Hazardous Waste Management: Reducing the Risk. Benjamin A. Goldman, James A. Hulme, and Cameron Johnson. Council on Economic Priorities, 30 Irving Place, New York, N.Y. 10003. 1986.316 pages. $64.96, cloth; $34.95, paper. Reviewed by Joan B. Berkowitz, President and Chief Executive Q c e r , Risk Science International, Washington, D. C.20007. The study upon which Hazardous Waste Management: Reducing the Risk is based was intended to provide generators with help in selecting hazardouswaste-management contractors. If the authors had not deviated from this purpose, the book would be an important contributionto the literature and a great
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help to hazardous-waste generators and facility managers. Generators of hazardous waste can be held strictly liable for any damage resulting from the management and disposal of their wastes. And when generators transfer wastes to facilities with Resource Conservation and Recovery Act (RCRA) permits, they retain liability. Prudent generators conduct independent evaluations of liability posed by waste transfers to commercial facilities. This book provides insufficient guidance for such assessments. The centerpiece of the book is a set of report cards for 10 commercial treatment, storage, and disposal facilities. The letter grades assigned to the facilities were widely reported at the time the book was published. This is unfortunate for two reasons: The grades are meaningless, and they do a disservice to the managers of the facilities and to the generators who need to assess the suitability of a facility for disposal of their own wastes. The 10 facility profiles published do provide useful background information, well worth reading before a site inspection, but the letter grades should be ignored. The information is presented under several categories, all of which are relevant to a potential user of the facility: site (demography, water use, hydrology and geology, surface water, areas of special concern); management (observed releases, groundwater monitoring, enforcement actions, corrective actions, staff and unionization, safety and health, financial responsibility); technology (processes and capacities, special wastes handled or excluded); and history (prior use and ownership, construction and permits, future processes and site uses, citizens’ concerns and organizations). These profiles would have been enhanced by the inclusion of maps of each facility and its surrounding area, although the maps likely would have added considerably to the very reasonable price of the book. The information in the facility profiles is not available in other public documents. For this reason alone the book deserves a place on every envi-
ronmental manager’s shelf. Unfortunately, only 10 facilities are described; more than 300 RCRA-permitted facilities are listed in the 1985 edition of the Hazardous Waste Services Directory published by J. J. Keller. Instead of presenting a profile of a larger number of available facilities and focusing on the difficult decisions generators face in selecting commercial vendors, the authors allow their attention to be diverted to pursuing what they call a nationwide toxic shell game. The result is a study that neither fulfills the book’s original intent nor serves any other clear purpose. The book is divided into three main sections: “Council on Economic Priority Findings,” “Problems and Solutions,” and “Case Studies.” The findings section includes a potpourri of superficial advice for anyone even remotely associated with hazardous wastes, but it contains little of significance for generators. The next section sets the stage for massive confusion between RCRA and Superfund (between closely regulated management of hazardous wastes generated as part of continuing production and problems stemming from the unregulated management of hazardous wastes from the past). This confusion culminates in the authors’ use of the hazard ranking system to evaluate RCRA facilities. The system was developed by EPA for the purpose of establishing the Superfund National Priority List, and it has no relevance to RCRA facilities. The final section contains raw data that are useful to generators. It includes information about the major commercial hazardous-waste-management companies and 10 facilities. Here, too, the companies are assigned letter grades, thus degrading the quality of the financial, regulatory, and technical data presented. The book is generally difficult to read because of its subjective and ponderous presentation of company and facility grading systems. The best that can be said for the grades is that they are consistent. Nevertheless, readers who can ignore the ratings and who can distinguish documented fact from opinion will find the book to be a valuable reference.
