The events of 9/11 and the anthrax incidents at the Capitol Hill complex and the NBC News headquarters exposed not only our internal weaknesses but also our greatness in management, interagency cooperation, and field response.

By Darlene Snow

Clear from recent events is the need to determine proper and safe disposal options for waste produced during any future terrorist incident. For the anthrax attacks on the Capitol Hill complex, for instance, the United States Environmental Protection Agency (EPA) was tasked with decontaminating the facilities and disposing of the resulting waste. According to Alice Jacobsohn, director of the Medical Waste Institute, a policy-making group within the National Solid Wastes Management Association (NSWMA) in Washington, DC, of all the agencies involved in the Capitol Hill cleanup, including the Centers for Disease Control and Prevention (CDC), EPA, and others, none of their authority had ever been focused on such a situation as this with anthrax. As a result, the initial cleanup effort was met with confusion. "CDC and everyone else pretty much said the same thing," Jacobsohn explains. "We had not dealt with this situation before, nor were we prepared to. There was a lot of [going] back and forth among the regulatory agencies, and no one would commit to how the material should be handled and disposed of." In this case, EPA officials ultimately determined that the waste would be handled as a special medical waste for transport and disposal and developed a storage facility for the material while attempting to make disposal arrangements. Ultimately the debris was transported to various medical-waste incinerators, including Fort Detrick in Maryland, which obtained special permission from the State of Maryland to receive offsite waste.

The point is that disposal is often an afterthought. According to Steven Levy, an environmental engineer with EPA's Office of Solid Waste in Crystal City, VA, the order of priorities typically goes like this: Detect the event, provide emergency response (i.e., evacuate the site, secure the area, and recover and treat any victims), remediate the site (i.e., isolate contamination and decontaminate and restore the area), and then address disposal. "Disposal is the last thing on the list. Once the site is decontaminated, the job is essentially considered finished. No one seems to care about disposal or the huge disposal problems that were created. They just want to get rid of it, leaving it to the waste-disposal industry to figure out."

Ed Skernolis, director of government affairs with Waste Management Inc. (WMI) in Washington, DC, remarks that the response to a terrorist incident is not unlike responses to natural disasters, an area where WMI has substantial experience, having provided assistance to the Federal Emergency Management Agency (FEMA) in the past. In that regard, Skernolis says, "A lot of these operations are fairly straightforward." Biological debris, however, is a separate problem. "There are a lot of unknowns. We are used to dealing with medical waste from hospitals in manageable amounts, and there is an infrastructure for this. But there is no real infrastructure in the US that is built to respond to large volumes of biologic waste."

With regard to national response efforts, Martin Powell, counterterrorism program coordinator for EPA's Region 3 in Wheeling, WV, explains that the protocols stem from Superfund. "The emergency-response process originated out of Superfund to respond to oil spills, was modified for chemical releases, and was modified again for biological incidences." For all of these incidences, EPA uses the same authority and essentially the same protocols granted to the agency by Superfund. Says Powell, "The process itself can easily be modified to any incident, whether it is Capitol Hill or the [Columbia] shuttle disaster."

FEMA administers technical and financial assistance in response to a Presidential Disaster Declaration. The National Response System (NRS), in contrast, is executed by the US National Response Team (NRT), which can act without a presidential declaration whenever there is a dangerous release, be the incident accidental or intentional.

NRT is chaired by EPA and comprises representatives from 17 different agencies, each with responsibilities for various aspects of emergency response to pollution incidents. NRT is taking the lead in coordinating the overall response to acts of terrorism from an emergency response, cleanup, and disposal perspective.

In 2003, EPA received $50 million from Congress to research and develop guidance over a three-year period to respond to acts of biological and chemical terrorism. As a result of the grants, the agency created the National Homeland Security Research Center (NHSRC) under its Office of Research and Development (ORD).

According to Paul Lemieux, a chemical engineer with NHSRC in Research Triangle Park, NC, EPA formed NHSRC by reassigning about 25 people from various laboratory-level organizations within EPA and by supplementing it with personnel from the Department of Energy and the Department of Defense.

EPA also is working with the Department of Homeland Security (DHS) in developing a national response plan. The Homeland Security Act of 2002 created DHS to improve our response and readiness to these kinds of attacks. DHS restructured and strengthened the executive branch of the federal government to, according to President Bush, "better meet the threat to our nation posed by terrorism."

In researching this article, a number of agencies were contacted about the progress in preparing for future incidents. Hoping to find a concise game plan, aggressive timelines, and clear channels of communication and leadership - that cut through all notions of bureaucracy - the complexities of this issue were revealed quickly. New agencies cannot be created overnight. "ASAP" to EPA can mean months or even years. Working closely with other offices and agencies does not necessarily mean anyone has figured out whom to talk to yet, but the intent is there.

This was a letdown at first, that even in the face of imminent terrorist attacks and Code Orange warning levels, we still could not rally quickly - not months or years quickly but 30-days quickly - around a crisis. I then realized that things take time for a reason; that, when called upon, we not only rally around a crisis, but we do so with excellence; that, in the overall scheme of things, EPA taking time to develop guidance is better than it not planning at all; and that, if another incident happens in the meantime, we will handle it. We will handle it like we did at NBC and the senatorial office buildings. In a way, that makes all of us proud.

This article therefore is intended to provide some insights into the progress and the issues surrounding homeland security and the disposal of large quantities of debris from a terrorist incident. The national response system is discussed in terms of disposal issues and concerns identified by government and industry officials involved in the process.

The National Response Plan

According to Captain Joe Saboe, vice chair, NRT, and chief with the US Coast Guard's Marine Safety, Security, and Environmental Protection Program's Office of Response, DHS is developing a national response plan that will encompass all types of human and natural disasters. The plan is addressing how to build on the national response systems already in place with NRT and the National Strike Force. "These are all good, well-functioning parts of an organization that we want to save."

At the time of this writing, Saboe indicated that DHS was expected to release an Initial National Response Plan in 2003 that likely would direct agencies to continue doing what they were doing. Ultimately the final plan would provide a blueprint for exercising federal authority in response to an incident, including instructions for state and local coordination. The plan will answer the who but not the what and would not detail the type of decontamination process to use; instead it would focus on the big picture - coordination, lines of communication, and information flow. Saboe says DHS is looking for commonalities in any disaster in developing a national plan to respond to terrorist attacks.

Concurrently ORD is developing a series of technical guidance documents that will address biological agents, chemical warfare agents, and toxic industrial chemicals. Tim Oppelt, director with NHSRC in Cincinnati, OH, explains that ORD's role is to provide support from a scientific basis. ORD is focusing primarily on three areas: the Safe Buildings Program, water security, and rapid risk assessment. The Safe Buildings Program is focused on the restoration of buildings, including detection, environmental measurement, decontamination methods, and disposal of hazardous biological and chemical materials purposefully introduced into buildings. The goal is to develop effective technologies and guidance for emergency responders, building owners and managers, decontamination crews, and waste-disposal personnel. "We see ourselves as the portal for scientific and technical input to response action in the event of a significant national event," says Oppelt.

He explains that EPA reorganized itself and created NHSRC to direct its efforts in this area, stressing that significant progress on communication issues already has been made and that they now are focused on science and technology. He indicates that his office is in the process of simulating events - primarily detection and containment scenarios - that represent the potential to have a negative outcome. "The results of this will be very sensitive and will serve as drivers for the rest of our research and will define the risk and exposure analysis."

Lemieux says EPA is working within the existing regulatory framework, using testing and research to supplement available information and develop guidance. EPA hopes to create a road map to ensure public safety. More specifically the guidance will address issues about capacity and transport, land disposal, thermal destruction, regulatory compliance, worker safety, and risk communication. "There is a lot of commonality with disposal issues. Anthrax is probably the worst-case scenario in many regards, so, if you take it as a generic agent, as a starting point, then you have really done your best with regard to what you can plan for." Lemieux says EPA will look at worst-case scenarios for the agents most likely to be used or most available, based on probability, and plan for these.

Oppelt explains that ORD is working off a list of about 110 threat agents. Chemical and biological agents, which were identified based on their toxicity and availability, are the priority, although ORD has not made this list public. "This list should really be held closely until we have a system to distribute it to the people who need to know about it. The last thing we want to do is add to the cruelties that these guys can inflict."

He indicates that - for the first time in his experience at least - this research has put EPA in a position of holding highly sensitive information. He adds that ORD is leading the discussions with the rest of the agency about information security needs.

Agriterrorism

Beyond anthrax, the medical and solid waste industries are concerned about agriterrorism, which Lemieux says presents a unique problem. With diseased livestock, there essentially are two options: onsite disposal by burial or burning and offsite disposal by burial or burning through rendering facilities or animal crematoriums. The problem is that most landfills do not want to take anything diseased and that combustion is an incredibly slow process. It takes several hours to completely combust an animal carcass, says Lemieux.

According to Levy, the US Department of Agriculture is developing guidance in this area to address how to prevent, respond to, and handle such an incident. Along these lines, Jacobsohn explains that NSWMA representatives met with EPA to discuss disposal issues around possible incidents involving diseased carcasses, from chronic wasting disease to Newcastle disease to foot-and-mouth disease. Jacobsohn says of the EPA meeting, "What came up is that there is not a lot known about some of these diseases and that they could result in wastestreams that are much greater in size and quantity than the facilities have taken in the past or are designed for." She mentions industry concerns about downstream liability: "What if more is found out about new castle or anthrax or other threat agents? There is no protection from future liability for things that we don't know much about, particularly when substances are in criminal grade. Now we are in a whole different scenario."

The Issues

Lemieux acknowledges that some real issues with the disposal process need to be resolved and that not everything is based on fear and perception. "With proper pretreatment and effective waste triage, however, debris might be able to be classified as a solid waste or a construction-and-demolition waste and not a Research Conservation and Recovery Act (RCRA) hazardous waste or a special medical waste, significantly reducing the regulatory burden of disposal." But sampling measures for determining if such porous materials as cushions and carpeting are clean, for instance, are not well defined. Furthermore, with anthrax, such waste-handling procedures as shredding or size reduction pose additional exposure risks that need to be addressed, such as the potential for resuspension of anthrax spores.

Some of the issues that have been identified by industry and government leaders are certification and testing for decontamination, waste-disposal capacity and availability, waste-handling protocols and exposure risks, present and future liability, worker safety, and community relations.

Testing

According to Levy, NRT's guidance for anthrax disposal is this: If you can document that you have decontaminated the material, you can haul it to a Subtitle D landfill or, if it is not MSW, even a construction-and-demolition debris landfill. The reality, however, is not that simple. "Practically speaking, to make the determination that the material is decontaminated, you have to do testing, a lot of testing. What got stressed in the anthrax cases was the lab capacity. Testing everything to the point of being able to certify decontamination is limited by lab capacity, making testing itself the bigger issue." Moreover, testing at $300 to $400 per sample might be too costly. The Catch-22 is that some facility operators might not be willing to accept waste that is not certified as decontaminated, regardless of whether they operate MSW, hazardous-waste, or medical-waste disposal facilities.

Lemieux agrees that concerns about certifying materials as decontaminated are on the forefront. Certification itself presents a series of issues and unanswered questions. Are decontamination and sampling procedures adequate for these quantities, materials, and circumstances? Can small quantities of anthrax hide and go undetected in sampling? Can we certify decontamination without adequate lab testing capacity? If debris is not sampled and tested, then what? How clean is clean? How many of these concerns are real? How many are based on fear?

According to John Skinner, Ph.D., executive director and chief executive officer of SWANA in Silver Spring, MD, EPA should look at different scenarios and conduct lysimeter tests to simulate decomposition in landfills. He suggests that waste from an incident be stored until more is known and EPA figures out what to do with it. Mostly SWANA has asserted its concerns over two issues: knowing what the disposal options are in advance if there is an incident and exposure of facilities, workers, and even facility neighbors to anthrax or another agent.

Oppelt asserts that EPA is studying ways to create systematic decontamination, "which should help the waste industry in terms of providing a level of comfort in the decontamination process. The fortunate thing is that, in most cases, we are not going to be hauling materials without some significant decontamination already having taken place. We are not rolling up the carpet and hauling it away to a facility. Before transport, already the levels of contamination in these materials should be reduced significantly enough to be considered safe for removal from these buildings." He says we need to educate people, particularly waste haulers, about the potential hazards of the levels that remain after decontamination. "After decontamination has taken place, many of these [agents] are more familiar to people at the lower levels, similar to materials found in the natural environment that they already work with."

Oppelt explains that CDC has a network of labs for clinical testing of materials received primarily from researchers. These labs are not set up for the quantity of samples that would come from a terrorist incident. The existing CDC network, however, still could be used for clinical samples, from people wanting to know if they were exposed, for instance. On the positive side, he points out that there are tests kits people can use to screen for the presence of anthrax. In the meantime, CDC and other health organizations are working with states to increase lab capacity.

Capacity

How do you get rid of what you have left? According to Levy, EPA recognizes that the MSW industry really has the largest capacity to handle the disposal of decontaminated and potentially contaminated debris, in terms of the number of facilities, the management, and the transportation infrastructure. "We recognize that we need to involve the MSW industry in this process."

Levy points out that there are less than 24 commercial-hazardous-waste Subtitle C landfills with the capacity to take about 5 million tpy. In contrast, there are about 1,800 MSW Subtitle D landfills with the capacity to take more than 500 million tpy. "The practical fact is that the MSW industry has more facilities, more capacity, and more trucks to handle the huge quantities of debris that could come out of something like this."

Skernolis cautions against assuming that MSW or hazardous-waste landfills are the answer. "Hazardous-waste landfills are no more likely to accept it than an MSW landfill is, depending on the nature of the contamination and the decontamination procedures. It's not an automatic that any of this capacity is available on a voluntary basis. We have an obligation to protect our employees."

In addition to landfills, MSW combustors are also an option, notes Levy, since they have a larger capacity than crematories or medical-waste incinerators. A number of technical issues, however, need to be worked out and addressed first, such as how waste will be fed into a charging hopper without spreading contamination. Other issues include training and equipping workers to handle contaminated material, compliance with permits, sizing of material, residue management, selection of appropriate facilities, and minimization of failure modes. ORD is conducting both thermal destruction experiments and land disposal experiments to better understand these issues.

On the practical side, Powell names two universal truths when it comes to emergency response: First, all sites generate waste. And second, disposal options are limited. Only so many facilities can take it. That is why he advocates working the process backward, starting with contacting local and state governments and the waste industry to resolve disposal issues up-front.

With anthrax, for instance, medical-waste facilities are very comfortable handling needles and other red-bag waste, says Powell, since they deal with it every day, but they are not comfortable with anthrax. "You cannot assume that they will take it."

Powell explains that the best way to work a site is to figure out your disposal options and then process the site accordingly so you are not left with a truckload of material and nowhere to take it because it does not meet the requirements of the available disposal options. When you work a site backward, the disposal option is secured first, and then the site is processed according to the disposal-facility requirements. "Classification of the waste comes out early on."

Jacobsohn would like to see the creation of a secure national database - a kind of readiness database for disposal - that identifies the locations of disposal facilities willing to accept the waste and what they are capable of accepting. "It's important to know what facilities exist and which can take what kinds of waste," Jacobsohn points out, noting that not all are equipped to handle anthrax.

Waste-Handling

Skernolis explains that there are three potential wastestreams to consider: basic debris (e.g., lumber, bricks, and the like, which are similar to residential waste), toxic chemicals resulting from industrial sabotage or a chemical accident, and biological waste resulting from a biological incident from anthrax or another agent.

"As a company, we have experience in managing debris. Our experience with natural disasters has been a good training ground for this," says Skernolis. "With industrial waste, we have experience because we've managed hazardous waste in this country for a long time. The infrastructure to deal with this is in place." Large volumes of biologic waste is another matter, he says, although WMI did handle waste disposal from the anthrax cleanup at the NBC Headquarters building in New York City. About 340 yd.³ of decontaminated material from this site went to the company's hazardous-waste landfill in Model City, NY.

According to Jacobsohn, policies and infrastructure for handling biological agents thus far have been geared toward much smaller quantities of material. Medical-waste incinerators are not designed for the type and quantity of debris that could result from a terrorist incident. Waste from the senatorial office buildings, for instance, was comprised of porous building materials and furnishings (e.g., acoustic tiles from ceilings, carpeting, wall fabric, office partitions, seat cushions, and curtains), office equipment (e.g., computers, desks, and file cabinets), residue from cleanup activities (e.g., personnel protection equipment, decontamination agents, and contaminated HEPA filters), and aqueous residues (e.g., personnel- and equipment-decontamination rinsate and fumigant-scrubber water).

Jacobsohn notes that medical-waste facilities handle diseases worse than anthrax every day. "The facilities and workers are trained to handle medical waste. Solid-waste incinerators, in contrast, are not. To send anthrax debris to incinerators, you have to look at the handling issues."

She cautions, however, that medical-waste facilities are not accustomed to furniture and other incident-related debris. Moreover, making a determination of waste type for disposal is another issue. Protective gloves, for instance, might have been contaminated with the combination of a cleaning chemical and anthrax. "If it's anthrax, since that's a disease, it gives the appearance of medical waste. If it's the chemical, it leads to hazardous waste. It is really both hazardous and medical, a combination not dealt with in federal regulations." She explains that the RCRA mixture rule, which says that mixing a solid waste with a hazardous waste deems the entire load hazardous, does not apply to the combination of medical and hazardous waste. For example, if anthrax is mixed with an RCRA-listed hazardous chemical but the load is not considered decontaminated, you still have both hazardous and medical waste. "We call this a Œmultihazardous waste,' and one does not supersede the other in existing regulations, making disposal options more complicated." For the material to be deemed solid waste, Jacobsohn says, you would have to declare that the waste had been decontaminated. "CDC says that anthrax is a threat between one and 10,000 spores, but no one can say what the number is, and declaring it a hazardous waste doesn't change the fact that it is also a medical waste." Levy adds, "Unless we have confirming information that it is not hazardous, we have to treat it as a hazardous waste."

Oppelt acknowledges that more information is needed about weaponized versions of these agents in terms of handling and disposal. "The waste industry has legitimate concerns over the handling of these materials." Is there the potential for resuspension of anthrax spores, for instance, during waste-handling, shredding, or size reduction, which might result in dispersion? "We are looking at these issues and will get information out as we are comfortable with it." He says this will not take the three years that ORD has been given to develop its reports. Instead the agency intends to make information available as soon as possible to the people who need it.

Lemieux explains that the guidance provided by ORD will assure the public that the selected disposal process will be safe and guide permitters to accelerate disposal options (e.g., mods, variances, and waivers). ORD will give facility operators guidance to ensure permit compliance and protection of workers and business assets. Lastly the guidance will help emergency responders incorporate disposal plans into the entire decision-making process.

With biological agents, Levy adds that it ultimately is up to the various state agencies to determine how disposal of biological waste should be handled under a state's medical-waste regulations, since EPA's only authority with regard to medical waste is derived from the Clean Air Act and the Federal Insecticide, Fungicide, and Rodenticide Act. "It's the states that have to approve how it will be managed."

Liability Concerns

According to Levy, facility operators are concerned about liability and about taking waste that the facility is not specifically or originally permitted to take, even if a state agency says it is OK. Furthermore, liability issues are compounded when third parties are involved. Facility operators are equally concerned about alarming their local communities and jeopardizing their permits. "There could be a public outcry over the facility taking the waste, regardless of whether it's deemed MSW or not."

Ed Repa, director of environmental programs for NSWMA, points out that, from a strictly regulatory standpoint, RCRA is clear. "If you read Subtitle D, it still trumps any state regulation. Even if a state says you can take it, you can't if it's a hazardous waste. So it really doesn't matter what the states say. They can't override Subtitle D. A facility operator would be taking a big chance accepting something that has not been tested. The biggest problem our members have with disposal of contaminated debris is that they want you to take it now, but no one will say they won't come back later and classify you as a Superfund site."

Jacobsohn also expresses concerns about future liability. "What happens five years from now when more is known about these substances, when more information comes out? Will the landfill be condemned?"

"Whom do we turn to if our facilities become contaminated?" asks Skernolis, who believes that more research is needed on decontamination and handling of biologically contaminated material. "The industry has largely resolved these issues with toxic-chemical contamination, but we don't yet have the knowledge base for the management of large volumes of the more dangerous biologic contaminants."

Worker Safety

After the anthrax incidents, Skinner explains that SWANA received many telephone calls from waste handlers concerned about protecting their employees. In response, SWANA set out to educate the industry about how to handle collection from locations where anthrax has and has not been found. In its guidance, SWANA covers safety tips and precautions for solid-waste workers handling potentially contaminated waste. Foremost, the guidance stresses the importance of educating building employees about not throwing suspicious packages in the trash. Moreover, waste handlers should suspend collection from any building under investigation.

Skernolis says that WMI, principally in response to the anthrax incidents, developed a formal company response plan under a joint effort between the company's security and safety departments. The company also began looking at the broader issue of terrorism in case of another incident. "The waste industry was directly connected to the anthrax incidents of 2001 and 2002 because mail from the affected post offices could find its way into post-office recycling programs and into ordinary household trash. We have to be concerned about our workers, the communities in which we operate, and our assets being exposed on the fate and transport side of any incident. In addition, we were getting feedback from our purchasers of recycled paper that they had similar concerns in accepting potentially contaminated material."

Skernolis adds that WMI was also getting hoax mail, including envelopes marked "This envelope contains anthrax," and the company consequently put security measures in place that specified what to do if someone suspected anthrax at a WMI facility.

Skinner goes so far as to advocate isolation and storage of debris until concerns about worker and asset protection are answered. He says these measures are necessary to prevent further human exposure, explaining that SWANA is concerned about the potential exposure of landfill workers; the potential releases of chemical or biological agents in landfill gas, leachate, and groundwater; and the adverse impacts to the landfill infrastructure itself, including the liner, cap, leachate, groundwater systems, gas collection systems, and equipment. Because of this, Skinner stresses, the EPA guidance must address ambient monitoring, worker safety, and other potential risks before the industry will be comfortable accepting this type of material.

Community Relations

Lemieux remarks that even if the material is certified as decontaminated, it still will have a stigma attached. There is a very real concern from the waste industry about jeopardizing business assets, worker safety, and community relations. "A lot of the waste-disposal process is dealing with fear and doubt." This makes perception an important issue. Even if the decontamination process renders the material harmless, are people willing to accept it?

Levy explains that EPA ran into this with the washwater from decontaminating protective gear from the Hart Senate Office Building. The local wastewater treatment plant was concerned about contamination - or at least the perception of contamination - of its sludge byproducts. Because of this, EPA had to sterilize the wastewater prior to disposal.

Powell says fear was such an issue at the Capitol Hill cleanup that he felt like a leper. "No one wanted to hold my hand when I was down there." Jacobsohn adds, "On one hand, you think of yourself as a hero for keeping the community safe, but on the other, there could be a big outcry from the community if you accept the material."

Repa concurs, remarking that there is concern about the perception of taking contaminated debris and how the local community and the facility's neighbors would feel about anthrax coming in. "No one really wants to take the stuff."

Planning for an Incident

Levy points out that it is difficult to plan for a terrorist incident. "We don't know what the agent of concern will be and what scenario a terrorist will use to disperse the agent." Plus, there is the concern that providing information about possible scenarios will reveal weaknesses in our security or response systems or will show avenues for potential devastation to terrorists.

A number of disposal scenarios, however, must be considered. One option is to prepare each and every waste-disposal facility - from small medical-waste incinerators to MSW landfills to hazardous-waste landfills - for the possibility of receiving debris from a chemical, agricultural, or biological terrorist incident. This would require facility operators to plan ahead and consider how they would train and protect their employees in the event that they are asked to accept debris and to consider any physical modifications that might need to happen to their facilities. Levy points out, however, that advance planning is costly and even uncharacteristic in a country that typically reacts to rather than plans for a situation.

Another option is to identify regional facilities that would be best suited for this and work in advance to prepare them for an incident in terms of physical modifications, training, special protective equipment, and waste-handling procedures.

Similarly EPA could engage a few facilities specifically for the sole purpose of accepting questionable debris from acts of terrorism. These facilities would be in a perpetual state of readiness. The risk here is of a terrorist act against these facilities, which could leave the country vulnerable and unprepared for disposal once again.

Jacobsohn points out that we are in a better position now if an attack were to happen again because of the work that has been done since the Capitol Hill and NBC incidents. "We know how the agencies work and have more knowledge of how to work together." She says a fair amount of educating already has been done. "We learned a lot from the first round. There was a lot of information that we didn't know was out there. Now it's being pulled together.

"In the short term, you do what you have to do to get by." But for the future, Jacobsohn asks, "How much do you spend to prepare for something that may never happen?"

What the Future Holds

The events since 9/11 have shown how awesome we can be in our response, but they also have shown our weaknesses.

Lemieux remarks that we did a great job with the senatorial office buildings and NBC but that the emergency crews had enough to worry about without having to wing it. He is hopeful that ORD's guidance documents will provide a checklist for marching through these situations and reducing the confusion and stress of the situation. He adds, "Our main goal is to make disposal part of the process, to look at disposal up-front so the people who are making decisions on the spot can factor disposal of building residue into the process."

As part of this process, ORD is involving state agencies and waste-industry representatives in discussions aimed at laying out main issues and concerns. The waste management industry is an important partner in the process of producing useful guidance documents."

Levy adds, "With most of the resources going to ORD for its research efforts, OSW's focus is on keeping disposal on the agenda." This essentially gives MSW managers an official heads-up to start thinking about this issue so they can prepare locally. "The MSW industry is uniquely situated to respond to this type of crisis. We need to build into the existing system what needs to be done."

As Skernolis points out, "The bottom line is that we need more research before the waste industry can feel comfortable accepting this material while protecting our employees and the communities in which we operate." But he also agrees with Jacobsohn in saying, "Ours is a very patriotic industry." Although no one might want to take these materials, the waste industry rose to the occasion before, and it will do it again. Only now it is up to the industry to plan for it and understand the consequences.

Darlene Snow, an independent environmental consultant specializing in solid waste management, resides in the Washington, DC area.

MSW - Elements 2005