UNITED STATES ENVIRONMENTAL PROTECTION
WASHINGTON, D.C. 20460
DATE: March 15, 1979
SUBJECT: Meeting of September 22, 1978
FROM: William Sanjour (WH-563)
Resource Recovery Division
During the period September 20 to 22, 1978, I and members of my staff (Assessment and Technology Branch) had several meetings with Mr. Gary Dietrich to discuss the draft 3004 standards under my development.
On September 20, we discussed sewage sludge and land-spreading standards. This meeting has been described in my memo of September 21, 1978 entitled "Standards for Landspreading of Hazardous Waste". At that meeting I argued unsuccessfully against Mr. Dietrich's decision to weaken our regulations so as to allow cadmium from industrial wastes into the human diet. (Cadmium is a cumulative poison which also causes cancer).
On September 22, we discussed "special wastes". This is a category of hazardous waste which the technical staff had found necessary to invent. We had found that for some wastes (such as mining waste) if required to follow our draft regulations would probably bankrupt the entire industry. Therefore, we proposed not regulating them while we gathered additional facts on how they could be regulated, and if they could not be regulated without ruination, to report this to Congress.
The technical staff had listed several wastes which had proved troublesome in this regard. However, to this list, our management (Mr. Jorling and Mr. Dietrich) had added several others of their own without giving any reason or consulting with me or my staff. This included oil and gas drilling mud from the oil and gas drilling industry and flue gas desulfurization (FGD) sludge from the electric power industry.
At this meeting on September 22, I told Mr. Dietrich that we were dropping oil and gas drilling mud from the category of "special waste" so that the oil and gas industry would have to comply with all the standards for disposing of hazardous waste with those muds. Mr. Dietrich asked if that meant that all those well drillers in West Texas would have to line their drilling ponds with clay. John Schaum, Tim Fields and I explained that this would present no great hardship since drilling muds are usually 95% bentonite clay to begin with. Furthermore we had visited several of these operations and concluded that can readily comply with our standards and should not be treated as a "special waste".
We also told Mr. Dietrich we were dropping FGD sludge as a "special waste". This sludge is generated by power plants equipped with FGD scrubbers required by EPA's air program to remove sulfur from power plant emissions. I and Howard Beard told Mr. Dietrich that EPA has been telling the public for years that the cost of adequate disposal of the sludge is not unduly expensive; that this cost has been taken into account in determining the need for FGD scrubbers; and that EPA has studied and has knowledge of the technology for adequate disposal. With this background we didn't see how our regulations could come out and say we don't know what to do with this.
Six days later I was removed without notice from my position as Chief of the Assessment and Technology Branch. Shortly after that, Mr. Dietrich instructed the Branch to reinstate oil and gas drilling mud and FGD sludge as "special wastes".
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