crude oil-contaminated waste that has been collected

during the response These wastes have been classified in federal and state regulations as

non-hazardous waste Since the waste is considered non-hazardous it is allowed to be

disposed in the appropriate state-permitted municipal solid waste landfills Ongoing

testing will continue to take place during the response including testing performed by

EPA in order to verify that the appropriate disposal or reuserecycling options are used

Sediment samples collected to assess potential oil spill impacts on aquatic life near shore

were analyzed for 29 chemicals that are components of oil To reach a level of concern in

the table below only one of the 29 chemicals needed to be present at that level

(Appendix G ndash Chemicals of Environmental Concern)

Certain wastes coming into the staging areas may be identified as recyclable or used for

energy recovery BP is investigating options for reuserecycle of the oiled liquid wastes

and some of the oily solids which may include energy recovery In addition BP is

evaluating ways to recycle decontaminated boom and other used response equipment that

contain plastics and metals If such were the case these wastes would be taken to the

approved facility for recycling or energy recovery

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According to Mervin Fingas in his book The Basics of Oil Spill Cleanup ldquoland farming

is the application of oil and refinery waste to land where it degradesrdquo (Fingas 2001 p

119) Fingas goes on to state that ldquoThis practice is now banned in most jurisdictions since

many oil components do not break down and contaminants such as metals and PAH are

carried away from the site often in groundwaterrdquo (Fingas 2001 p 119)

Lightly contaminated water less than 15 ppm by weight of oil can usually be returned to

the water body from where it came from (Fingas 2001 p 119) More contaminated

water may require further treatment in separators or at a municipal wastewater treatment

plant (Fingas 2001 p 119)

Waste Streams from the BP Oil Spill are being disposed in the appropriate state-

permitted municipal solid waste landfills Testing will continue to take place during the

response including testing performed by EPA in order to verify that the appropriate

disposal or reuserecycling options are used

To date the designated sites are Chastang in Alabama Spring Hill in Florida various

sites in Louisiana and Pecan Grove in Mississippi At this time no crude oil contaminant

is being sent to Pecan Grove Results from July 2010 Solid Waste Sampling ndash Exceeding

DATE STATE NAME SUBSTANCE RESULT REPORTING LIMIT Delta Pct OverUnder Limit REPORTING LIMIT UNIT 7102010 Mississippi Barium 006 005 001 100 mgL

7142010 Alabama Zinc 006 005 001 100 mgL 7122010 Florida Zinc 006 005 001 100 mgL 7122010 Alabama Barium 007 005 002 200 mgL 7102010 Mississippi Zinc 007 005 002 200 mgL 7102010 Mississippi Barium 009 005 004 400 mgL

722010 Louisiana Barium 006 001 005 500 mgL 7142010 Alabama Barium 013 005 008 800 mgL 7122010 Alabama Zinc 019 005 014 1400 mgL

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722010 Louisiana Barium 021 001 020 2000 mgL 7142010 Alabama Barium 044 005 039 3900 mgL 7102010 Mississippi Zinc 051 005 046 4600 mgL 7102010 Mississippi Cresol 18 15 300 30000 ugL 7142010 Alabama Zinc 85 005 845 84500 mgL

BP Oil Spill Staging Area Solid Waste Totals as of July 20 2010

Staging Area State Amount Venice LA 2204 tons Lafitte LA 892 tons Hopedale LA 1084 tons Slidell LA 443 cubic yards Grand Isle LA 4130 tons Fourchon LA 1392 tons Cocodrie LA 682 tons Montegut (PAC) LA 601 tons Dulac LA 326 tons St Mary (Horseshoe) LA 183 tons Berwick LA 10 tons Theodore AL 1339 tons Foley AL 6019 tons Fort Walton FL 700 tons Pensacola FL 5144 tons Panama City FL 125 tons Pecan Grove MS 1630 tons Pascagoula MS 413 tons

BP Oil Spill Staging Area Liquid Waste Totals as of July 20 2010

Staging Area State Amount

Venice LA 79426 BBLS Lafitte LA 675 BBLS Hopedale LA 7415 BBLS Slidell LA 1560 BBLS Grand Isle LA 16387 BBLS Fourchon LA 60042 BBLS Cocodrie LA 930 BBLS

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Montegut (PAC) LA 0 BBLS Dulac LA 0 BBLS St Mary (Horseshoe) LA 0 BBLS Berwick LA 0 BBLS Intracoastal LA 0 BBLS Misc LA 450 BBLS

BP Oil Spill Landfill Solid Waste Totals as of July 20 2010

Disposal Facility State Amount Disposed

Tidewater LA 2204 tons

Colonial LA 7720 tons

Jefferson Parish LA 225 tons

River Birch LA 1406 tons

Jefferson Davis LA 182 tons

Pecan Grove MS 1945 tons

Chastang AL 1339 tons

Magnolia AL 5636 tons

Springhill FL 14623 tons

BP Oil Spill Facilities Receiving Liquid Waste as of July 20 2010

Riverbirch Inc LA 9425 Barrels

Newpark Environmental Services

TX 155855 Barrels

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In summary the following tables reflect the Wastes that are being collected from various

areas stored in staging areas and then sent to appropriately permit waste management

disposal facilities The information above lists the staging areas and disposal facilities

receiving solid and liquid wastes from the Gulf oil spill cleanup

Under the Directives issued to BP oily solid waste must only be sent to state regulated

landfills that are specifically permitted to receive such wastes These landfills must

comply with the federal regulations within Subtitle D of the RCRA and additional state

regulations which include design requirements to prevent these wastes from

contaminating groundwater

Recently published in Water Resources is a research study which suggests that oil

pollution may render the seafloor unable to filter out arsenic that occurs naturally in the

ocean and is introduced by drilling operations and oil spills (Wainipee et al June 2010)

Sediments on the seafloor naturally bind arsenic removing it from seawater The authors

of the new laboratory study found that low pH levels in seawater created a positive

charge on samples of goethite (an iron oxide that is one of the most abundant compounds

in ocean sediments) which then attracted negatively charged arsenic Adding oil to the

water created a physical barrier on the goethite and weakened the attraction between the

two minerals If oil pollution causes similar effects in ocean waters the authors speculate

arsenic may concentrate in the food chain to potentially harmful levels (Schmidt 2010)

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Conclusion

BP is using a holistic approach to managing solid waste streams from the oil spill

There has been no negative impact on the landfills in each of the four states so far EPA

and US Coast Guard have developed a directive as an effective strategy to ensure an

integrated approach is in place and being followed EPA has been now posting waste

sampling results from environmental audits being done at each of the waste staging areas

and can be accessed from the EPA webpage sharing the results of such analysis Refer to

Appendix B for independent quality review that whas been completed

EPA has approved the Waste Analysis plan and has demonstrated that Land Disposal

Restrictions (LDR) standards are not being exceeded and compliance is being achieved

According to Cox amp Borgas residuals not meeting standard must be removed annually

(Cox amp Borgas p 678) EPA has been assisting local communities and each of the State

environmental agencies to find what is the most environmentally acceptable approach to

see is being put in place and adhered to by BP and its waste hauling contractors

EPA has observed odor-causing pollutants associated with oil on the shore in the gulf

region at low levels Some of these chemicals may cause short-lived effects like

ETD 452

headache eye nose and throat irritation or nausea Some people may be able to smell

several of these chemicals at levels well below those that would cause short-term health

problems

EPA surface water samples collected on July 14 and 15 along the Gulf Coast found no

compounds exceeding chronic water benchmarks These results include data for

compounds found in dispersants in samples EPA sediment samples collected on July 14

2010 along the Gulf Coast found no compounds exceeding chronic sediment benchmarks

According to EPA Response to BP Oil Spill website ldquoto date waste sampling results do

not exceed regulatory limits for the disposal of oil waste in state permitted landfills

These landfills have already been identified for disposal of BPs collected oil waste and

material in the Waste Management Plans approved by the US Coast Guard in

consultation with EPA and the States involved in this responserdquo (EPA 2010)

In summary the sites where direct disposal of the oily debris should be adequately lined

to contain any leachates and test wells at the site should be established so that water

quality monitoring can take place to be sure that oil is not leaching into groundwater

(IMO p 168) According to EPAs website from Coastal Water Sampling ldquosurface water

samples collected July 21 - 22 2010 along the Gulf Coast did not reveal elevated levels

of chemicals usually found in oil

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EPAs surface water samples collected July 15 21 and 22 2010 along the Gulf Coast

were measured for three of the chemicals associated with dispersants (Dioctyl

sulfosuccinate sodium salt 2-Ethylhexyl Alcohol and 2-Butoxyethanol) but did not

detect themrdquo (EPA 2010) But weeks after use of Corexit 9527 was supposedly phased

out BP released data indicating 2-BE was still being detected in 20 of personal air

samples collected offshore14mdasha finding that has not been explained Frank Mirer a

professor of toxicology at Hunter College comments ldquoIt is implausible that this fraction

of samples with detectable levels would be found if 2-BE were no longer being used

This calls into question the accuracy of dispersant usage information being reportedrdquo

(Schmidt 2010)

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References ATSDR (Sept 1996) ToxFAQs for Polycyclic Aromatic Hydrocarbons Agency for Toxic Substances and Disease Registry - Division of Toxicology and Environmental Medicine Atlanta GA accessed on July 24 2010 from httpwwwatsdrcdcgovtfacts69html Cox Doye B amp Borgas Adriane P (2005) Hazardous Materials Management Desk Reference 2nd Edition Academy of Certified Hazardous Materials Managers Rockville MD Chapter 41 ndash RCRA Overview A Generator Perspective - Treatment Standards p 678-680 EPA Website (May 2002) What is Integrated Solid Waste Management Fact Sheet US Environmental Protection Agency Publication EPA530-F-02-026a (5306W) Solid Waste and Emergency Response accessed on July 24 2010 from httpwwwepagovclimatechangewycdwastedownloadsoverviewpdf Exxon Mobil (2008) Oil Spill Response Field Manual ExxonMobil Research and Engineering Company Chapter 14 ndash Waste Management 146 Disposal Methods p 14-18 thru 14-23 Fingas Mervin F (2000) The Basics of Oil Spill Cleanup 2nd Edition CRC Press IMO (2005) Manual on Oil Pollution Section IV Combating Oil Spills 2nd Edition International Maritime Organization London Publication IA569E Chapter 11 ndash Management and Disposal of Oil and Oily Debris 116 Waste Disposal Methods P 165 Johnson Tim (May 20 2010) Gulf Recovered from last big oil spill but is this one different McClatachy Newspaper - Washington Bureau accessed on July 24 2010 from httpwwwmcclatchydccom2010052094562gulf-recovered-from-last-big-oilhtml Levin Alan (June 17 2010) USA Today BPrsquos Next Challenge Disposal of Tainted Sludge Accessed on July 24 2010 from httpwwwusatodaycomnewsnation2010-06-16-oil-waste_Nhtm Lustgarden Abraham (April 30 2010) ProPublica website Chemical Meant to Break up BP Oil Spill Present new environmental concerns Accessed on July 24 2010 from httpwwwpropublicaorgarticlebp-gulf-oil-spill-dispersants-0430 BP (June 22 2010) Gulf of Mexico Response website Interview with Michael Condon Environmental Unit Leader at Houma LA Command Post - Waste Recovery accessed on July 31 2010 from httpbpconcertscomgomwasterecovery062210htm Wainipee W Weiss DJ Sephton MA Coles BJ Unsworth C Court R (June 9 2010) Water Resources The effect of crude oil on arsenate adsorption on goethite 101016jwatres201005056 PMID 20599240

ETD 452

Schmidt CW 2010 Between the Devil and the Deep Blue Sea Dispersants in the Gulf of Mexico Environ Health Perspective 118(8) doi101289ehp118-a338 Myers Lisa (2010) MSNBC Video aired on NBC Nightly News ndash Scientists say BP Dispersants increase toxicity of oil Accessed on July 31 2010 from httpwwwmsnbcmsncomid21134540vp3849220138492201 Kerr Richard Kintisch and Stokstad Erik (May 2010) Science Magazine Will Deepwater Horizon Set a New Standard for Catastrophe Volume 328 No 5979 pp 674-675 DOI 101126

Biographical Information

Albert V Condello III is a lecturer visiting associate professor with the

University of Houston Downtown with their Engineering Technology Department since

the fall 2008 semester He is presently pursuing a Masters degree in Occupational Safety

and Health with a concentration in Environmental Engineering from Columbia Southern

University Condello has worked with Nuclear Power Institute developing outreach

programs allowing students to move into utility training programs He is also an

authorized OSHA Outreach Instructor for both General Industry and Construction

Standards

Foreign teaching assignments have been in such areas as in Ndola Zambia Africa

offering a course on Soil and Groundwater Remediation and in London England

teaching Environmental Control for Oil and Gas Exploration

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Appendix A ndash Waste Management Plans

Recovered Oil Approved Related to

Deepwater Horizon Rig Incident (MC Block 252)

From Houma LA Command Post (approved on June 14 2010)

Waste management plan for Louisiana (PDF) (60pp 57MB)

From Mobile AL Command Post (approved on June 24 2010)

Waste management plan for Mississippi Alabama and Florida (PDF) (36pp 785 K)

Source BP Website ndash Gulf of Mexico Incident ndash Waste Management Plans httpwwwbpcomgenericarticledocategoryId=9034343ampcontentId=7063426

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Appendix B ndash EPA Independent Waste Sampling Strategy EPA or its contractors will collect samples of waste that are temporarily collected at selected waste staging areas to ensure that all the waste is properly characterized A representative sample of the following waste streams (if available) will be collected at each of the chosen staging areas 1 Oily solid waste 2 Liquid waste this includes Liquids sent for underground injection andor Non-reclaimable liquids sent for disposal Samples will be collected handled and analyzed in accordance with the appropriate EPA Regional policy and protocol Solid waste will be analyzed for

bull Toxicity Characteristic Leaching Procedure Volatiles by SW-846 Method 13118260B

bull Toxicity Characteristic Leaching Procedure Semivolatile Compounds by SW-846 Method 13118270D

bull Toxicity Characteristic Leaching Procedure Resource Conservation and Recovery Act

List Metals by SW-846 Method 13116010C and SW-846 Method 13117470A

bull Free Liquids by SW-846 Method 9095B Paint Filter Liquids Test Liquid waste will be analyzed for

ETD 452

List Metals by SW-846 Method 13116010C and Method 13117470A

bull Ignitability by SW-846 Method 10101020 BP and the State Incident Commanders will be notified prior to EPA sampling the waste Sampling will be conducted two times per month at selected waste staging areas Based on sample results and waste handled at staging areas this plan may be modified The daily waste tracking information submitted by BP which contains the type and quantity of waste handled at each staging area will serve as the basis for selecting staging areas for sampling EPA Independent Waste Sampling Strategy (PDF) (1pg 23K) Accessed on July 31 2010 from httpwwwepagovbpspillwastewaste_sampling_strategypdf

Appendix C - Map of staging decontamination sites in LA MS AL and FL

Source EPA Website ndash EPA Waste Site Visit Plans and Results (July 22 2010) accessed on July 24 2010 from httpwwwepagovbpspillwastehtml

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Appendix D ndash Lessons Learned

Waste management overview Types of waste anticipated

bull Solids o Oil contaminated material (personal protective equipment sorbents debris) o Non-contaminated material (trash recovered from beaches cleaned

preemptively or trash generated by support operations) bull Recoverable oil amp oily water

o Typically generated during skimming operations o Oilwater to be separated and sent to the appropriate recyclingdisposal

facility bull Decontamination water

o Water generated by on shore decontamination of equipment and personnel o Sent via vacuum truck to an approved disposal facility

bull Animal carcasses o US Fish and Wildlife Service responsible for collecting and storing animal

carcasses

Waste disposal Waste minimization strategy re-use recycle disposal

bull All waste streams will be profiled bull Waste is likely all non-hazardous bull Disposal sites have been identified audited and approved (RCRA Subtitle D

Landfills or permitted liquid recyclingdisposal facility) bull Recycling options are under evaluation for certain materials (booms recovered oil)

Waste handling process

bull Waste is collected near the point of origin and stored in the appropriate container (lined roll-off bin vacuum truck or frac tank)

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bull As necessary waste containers are moved to staging areas (waste management establishing six sites)

bull Transported to appropriate disposal facility and disposed o Waste volumes are tracked by type

Decontamination strategy

bull On shore decontamination sites are being established to decontaminate equipment o Sites will have fully-lined and bermed decontamination areas and closed-

loop water treatment systems

Appendix E ndash Fact Sheet ndash Waste Streams from BP Oil Spill

Waste Trash amp Disposal ndash Dated July 30 2010

Where does all that oil oiled waste and trash go In response to the oil spill BP has set up a waste management program much like those in many American cities and towns Each day waste is picked-up from lots of locations carried to a central location where it is sorted and then sent for recycling or disposal Workers pick-up waste from beaches marshes and coastal waters every day Most of this waste is oiled sand oiled vegetation or clean-up materials used by the workers (oiled sponges towels rags) Some of the waste is typical trash like that from any job site (bags bottles litter) This trash is separated and taken to a permitted landfill Recyclable trash is separated and sent to local recycling centers Oiled waste from these different locations is taken to nearby staging areas Here - the waste is sorted and wastes of the same kind are combined into a large shipment Shipments are tested to decide where they should be sent for disposal Workers also replace oiled boom along the coastal areas or used by boats Some boom can be washed to remove oil and reused several times Oiled boom and even small oiled boats also come to staging areas to be washed so they can be reused These staging areas have equipment similar to a car wash and they collect dirty water and oil so it can be treated The remaining dirty water is filtered to remove more oil and sent to a local wastewater treatment plant If test results indicate that the dirty water cannot go to the cityrsquos plant it is trucked off to a permitted liquid disposal facility where it is injected deep underground Old filters have to be sent to a permitted landfill State Environmental Agency and EPA personnel visit the temporary staging areas to make sure BP is doing a good job and their operations comply with the law

BP is required to test waste for toxicity EPA is also conducting its own independent tests of waste So far none of the waste samples has exhibited hazardous characteristics The sorted waste is trucked to permitted landfills that have been approved by the state to take oiled waste Private companies run these landfills as businesses and charge companies to use them Since these landfills are private businesses ndash State and EPA personnel are also visiting them to make sure they are doing a good job and following the law

ETD 452

BP is responsible for making sure waste is collected and disposed of correctly The company is paying workers to collect the waste as well as paying for the disposal The US Coast Guard is the lead for the response and cleanup Both your State Environmental Agency and EPA are helping the Coast Guard inspect and watch clean-up work and disposal of waste US Coast Guard and EPA have outlined additional requirements for BP including that BP share information about the amounts types and destination of waste and setting up a complaint system for people to contact Coast Guard States and EPA believe everyone should have up-to-date and accurate information Source Deepwater Horizon Response Website Fact Sheets (July 30 2010) Oil Waste Trash and Disposal Fact Sheet (19150 KB) Accessed on July 31 2010 from httpwwwdeepwaterhorizonresponsecomposted2931Waste_One_Pager_7_26_10_final835891doc

Appendix F ndash Literature Search

Results from Search Oily Sludge ndash 31 articles found

1 Sheep Reared on Sewage SludgendashTreated Pasture Sharpe Responds Richard Sharpe Correspondence published 01 Feb 2006 | doi101289ehp114-a88a

2 Microbial Risk Assessment Framework for Exposure to Amended Sludge Projects Joseph NS Eisenberg Kelly Moore Jeffery A Soller Don Eisenberg John M Colford Research Article published 13 Mar 2008 | doi101289ehp10994

3 Sheep Reared on Sewage SludgendashTreated Pasture Flawed Conclusions Tim Evans Correspondence published 01 Feb 2006 | doi101289ehp114-a87

4 Cellular and Hormonal Disruption of Fetal Testis Development in Sheep Reared on Pasture Treated with Sewage Sludge Catriona Paul Stewart M Rhind Carol E Kyle Hayley Scott Chris McKinnell Richard M Sharpe Research Article published 11 Jul 2005 | doi101289ehp8028

5 Alkyl Phenols and Diethylhexyl Phthalate in Tissues of Sheep Grazing Pastures Fertilized with Sewage Sludge or Inorganic Fertilizer Stewart M Rhind Carol E Kyle Gillian Telfer Elizabeth I Duff Alistair Smith Research Article published 20 Jan 2005 | doi101289ehp7469

ETD 452

6 Getting a Handle on Biosolids New Model Estimates Microbial Exposure Risk Rebecca Renner News | Science Selections published 01 Jun 2008 | doi101289ehp116-a258a

7 A High-Level Disinfection Standard for Land-Applied Sewage Sludges (Biosolids) David K Gattie David L Lewis Commentary published 17 Nov 2003 | doi101289ehp6207

8 Reproductive Toxicity Birth Weight Raises More Questions on Seafood Safety Adrian Burton News | Forum published 01 Jan 2008 | doi101289ehp116-a20

9 The Role of Syntrophic Associations in Sustaining Anaerobic Mineralization of Chlorinated Organic Compounds Jennifer G Becker Gina Berardesco Bruce E Rittmann David A Stahl Research Article published 08 Dec 2004 | doi101289ehp6933

10 Oseltamivir Carboxylate the Active Metabolite of Oseltamivir Phosphate (Tamiflu) Detected in Sewage Discharge and River Water in Japan Gopal C Ghosh Norihide Nakada Naoyuki Yamashita Hiroaki Tanaka Research Article published 28 Sep 2009 | doi101289ehp0900930

11 The Beat Erin E Dooley News | Forum published 01 Jan 2005 | doi101289ehp113-a25b

13 Ports in a Storm Dinesh C Sharma News | Focus published 01 Apr 2006 | doi101289ehp114-a222

14 Dispersants in the Wake of the Deepwater Horizon Spill with Dana Wetzel Ashley Ahearn Podcast published 01 Aug 2010 | doi101289ehptrp080110

15 By Order of the Court Environmental Cleanup in India Dinesh C Sharma News | Spheres of Influence published 01 Jun 2005 | doi101289ehp113-a394

ETD 452

16 Brominated Flame Retardants Cause for Concern Linda S Birnbaum Daniele F Staskal Review published 17 Oct 2003 | doi101289ehp6559

17 Balancing Act Creating the Right Regulation for Coal Combustion Waste John Manuel News | Spheres of Influence published 01 Nov 2009 | doi101289ehp117-a498

18 Review of the Occurrence of Anti-infectives in Contaminated Wastewaters and Natural and Drinking Waters Pedro A Segura Matthieu Franccedilois Christian Gagnon Seacutebastien Sauveacute Review published 22 Jan 2009 | doi101289ehp11776

19 Infectious Disease The Human Costs of Our Environmental Errors Bob Weinhold News | Focus published 01 Jan 2004 | doi101289ehp112-a32

20 In Katrinarsquos Wake John Manuel News | Focus published 01 Jan 2006 | doi101289ehp114-a32

21 Vulnerability as a Function of Individual and Group Resources in Cumulative Risk Assessment Peter L deFur Gary W Evans Elaine A Cohen Hubal Amy D Kyle Rachel A Morello-Frosch David R Williams Research Article published 24 Jan 2007 | doi101289ehp9332

22 Childhood Lead Exposure After the Phaseout of Leaded Gasoline An Ecological Study of School-Age Children in Kampala Uganda Lauren K Graber Daniel Asher Natasha Anandaraja Richard F Bopp Karen Merrill Mark R Cullen Samuel Luboga Leonardo Trasande Research Article published 01 Mar 2010 | doi101289ehp0901768

23 Health Effects in Fish of Long-Term Exposure to Effluents from Wastewater Treatment Works Katherine E Liney Josephine A Hagger Charles R Tyler Michael H Depledge Tamara S Galloway Susan Jobling Research Article published 21 Oct 2005 | doi101289ehp8058

ETD 452

24 Adverse Effects of Methylmercury Environmental Health Research Implications Philippe Grandjean Hiroshi Satoh Katsuyuki Murata Komyo Eto Review published 01 Aug 2010 | doi101289ehp0901757

25 Between the Devil and the Deep Blue Sea Dispersants in the Gulf of Mexico Charles W Schmidt the scope of the worst oil spill in US history remains a moving target oil rig on 20 April 2010 uncorked an underwater geyser that for 85 of coastline was fouled by the oil and about one-third of the Gulfrsquos fishing grounds News | Focus published 01 Aug 2010 | doi101289ehp118-a338

26 Warfare Iraqrsquos Toxic Shipwrecks Valerie J Brown the engine room will typically contain substances such as fuel oil lubricating oil battery acid hydraulic fluid and asbestosrdquo Silting in Washington DC The UNDP found that oil is the worst News | Forum published 01 Apr 2005 | doi101289ehp113-a230

27 EHPnet International Maritime Organization Erin E Dooley of crude oil off the southern coast of England the organization began focusing and modified in 1978 This treaty governs accidental and operational oil pollution pollution The 1990 International Convention on Oil Pollution Preparedness News | Forum published 01 Apr 2006 | doi101289ehp114-a219

28 Emergency Responder Health What Have We Learned from Past Disasters Bob Weinhold potentially risking their health as they work to clean up the worst oil spill responders who rush to the scene of crises such as oil spills terrorist attacks by October nine years after the disaster Oil spills also are a source News | Spheres of Influence published 01 Aug 2010 | doi101289ehp118-a346

29 Chemical Exposures An Eye to the Sea Graeme Stemp-Morlock activities can have big impacts on the oceans Think of an oil spill like are also released during the combustion of wood coal and oil is just like an

ETD 452

aerosolized oil spill And if a physician knowingly gave News | Forum published 01 Apr 2008 | doi101289ehp116-a156

30 EHPnet CDC Environmental Concerns After Hurricane Katrina NIEHS Natural Disaster Response Erin E Dooley on the Murphy Oil Company spill which released 25110 barrels of mixed crude oil into the area around Meraux and Chalmette Louisiana The site News | Forum published 01 Jan 2006 | doi101289ehp114-a27

31 Louisianarsquos Wetlands A Lesson in Nature Appreciation John Tibbetts including activities by the oil and gas industry Peaking during the 1960s through the 1980s oil and gas companies dredged canals for exploration in coastal Louisiana serving about 50000 oil and gas production facilities News | Spheres of Influence published 01 Jan 2006 | doi101289ehp114-a40

Appendix G ndash Chemical of Environmental Concern

Sediment Benchmarks for Aquatic Life by Chemical

CHEMICAL CAS

Number

Acute Benchmark Chronic Benchmark Citation

Metals (mgkg) Nickel 7440-02-0 516 209 1

Vanadium 7440-62-2 -- 57 2 Mixtures (microgkg)

Total Petroleum Hydrocarbons GRO

-- None None --

Total Petroleum Hydrocarbons DRO

-- None None --

Oil Range Organics ORO -- None None --

CHEMICAL CAS

Number Acute Potency Divisor

(microgkg Organic Carbon) Chronic Potency Divisor (microgkg Organic Carbon) Citation

PAH Mixtures (Oil-Related Organic Compounds) microgL Explanation and example of PAH benchmark calculations (PDF) (6pp 200K)

PAH Mixtures -- see

NOTEhttpwwwepagovbpspillsediment-benchmarkshtml - dblstardblstar

see NOTEhttpwwwepagovbpspillsediment-

benchmarkshtml - dblstardblstar --

Benzene 71-43-2

3360000 660000 3

Cyclohexane 110- 4000000 786000 3

ETD 452

82-7

Ethylbenzene 100-41-4

4930000 970000 3

Isopropylbenzene 98-82-8

5750000 1130000 3

Total xylene 108-38-3

4980000 980000 3

Methylcyclohexane 108-87-2

4960000 976000 3

Toluene 108-88-3

4120000 810000 3

Naphthalene 91-20-3

1600000 385000 4

C1-Naphthalenes -- 1850000 444000 4 C2-Naphthalenes -- 2120000 510000 4 C3-Naphthalenes -- 2420000 581000 4 C4-Naphthalenes -- 2730000 657000 4

Acenaphthylene 208-96-8

1880000 452000 4

Acenaphthene 83-32-9

2040000 491000 4

Fluorene 86-73-7

2240000 538000 4

C1-Fluorenes -- 2540000 611000 4 C2-Fluorenes -- 2850000 686000 4 C3-Fluorenes -- 3200000 769000 4

Phenanthrene 85-01-8

2480000 596000 4

Anthracene 120-12-7

2470000 594000 4

C1-Phenanthrenes -- 2790000 670000 4

C2-Phenanthrenes -- 3100000 746000 4

C3-Phenanthrenes -- 3450000 829000 4

C4-Phenanthrenes -- 3790000 912000 4

Fluoranthene 206-44-0

2940000 707000 4

Pyrene 129-00-0

2900000 697000 4

C1-pyrenefluoranthenes

-- 3200000 770000 4

Benz(a)anthracene 56-55-3

3500000 841000 4

Chrysene 218-01-9

3510000 844000 4

C1-Chrysenes^ -- 3870000 929000 4

C2-Chrysenes^ -- 4200000 1010000 4

ETD 452

C3-Chrysenes^ -- 4620000 1110000 4

C4-Chrysenes^ -- 5030000 1210000 4

Perylene 198-55-0

4020000 967000 4

Benzo(b)fluoranthene 205-99-2

4070000 979000 4

Benzo(k)fluoranthene 207-08-9

4080000 981000 4

Benzo(e)pyrene 192-97-2

4020000 967000 4

Benzo(a)pyrene 50-32-8

4020000 965000 4

Indeno(123-cd)pyrene

193-39-5

4620000 1110000 4

Dibenz(ah) anthracene

53-70-3

4660000 1120000 4

Benzo(ghi)perylene 191-24-2

4540000 1090000 4

+ This includes m- o- and p-xylenes

These include phenanthreneanthracenes

^ These include benzanthracenechrysenes

NOTE Oil Related Organic Compounds are assessed jointly through a mixture approach because they all have the same type of effect on aquatic organisms Potency divisors are not chemical-specific benchmarks but are intermediates used in calculating the aggregate toxicity of the mixture To assess the potential hazard to aquatic organisms the sum of the calculated values is compared to a hazard index of 1 A value greater than 1 (gt1) indicates that the sample has the potential to cause an acute or chronic effect on sediment-dwelling organisms like crabs clams and worms

CITATIONS

1 NOAA National Status and Trends Program Sediment Quality Guidelines (ERLERM)

2 NOAA Screening Quick Reference Tables (PDF) Washington Department of Ecology Publ 95-308 1995 and 97-323a 1997 Gries and Waldrow Puget Sound Dredged Disposal Analysis Report 1996

3 US EPA 2008 Procedures for the Derivation of Equilibrium Partitioning Sediment benchmarks (ESBs) for the Protection of Benthic Organisms (PDF) Compendium of Tier 2 Values for Nonionic Organics US Environmental Protection Agency Office of Research and Development Washington DC EPA600R-02016 PB2008-107282 March 2008

4 US EPA 2003 Procedures for the Derivation of Equilibrium Partitioning Sediment benchmarks (ESBs) for the Protection of Benthic Organisms (PDF) PAH Mixtures EPA-600-R-02-013 Office of Research and Development Washington DC

ETD 452

Appendix H ndash Decontamination Water Treatment System

Source From ERM Mrptdoc p 9

Under normal conditions without rainfall all decontamination water will be treated and recycled at the decontamination area The treatment system will consist of a frac tank constructed with an underflow weir to remove both floating material and settling solids Pretreated water will be stored in a second frac tank Water from the second frac tank will be treated batch-wise through a system consisting of a bag filter and two stage of organo-clay filtration This treatment will remove residual fine solids and residual oil Treated water will pass into a clean water frac tank which will feed the decontamination pressure washer systems

A water treatment flow diagram is shown in Figure 3

The water usage for cleaning is estimated to be 200 gallons per hour or 2400 gallons per day for a 12-hour workday The water treatment system will likely operate once per week to keep the clean water frac-tank supplied

ETD 452

Because the decontamination area will not be covered it will accumulate rainwater Storage capacity will be provided to temporarily store this storm water Accumulated storm water will be removed as need by vacuum truck and taken to a BP approved off-site wastewater treatment system according to BPrsquos waste management procedures defined in Section 16 of BPrsquos ldquoRegional Oil Spill Response Plan ndash Gulf of Mexicordquo Rainwater will be treated through the initial frac tank for removal of floating or settling material prior to storage The rainwater storage capacity will be provided to hold the volume from a 10-year 12-hour storm event which is eight inches of rain

Any free oil tar material and oily debris that accumulate in the oilwater separator will be vacuumed from the top of the separator The vacuumed material will be transported to a BP approved facility according to BPrsquos waste management procedures defined in Section 16 of BPrsquos ldquoRegional Oil Spill Response Plan ndash Gulf of Mexicordquo

Kerr Richard Kintisch and Stokstad Erik (May 2010) Science Magazine Will Deepwater Horizon Set a New Standard for Catastrophe Volume 328 No 5979 pp 674-675 DOI 101126
Types of waste anticipated
Waste disposal