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3 Tonnage and Toxicity: The Nonissue of Nonhazardous Industrial Waste I have spent my adult life studying and working in one way or another with garbage. As a result, I have spent a great deal of time looking at data on waste quantities and composition—how much municipal solid waste is produced in a city, state, or country; what materials make up different waste flows; how much is disposed and how much goes to recycling, composting, or another alternative. The U.S. EPA publishes biennial data on this subject for the United States as a whole, detailing the composition of municipal solid waste by material as well as by product type. States, counties, and cities all over the country also compile and report data on municipal solid waste generation and composition, as do several trade publications (see, e.g., Waste News 2007; BioCycle 2008). Combined, these sources paint a detailed picture of what is in U.S. municipal solid waste and how much there is of it over time. The EPA data, which as of 2008 reported the total annual U.S. municipal solid waste generation at about 250 million tons annually (U.S. EPA 2009b), is the basis for what has become a frequently cited statistic, often quoted to shock and shame: “The average American throws out 4.3 pounds of garbage . . . per day—1.6 more pounds than 30 years ago” (Royte 2005, 11). Like many Americans, I had come to consider the hundreds of millions of tons of municipal solid waste produced annually as an indicator of the “throwaway society.” Then, ten years into my study of solid waste, I stumbled on a waste statistic quietly put out by the EPA in a document called Guide for Industrial Waste Management (U.S. EPA 1999). This technical manual, meant to provide tips to factory managers for handling waste at their plants, noted, without further comment, that manufacturing industries were generating some 7.6 billion tons a year of solid waste. Some digging on my part uncovered an older, unpublished report that was the source of this estimate as well as two follow-up government 88 Chapter 3 documents that cited other industrial, mining, extractive, and agricultural operations as bringing the total industrial waste tonnage generated in the United States up to around 12 billion tons (U.S. EPA 1987, 1988; OTA 1992). These amounts were an order of magnitude greater than the tonnage of municipal solid waste that every book, volunteer effort, government program, or household conversation about trash and its problems seemed to focus on. Yet very little had been published about this far larger quantity. Where and what is the shadowy, massive fraction of solid waste that environmental business consultant and journalist Joel Makower has called the “gross national trash” (2009)? It certainly is not garbage as we know it. Instead, this massive stream represents solid waste disposed of as unintended consequences of industrial processes: it consists of the discards of the factory itself, excluding recycled or reused materials (for which there are simply no comprehensive national data). As I discuss in this chapter, we know very little about what materials are in it or where it is being disposed. And despite the EPA’s classification of manufacturing wastes as “nonhazardous,” there are reasons to be concerned about its toxicity. As the Congressional Research Service observed in 1994, In general, [nonhazardous] industrial waste presents a number of causes for concern. There is a large number of facilities, nearly 28,000 industrial land disposal units . . . which the EPA estimates have 125,000 surface impoundments (ponds) in which liquid wastes are disposed. Many of these facilities handle wastes with the same characteristics as hazardous waste. There is also a growing recognition that non-hazardous waste can contaminate groundwater. . . . Many states do not require permits for on-site disposal of industrial waste. . . . Few facilities have adequate safeguards to protect groundwater. (McCarthy 1994, CRS-11) Nonhazardous industrial wastes in this context do not include wastes that the EPA has explicitly deemed hazardous. Nor do they include coal ash, the subject of much current focus due to a massive structural failure in a Tennessee holding pond in December 2008 that spilled 5.4 million cubic yards of sludge over 300 acres of land, damaging homes and threatening groundwater quality (Hall 2008). The residue from coal-fired electrical plants, coal ash is classified among other wastes called “special” in that they fall outside the EPA’s relatively robust regulatory structure...

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