A Wasteful Use of Time: EPA Regulations of Hazardous Waste in the 1980’s

Today’s post was written by Brian Schamber, student at Central Michigan University and summer intern in Textual Processing at the National Archives at College Park, MD.

Since the implementation of the Resource Conservation and Recovery Act (RCRA) in 1976, municipalities, corporations and landfills across the United States have had to deal with hazardous waste in a very thorough and heavily documented manner. Under Subtitle D of RCRA: Non-Hazardous wastes are what we would think of as everyday waste such as food, scrap metal, and sewage waste. In comparison, some examples of hazardous waste would be the products of industrial processes, such as sewage treatment sludge or sludge created from a distillation process.

I am working with records Regulations, Standards, and Guidelines Relating to Delisting Hazardous Substances* (NAID 7543044) in RG 412, Records of The Environmental Protection Agency (EPA) pertaining to delisting “hazardous” waste so that it can be disposed of as a non-hazardous waste in landfills. One particular case stuck out to me concerning the manner of disposal that one company used for their “non-hazardous” waste.

The subject of the delisting petition is Storeys Transprints Inc. of Harrisonburg, Virginia. Storeys was under investigation for illegal waste disposal from 1982 until 1986. In correspondence the operational manager at Storeys expressed that the Colonial Heights facility held on to its waste in cardboard boxes until their delisting petition. If the petition was successful they would dispose of the waste at a nearby landfill.

In 1987 Storeys’ Transprints Inc. submitted a petition to the EPA to delist two types of waste: Methyl Ethyl Ketone (MEK or Butanone) and Methyl Isobutyl Ketone (MIBK) used as solvents in the production of their inks. Butanone and MIBK are industrial solvents that are moderately explosive, a spark or small flame could cause the solvent to ignite. Production occurred at Storeys Colonial Heights facility, which the EPA addressed in delisting petition 0691 B.

However, Storeys petition would later be dismissed in 1988 for failing to adequately respond to the EPA’s requests for follow up information. The EPA also denied their petition as the sampling analyses yielded reports of unsafe levels of barium and lead, at 6.6 parts per million (ppm) compared to the EPA’s standard of 0.05 ppm. The results of exposure to either of these substances are extremely toxic. Lead poisoning can lead to abdominal pain neurological changes, and in high enough doses even death. Barium exposure can cause gastrointestinal pain and nausea, in addition to a reduction in blood potassium levels known as hypokalemia.

In regards to the two chemicals that Storeys originally wanted delisted, samples of MIBK from the Colonial Heights site exceeded 120,000 ppm. High quantities of this extremely flammable chemical posed a high risk to both the facility and the environment; making this waste truly hazardous.

*The folders pertaining to the Storeys case in this series have been screened for FOIA b(4), and are able to be released to the public.