ALTERNATIVES TO THE  MANAGEMENT

OF HAZARDOUS WASTES AT

NATIONAL DISPOSAL SITES


APPENDICES


report to


THE ENVIRONMENTAL PROTECTION AGENCY

 under

 Contract No. 68-01-0556


 by

 Arthur D. Little, Inc.
 Cambridge, Massachusetts

 C-74861

 May 1973
                              Arthur D Little Inc.

-------
   ALTERNATIVES TO THE MANAGEMENT
        OF HAZARDOUS WASTES AT
         NATIONAL DISPOSAL SITES

                 APPENDICES

                   report to


THE ENVIRONMENTAL PROTECTION AGENCY
                    under

            Contract No. 68-01-0556


                      by

              Arthur D. Little, Inc.
            Cambridge, Massachusetts

                   C-74861

                   May 1973
          This report was prepared for the U.S. Environ"
          mental Protection Age icy and is iss'-ed as sub*
          mitted ty the Cent, actor. Iss  ance does not
           signify that the contents ne^esranly reflect
          the views and policies of the U.S. Environment^
          al Protection Agency, nor does mention of com-
           mercial products constitute endorsement of
          Recommendation for. use £>y the U. S. Gov't,

-------
                      TABLE OF CONTENTS

                                                            Page

List of Tables

List of Figures

APPENDIX A  - LIST OF WASTES                                    1

APPENDIX B.1 -  DESCRIPTION OF WASTE TYPES                     15

    BACKGROUND                                              17
    ORGANIC WASTES SUITABLE FOR INCINERATION                   18
    WASTES CONTAINING HEAVY METALS AND/OR CYANIDES            32

APPENDIX B.2 -  IDENTIFICATION OF SPECIFIC SOURCES               53

APPENDIX C  - PROCESS ECONOMICS                               67

    BACKGROUND                                              69
    CONCENTRATED HEAVY METALS                               70
    DILUTE HEAVY METALS                                      73
    HEAVY METALS WITH ORGANICS                               81
    DISPOSAL OF HEAVY METAL SLUDGES                           86
    CONCENTRATED CYANIDE WASTES                             88
    DILUTE CYANIDE WASTES                                     92
    CHLORINATED HYDROCARBON WASTES                          94
    ORGANIC WASTE REQUIRING A KILN                            96
    DISINTEGRATION AND INCINERATION OF INSECTICIDE DRUMS
     AND PAILS                                               98

APPENDIX D- RISK ANALYSIS                                  101

    GENERAL METHODOLOGY                                    103
    RISK TO HUMAN LIFE                                        104
    CALCULATION OF WATER POLLUTION RISK                      110
    ACCEPTABLE POLLUTION RISK                                113
    REFERENCES TO APPENDIX D                                 M4
                               iu

-------
                   TABLE OF CONTENTS (Continued)

                                                                 Page

APPENDIX E -  ANALYSIS OF FEDERAL AND STATE LAWS                 115

    FEDERAL LEGISLATION AND STATUTES                            117
    NEW JERSEY LAWS AND REGULATIONS RELATING TO HAZARDOUS
      WASTES                                                     148
    PENNSYLVANIA LAWS AND REGULATIONS RELATING TO
      HAZARDOUS WASTES                                          172
       Background                                                 172
       Existing Laws                                                173
       Administrative Implementation and Political Realities                   176
       Probable Legislative Needs for Hazardous Waste Disposal Alternatives        178

APPENDIX F -  DEVELOPMENT OF ECONOMIC DECISION MAPS             191

    INTRODUCTION                                                193
    DETERMINING THE LOWER COST STRATEGY                         195
    DETERMINING THE BEST STRATEGY FROM SOURCE SIZE               206
    IMPACT OF "NONHAZARDOUS" WASTES ON ECONOMICS OF
      TREATING HAZARDOUS WASTES                                207
    EFFECT OF SOURCE SIZE DIFFERENCES ON RESULTS OF USING THE.
      DECISION MAPS                                              216
    UTILIZATION OF THE DECISION MAPS ON SELECTED WASTES           220
    EFFECT OF ASSUMPTIONS ON DECISION MAP UTILITY                 231
                                  IV
                                                              Arthur D Little, Inc.

-------
                               LIST OF TABLES

Table IMo.                                                                     Page

  A.1         Hazardous Wastes Selected by TRW for National Disposal Sites           3
  A.2        Categorization of Wastes for Detailed Study                            8
  B.1.1       Chloro-Organic Compounds                                        19
  B.1.2       Estimated End Use                                                23
  B.1.2A     Production of Pesticides                                            25
  B.1.3       Pigments Consumed by the Coatings Industry — 1970                  27
  B.1.4       Pigments Containing Toxic  Ingredients                               28
  B.1.5       Estimated U.S. Paint Sludge Production by Company Size              30
  B.1.6       Number of Establishments by Geographic Area — Plating and
                Polishing. SIC Code 3471                                        33
  B.1.7       Rinse Water Volumes in Contract Plating Shops from Literature
                and ADL Surveys                                                37
  B.1.8       Volumes of Chromium and Cyanide-Bearing Wastes from Typical
                Plating Operations in the Electroplating Industry                    39
  B.1.9       Geographical Distribution of U.S. Tanneries                           40
  B.1.10      Tannery Wastes                                                    43
  B.1.11      Waste Water Discharge  From the A.C. Lawrence Chrome
                Upper Side Leather Tannery in South Paris, Maine                  4.4
  B.2.A       Concentrated  Heavy Metals                                         56
  B.2.B       Dilute Heavy Metals                                                57
  B.2.C       Dilute Heavy Metals with Organics                                   59
  B.2.D       Heavy Metal Sludges                                               60
  B.2.E       Concentrated  Cyanides                                             61
  B.2.F       Dilute Cyanides with Heavy Metals                                   62
  B.2.G       Liquid Wastes with Chlorinated  Hydrocarbons                        63
  B.2.H       Organic Wastes Requiring a Rotary Kiln                              65
  C.1         Treatment Cost of Concentrated Chrome Wastewater                  71
  C.2         Recovery of Chromium from Dilute Wastewater by ION Exchange      73
  C.3         Treatment Cost of Dilute Chrome Wastewater                         76
  C.4         Economic Comparisons Portable Vs Stationary ION  Exchange          77
  C.5         Cost of Sulfide Precipitation of Heavy Metals from Wastewater          80
  C.6         Cost of Incineration of Dilute Hydrocarbon                           81
  C.7         Cost of Dilute Hydrocarbon Treatment by Activated Carbon            82
  C.8         Cost of Incineration of Dilute Hydrocarbon Containing Halogen         84
  C.9         Disposal of Filtered Heavy Metal Sludges                             86
  C.10       Cost of Treatment of Concentrated Cyanide Waste by Chlorination      88
  C.11        Cost of Concentrated Cyanide Waste Treatment - 2 Stages             91
  C.I2       Cost of Dilute Cyanide Waste Treatment                             92
  C.13       Incineration of Chlorinated Hydrocarbon Liquid                      94
  C.14       Incineration of Chlorinated Hydrocarbon Slurry                      96

-------
                          LIST OF TABLES (Continued)

Table No.                                                                       Page

  C.15          Cost of Waste Water Concentration by Evaporation                    99
  C.16          Portable Insecticide Can Destroyer                                 100
  D.1           Typical Values of Risk                                            104
  D.2          Expected Reduction in Lifetime from a Continuous, Lifelong,
                  Threat of Fatality                                              105
  D.3          Transport & Transfer Spill Risk: Hypothetical Example               111
  E.I           Federal Laws Relating to Hazardous Wastes                         121
  E.2           Organizational Units in Federal Executive Branch with Interest
                  in Hazardous Wastes                                            141
  E.3           Structural Units in  Congress with  Interest in Hazardous Wastes        146
  E.4           New Jersey Laws and Regulations Relating to Hazardous
                  Wastes — Existing Laws                                         148
  E.5           Existing Pennsylvania Laws Relating to Hazardous Wastes             180
  E.6           Excerpts from Pennsylvania Rules and Regulations, Department
                  of Environmental Resources                                    184
  E.7           Copy of Department of Environmental  Resources Internal
                  Instructions Concerning Issuance of Department of
                  Environmental Resources Permits                                188
  E.8          Key Officials Interviewed in Harrisburg, Pennsylvania                189
  F.1           Effect of Dimensionless Grid Size on Degree of Collection            201
  F.2          Field Data for Organo Wastes                                      221
  F.3          Incineration of Chlorinated Hydrocarbons —  Modular Cost           223
  F.4          Calculation of Auxiliary  Fuel Requirements                         225
  F.5          Chemical Utility  Requirements                                    226
                                         VI

-------
                               LIST OF FIGURES

Figure No.                                                                     Page

  B. 1.1        The Chrome Tanning Process                                        42
  B.1.2       Manufacturing Process for Nickel-Cadmium Sintered Plates             46
  C.1         Comparison of Heavy Metal Sludge Volume with Volume of Waste-
                water                                                          70
  C.2         Treatment of Concentrated Chrome Wastewater                       72
  C.3         Recovery of Chromium from Dilute Wastewater by ION  Exchange      74
  C.4         Treatment of Dilute Chrome Wastewater                             75
  C.5         Disposal of Hazardous Heavy Metal Water Sulfide Precipitation
                of Heavy Metals                                                 79
  C.6         Incineration of Dilute Hydrocarbon                                 81
  C.7         Dilute Hydrocarbon Removal from Wastewater by Activated Carbon    83
  C.8         Incineration of Dilute Hydrocarbons Containing Halogen              85
  C.9         Asphalt Encapsulation of Chrome Waste Sludge & Burial (20% Solids)   87
  C.10        Concentrated Cyanide Waste Treatment by Chlorination               89
  C.11        Concentrated Cyanide Waste Treatment by Acidification and
                Chlorination                                                    90
  C.I2        Dilute Cyanide Waste Treatment                                    93
  C.13        Incineration Cost of Chlorinated Hydrocarbon Liquids —
                Capital Costs                                                    95
  C.14        Incineration of Chlorinated Hydrocarbon Slurries — Capital Costs       97
  E.1         Organizational Units Within Federal Executive Branch that have
                Interest in Hazardous Wastes                                     140
  F.1         Alternative Processing Strategies                                   194
  F.2         Collection Alternatives                                            199
  F.3         Transport Geometry                                              200
  F.4         Effect of Grid Size on Degree of Collection                          203
  F.5         Typical Decision Map Based on  Source Size                          205
  F.6         Empirical  Fitting of Dimensionless Decision Map                     209
  F.7         Collection Site Distribution Geometry                              210
  F.8         Distribution of Sources Between T and  H Centers                    211
  F.9         Fraction of Hazardous Sources Using H Centers                      214
  F.10        Effect of Source Size on Model  Utility                              219
  F.11        Incineration Cost of Chlorinated Hydrocarbons — Capital Costs       224
  F.12        Decision Map for Test Run                                        230
                                      vn
                                                                        Arthur D Little Inc

-------
  APPENDIX A




LISTS OF WASTES

-------
                              TABLE A.I

                      Hazardous  Wastes Selected by TRW
                        for National Disposal Sites
                      (through TRW 8th Monthly Report)
Inorganics
                                                           TRW
               Compound                                  Code No.

     Cyanides

          Calcium Cyanide                                     91
          Cadmium Cyanide                                     84
          Copper Cyanide                                     120
          Lead Cyanide                                       239
          Mercuric Cyanide                                   254
          Nickel Cyanide                                     295
          Potassium Cyanide                                  344
          Silver Cyanide                                     370
          Sodium Cyanide                                     387
          Zinc Cyanide                                       457

     Arsenites and Arsenates

          Calcium Arsenite                                    88
          Copper Arsenate                                    119
          Copper Acetoarsenate                               490
          Lead Arsenate                                      235
          Lead Arsenite                                      236
          Manganese Arsenate                                  500
          Potassium Arsenite                                  341
          Sodium Arsenate                                    377
          Sodium Arsenite                                    376
          Zinc Arsenate                                      453
          Zinc Arsenite                                      454

     Chromates

          Ammonium Chromate                                   21
          Ammonium Bichromate                                 22
          Chromic Acid                                       114
          Potassium Chromate                                  343
          Potassium Bichromate                               345
          Sodium Chromate                                    386
          Sodium Dichromate                                  379

     Arsenic Compounds

          Arsenic Trichloride                                 47,  50
          Arsenic Trioxide                                    87

-------
                           TABLE A.I (Corit.)

Inorganics (cont.)
                                                             TRW
                                                           Code No.
     Antimony Coirpounds

          Antimony Pentafluoride                              36
          Antimony Trifluoride                                43

     Cadmium and Compounds

          Cadmium Oxide                                       81, 85
          Cadmium Metal                                       82
          Cadmium Chloride                                    83
          Cadmium Phosphate                                   86
          Cadmium Nitrate                                    479
          Cadmium Potassium Cyanide                          489
          Cadmium Sulfate                                    481

     Mercury and Compounds

          Mercury                                            257
          Mercuric Chloride                                  253
          Mercuric Nitrate                                   255
          Mercuric Sulfate                                   256
          Mercuric Ammonium Chloride                         503

     Chromium (III) Salts (Sludges only)

          Fluoride                                           485
          Sulfate                                            486
          Cyanide                                            487
     Other
          Nickel Carbonyl                                    293
          Carbonyl Chloride                                  101
          Perchloryl Fluoride                                326
          Chlorine Trifluoride                               106
          Bromime Pentafluoride                               66
          Fluorine                                           200
          Chlorine                                           105
          Boron Hydrides                                      61
          Pentaborane                                        505
          Hydrogen Sulfide                                   221

-------
                             TABLE A.I (Cont.)


Organics                                                     XRW
                                                           Code No.
     Pesticides
          Aldrin                                              13
          Benzene Hexachloride                                55
          2,4-D (2,4-Dichlorophenoxyacetic Acid)             135
          ODD                                                136
          DDT                                                137
          Dieldrin                                           147
          Dinitro Cresols                                    162
          Endrin                                             170
          Ethylene Bromide                                   182
          Methyl Bromide (Bromomethane)                      267
          Methyl Chloride (Chloromethane)                    268
          Methyl Parathion                                   274
          Parathion                                          321
          Chlordane                                          484
          Demeton                                            491
          Guthion                                            495
          Heptachor

     Aliphatic Halogenated  Hydrocarbons

          Carbon Tetrachloride                               100
          Chloral Hydrate                                    104
          Chloroform                                         109
          Dichlorofluoromethane                              142
          Dichloroethyl Ether                                143
          1,2-Dichloropropane                                145.363
          1,3-Dichloropropene                                146
          Dichlorotetrafluoroethane                          147
          Epichlorin                                         171
          Ethyl Chloride                                     180
          Ethylene Dichloride                                185
          Methyl Chloroformate                               269
          Perchlorethylene                                    325
          Polyvinyl  Chloride                                 340
          Tetrachloroethane                                  424
          Trichloroethane                                    437
          Trichloroethylene                                  438
          Trichlorofluoromethane                             439
          Vinyl Chloride                                     450

     Aromatic Halogenated Hydrocarbons

          Chloracetophenone                                  107
          Chlorbenzene (Chlorbenzol)                          108
          o-Dichlorobenzene                                  140,278
          p-Dichlorobenzene                                  141
          Trichlorobenzene                                    436
          Hexachlorophene                                    497

-------
                             TABLE A.I(Cent.)

                                                             TRW
Organics (Cont.)                                           Code No.
     Other
          Chloroacetophenone                                 107
          Nerve Gas  (non-persistent)  (DOD)                   287
          Nerve Gas  (persistent)  (DOD)                       288
          Nitrogen Mustard (DOD)                             306
          Nitroglycerin  (DOD)                                307
          Acrolein                                             8
          Dimethyl Sulfate                                   160
          Dinitro Cresols                                    162
          Dinitrotoluene                                     165
          Tear Gas (CN and CS)                               42.2,423
          Tetraethyl Lead                                    42.5
          Tetramethyl Lead                                   427
          Organo Mercury Compounds                           258
Explosives
          Picric Acid                                        338
          Copper Acetylide                                   517
          Silver Acetylide                                   537
          Cyanuric Triazid                                   519
          Primers and Detonators                             520
          Diazodinitrophenol  (DDNP)                          521
          Dipentaerythritol Hexanitrate  (DPEHN)              522
          Gelatinized Nitrocellulose  (PNC)                   523
          Glycol Dinitrate-Nitroglycerin                     525
          Lead Azide                                         529
          Lead Styphnate                                     531
          Mannitol Hexanitrate                               532
          Mercury Fulminate                                  533
          Potassium Dinitrobenzfuroxan  (KDNBF)               536
          Silver Azide                                       538
          Tetrazene                                          542
Radioactive
          Cesium-134
          Cesium-137
               (Barium)-137m
          Plutonium-238
                   -239
                   -240
                   -241
          Americium-241
                   -243

-------
                               TABLE A.I (Cont.)


Radioactive (Cont .)

          Curium-242
          Ruthenium-106
              (Rhodium)-106
          Cerium-144
              (Praseodynium)-144
          Promethium-147
          Strontium-90
              (Yttrium)-90
          Zirconium-95
          Niobium-95
          Carbon-14
          Cobalt-60
          Iridium-192
          Radium-226
          Iodine-129
          Iodine-131
          Krypton-85
          Zenon-133

-------
                      Q£  O
                      H  E3
                                      ro
                                     r*^  CT»  in  o
                                     00  rH  CO  O
                                         rH  CN  m
                                               00  O  MD  rH  vO  <>•
                                               oo  cr>  co  -d*  r~*  in
                                                   -3-  CN  co  co  <±
                                                                                                     
-------
            13
             C

             O

             £
             O
            o
             CO
             o
            •H
             0
             tij
            43
            a
                pi   o
                H  !S
                                        f—t  
rJ rH
Q) -H
S CO

0
3 rH
•H 0)
O ,M
rH CJ
tfl -H
CJ i3
0
3
•H
C
O

£
<3
§
•H
03 0
co 3
CO vH
4J 13
O O

•H
CJ
O
•H
0
O

i-;
C_J
0)
T3 d> 0)
•i-l 4-1 T3
>-i CO -H
0 K-i (3
3 rH Cfl
rH 3 r^i
rH C/3 U

^,
S-(
3
O
M
0)
s
Mercury

o
c
cfl
00
y^
o
e
m Chloride
T3 01 0) 3
•H 4J 4-J -H
>-i CO to C
o M m o
rH JJ rH E
43 -r4 3 B
U SZ 00 <
•d
 a)

 (3
•H
 4-1
 (3
 O
O
CN
 I
W
             o
             oc
             0)

             cO
            u
oo
 03
 CO
 cfl
rH
a
 i
43
 3
CO
        43
 O
CO
                                        43
                                         3
                                        t-(
                                         O
                                         CO
                                         (3
                     cfl
                     H
                     0)
                             03
                             (U
                            T)
                            •H

                             cfl
                                                                                 03
                                                                                 0)
                                         O
                                         S-i   03
                                        43   0)
                                        U   4->
                                             cfl
                                         01   0
                                        iH   O
                                        43   H
                                         3  43
                                        i-l   O
                                         O  -H
                                        w  a
                                         en
                                        T3
                                         C

                                         O

                                         I1
                                         o
                                        u

                                         0

                                        •H
                                         0
                                         O
                                                            o
                                                            i-H
 03
 0)
 60

 3
rH
CO

M
M
H

 0

i-f
 0
 O
 1-J
43
O
                                                                                                                             3
                                                                                                                             p


                                                                                                                            I
                                                                                                         00
                                                                                                         1-1
                                                                                                        o
                                                                                             03
                                                                                            "O
                                                                                             (3

                                                                                             O
                                                                                                         O
                                                                                                        u

                                                                                                         u
                                                                                                        •H
                                                                                                         (3
                                                                                                         ct)
                                                                                                         SO
                                                                                                         M
                                                                                                         O
                                                                                                         (3
                                                                                                                     e
                                                                                                                     o
                                                                                                                     o
                                                                                                                    a
                                                                                                                     cfl
                                                                                                 3
                                                                                                 O
                                                                                                 H
                                                                                                 01

-------
*   o
H  S3
           CN
                                           ^o  o  m  I-H
                                           O  O  O  O
                                           rH  CM  r-t  rH
rH  rH  in
CMvOO
CM      U">
                                                                                       rH  rH  rH rH rH •<)•
                                                                                                                      csi i-~ oo
                                                                                                                      00 ">O ^O
                                                                                                                      t-H CM CM
                                                                                                                                          tn
                                                                                                                      CM
                                                                                                                  CM  CO
TJ
C
3
O
a
B
0
o

rH
«
a
•H
B
CU
X!
U














0)
T3
•H
S-l
0
3
T-H
M-l
0) CO
B 4J
co ei
Z 0>
PM

CU
H £3
0) -H
J.
!H
O
rH
f"{
(J
J_4
cu
PH






cu
T3
•H
(-1
0
3
rH
MH
•H
(-1
H

0)
C
•H
}_t
O

(-{
U


















cu
c
•H
}_i
O
3
rH
fe









CU
"O
•H
M
O
rH
J3
O

CU H
C r**
•H C3
i-4 O
0 £>
rH !H
43 cfl
U CJ










Q)
T3
•H
MH
rH
3
CTD

ti
Q)
00
O

T)

ffT


















0)
c
cfl
H
0

•H
O














CD
C
CO
r4
0
pq

cfl

C
a)

                                                                                   0)
                                                                                   •a
                                                                                   •H
                                                                                   M
                                                                                   O
                                                                                   rH
                                                                                   ,C
                                                                                   O
                                                                                   CO
                                                                                   X
                                                                                   01
                                                                                   S3
                                                   c  a
                                                   •H  CU  Q
                                                   M  N   I
                                                   •a  c  >

01
T3
•H
J-l
O
rH
43
CJ
rH
>.
                                        C  OJ  43
                                        W  33  CJ
                                                                                                                      W
                                                                                                                               (1)
                                                                                                                              g
                                                                                                           C
                                                                                                           O
                                                                                                                       B
                                                                                                                       01
                                                                                                                       Q
    C
    O
    •H
    43
    4-J
    CO
    i-i
    cO   C
    P-i   O
 e      -H
 O  rH  43
•H  >~, 4-1

4-1  4J   1-1
 3  CU   nj
O  S  PH
-a
 a)
 3
 o
 o
CM

<

W



3
H







>!
!-i
0
bt
a)
4-i
03
u
CO
en
ed
rH
U
Xl

CO




1
r~l
>^
c
o
J3
VJ
n)
CJ



CO
C
QJ
&0
O
rt
,c
S-l
0)
4-1
c
h- 1



                                                                O
                                                                a;
                                                                CD
                                                                a
                                                                CO
                                                    en
                                                    a
                                                   -H
                                                    c
                                                    cfl
                                                    GO
                                                    »-l
                                                   O

                                                    o
                                                    !-i
                                                    O
                                                   rH
                                                   43
                                                                                                                      OO
                                                                                                                       CO
                                                                                                                       CU
                                                                                                                       CO
                                                                                                                       CO
                                                                                                                       CJ

                                                                                                                       00
                                                                                                                       c
                                                                                                                       •H
                                                                                                                       c
                                                                                                                       o
                                                                                                                       u

                                                                                                                       c
                                                                                                                       cu
                                                                                                                       oo
                                                                                                                       o
                                                                                                                       r-t
                                                                                                                       CO
                                                                                                                       33
                                                                        CD
                                                                        CU
                                                                        4-1
                                                                        CO

                                                                        O,
                                                                        CO
                                                                        O

                                                                        P-i

                                                                        O
                                                                        •H

                                                                        CO
                                                                        00
                     CO
                     K
                     01
                     c
 CO
 a
•H
 C3
 «s
 00
 S-i
 o
                             0)
                                                                                en
                                                                                0)
                                                                               13
                                                                               •H
                                                                                a
                                                                               •H
                                                                                .U
                                                                                tn
                                                                                0)
                                                                    10

-------
              OS   O
              H  S3
                                                  co
                                                  vD
                                                  co
                                  r-l I-l rH r-l I— l
                                                          r-lr-4r-|CMCO-3-
e w
o
t-i iH
O >:

.J [ 1
14H 01
0 O

O O
rH rH
43 43
O CJ
•H -H
P P







01
C
cfl
ft
O
S-i
ft
O

o
rH
4^
O
•rl
Q
1
CM
,-T

0>
fi
cfl
r!
4J
01
01 O
(3 !-i
01 0
ft 3
O rH
V-l <4H
ft Cfl
O rl
M i -J
O 0)
rH 4-1
43 O
O VJ
•H O
P rH
1 43
CO CJ
•> -H
rH P







0)
-rj
•H
^
O
01 rH
•CJ 43
•H 0
M -H
0 P
rH
43 01
0 G
0)
rH rH
^1 £**«
43 43
4J 4-J
w w






01
4-1
Cfl
G 01
M (3
O 0)
14H rH
O >-,
)H 43
O 4J
r-l 01
43 0
U S-i
O
rH rH
^ 43
43 O

o; o>
IS (Xi









0)
C
cfl 0)
43 C
4-1 Cfl
0) 43
O 4-1
)-i 0)
0 0
rH ^-1
43 0
0 rH
cfl 43
M 0
4J -H
01 J-i
H H




Ol
C
CO
43
4-1
01 CU
fi e
Ol O
rH 1-1
>. 0
43 3
4-1 rH
01 4H
0 O
r-l V-l
O O
rH rH
43 43
CJ U
•rl -H
J-i S-J
H H












cu
TJ
•H
^)
O
rH
43
O

rH
Ix»
fi
•H








0)
C
O
f3
0)
43
ft
0
4J
01
U
Cfl
o

o
rH
43
U









0)
C
(U
N
0) C
C 0)
01 4=
N C

0) O
43 rH
0 43
>-i U
O -H
rH C
43 1
0 0









(U
C 01
Ol C
N 01
C N
0) C3
42 a)
C 43
rJ 0
O rJ
rH 0
43 rH
U 43
•H CJ
C -H
ft H











01
C3
01
43

O
^_j
0
rH
43
a
cfl
X
O)
33










TJ
cfl T3
QJ CO
1-4 0)

rH

43 >,
4J 43
flj 4-1
B 01
cfl cfl

4J 4J
01 0)
H H
"O
 01


•H
4J

 O
U
O
CXI
        CM
CM
CM
CO
CM
W
rJ


















?*i
Vj
0
60
0)
CO
U























CO
rrj
CO C3
Cfl 3
cfl O
i — 1 ft
u 6
1 0
43 U
3
W O
1-4
4-1
•H
fz;












cfl

0)
c co
Ol 0)
CJ rg
CJ
•H
4J
CO
01
CO
*o
C
(3 3
0) O
60 ft
0 g
rH O
cfl U
K
60
0 (3
•rl -H
4-1 (3
Cfl -H
43 Cfl
CX 4-1
•H C3
iH O

-------
              Pi   O
          -a
           C
           3
           O
           p.
           e
           o
          CJ
           cfl
           CJ
          •H
           e

          43
          CJ


oo





















(3
•rl
01
rH
O
}-j
a



o
**o
1-1











0)
4-1
cfl
14-t
rH
3
Ol

rH
r^l
43
4-J
0)
6
•rl
P


m
vo
rH












cu
PS
0)
3
rH
O
H

O
r-l
4-1
•H
PS
•rl
O
OO
00
CM
oo ^o CM on
r-~ O CM CM
CM on -j-  rl rl
rJ 4J Cfl
0) -rl Ol C/3
53 Z H CJ


r^.
O
on














C
•H
M
01
U
£*"!
rH


in
CM
m











0)
4-1
Cfl
Ji-j
4-1
•rl
C
•H
P



CNI
CM
in
O)
4-1
Cfl
1-1
jj
•H
13
cfl
X
01
tfj
1— I
O
4J
-H
J-J
rC
4J
r>"l
^_|
0)
cfl


OO
CM
m

01
tn
0
p- i
3
rH
rH
a>
a
o
^4
4-1
•H
%%

-0

ta
•H
C
•H


CM
on
m







01
4-1
Cfl

4-J
•H
C
cfl
X
0)


rH
O
60 rH 4-J 4-1 4-1
O
i-l
4-1
•H
S3
0
CJ
>.
rH
CJ
C
CU
ex
•H
P
C
cfl
rH
01
CJ
•rl
C
C
cfl
a


OO rH CM
on on *3'
on m m












y— . s
fe Ol
m 4-j
Z cfl
T3 P (3
•H tai 43
CJ ^^ CX 0)
<^ K^S (3
(3 -l-l CU
O cd c/i N
•rl X CO
MO 13 r-l
CJ J-l Cfl 4-1
•H 3 0) 0)



,_!
CM
in



'—•
S3
P
P_


1 	 1
O
C3
O)
43
CX
O

u
•rl
C!
•rl
T)
O
N
Cfl
•H
P


1^
, — |
in











0)

•H
rH
p*>
4-1
0)
CJ


»-l
Ol
CX
ft
0
CJ


f^
CO
m











D

•H
, — (
r**t
4J
O)
O


M
11)
>
r— |
•H
01


00 OO
m on
m m










0)
4-1
Cfl
(3
•H
oi B
"O rH
•H 3
N ft,

r>*>
l-l r-l
0) 3
r> CJ
rH S-l
•H CU
C/1 S


OS CJS
CM rH
m m










(U

•H
N
cfl
•H
^
Ol H
TD
•H CJ
N -H
-,  cn
 >   4-1
 Cfl  r-l
 01   cfl
33  c/2
           cfl
           cj
                            tn
                            o
                           •H
                            c
                            cfl
                    a)
                   o
tn
3
O
0)

cfl
                            QJ
                            O
                            tn
                           •H
                           2
                                            O

                                            I
                                            O
                                                                •H
                                                                 tn
                                                                 o
                                                                      12

-------







13
C
D
O
D.
g
O
U

t-H
cd
CJ
•H

OJ
43
CJ



S • o
Pi O CM
HZ m
cn
13
C

0
CX
0
O
O

MH
O

>^
4J
cu cu
B -H
cd s-i
z cd
>
cu
C >
•H 0
cd 43
4-1 Cd
C
O CO
o cd









r-~
ro
i— I
1
B
3
•H
CO
Ol
CJ

»l

/-* CO
B CM
r^ **
co co
t-H CM
1 i
g §
•H -rl
M CJ
cd o
pa 4-1
"-' 3
t-H
PH














CO

CM O
•> rH
CM 1
,
13
O ^^
cu r~~
cn , C
o s-i i-i cu
CJ H ^ (SI

















rH
CO
rH
*
ty
-i cu
^4-{ PS

cn 13
cu cu
• I ^
4-J 1—1
CO CU
cd 3
S Pn



•H
4J
 C
 cd
 3
 cr

13
 01
4J
•H
 B
                                                                                  4J
                                                                                  O
0)
cn
3
                                                                                                      cu
                                                                                                     13
                                                                                                     •H
                                                                                                      S-i
                                                                                                      0)
                    4-1
                    o
rH
cd
tl
M
0)
C
0)
o



cn
01
(^
•H
CO
O
rH
a.
X
w


cu
>
•H
l|
a
cd
o
•H
13
"3
K
                                                                                                                                     to
                                                                                                                                     t-l
                                                                                                                                     ai
                                                                                                                                     Pi
                                                                                                                                     H
                                                                                                                                     *
                                                                  13

-------
       APPENDIX B1




DESCRIPTION OF WASTE TYPES
            15

-------
                                   BACKGROUND

     To apply the decision map  model for selecting between alternatives on an economic
basis, it was  necessary to develop a general understanding  of the types of industries thai
generate hazardous waste streams as well as detailed information on specific waste streams
which currently exist and thus are potential candidates for Central Processing Facilities, This
section describes the results of a general overview as it applies to:

     •    Organic wastes suitable for incineration;
              Chloric organic solvents
              Pesticides
              Paints
     •    Waste streams containing heavy metals and/or cyanides;
              Electroplating
              Tanning
              Battery manufacturer
              Cooling tower blowdown
              Smelting and Refining
              Chlor  alkali plants
                                       17

-------
                ORGANIC WASTES SUITABLE FOR INCINERATION

     Within  the  list  of Category  I wastes (see  Appendix A), the categories which could
utilize  incineration  as the treatment  process  are pesticides,  the  chloro  organics,  some
miscellaneous organic compounds, and wastes from the paint industry which contain heavy
metal pigments.

                              Chloro Organic Solvents

     The potential sources of industrial wastes for these compounds were explored in two
ways.  First, the producers were  examined  in  terms of  plant  capacity and  the process
employed.  Second, the  major users  (by  volume) were studied to determine whether un-
reasonably  large  volumes might be encountered at many  individual use points. In both of
these situations,  it is important to recognize that  an effort was only made to determine
whether  the industry segment  had many large sources.  If most individual plants in the
industry  generated  less  than 10  million gallons/year,  this was  taken  as  support of the
conclusion that the chloro organic wastes would be treated off-site.

     With a few possible exceptions, such as those producing vinyl  chloride and ethylene
dichloride,  most of the plants that produce chloro  organic solvents  will have waste streams
of well under  10 million  gallons per year. Similarly, almost all users of  these solvents have
waste volumes much lower than 10 million gallons per year. Thus, most plants producing or
utilizing  these  solvents  will  probably have  need on an  economic basis, for  a central
processing facility to treat their wastes.

     A summary of the production volumes for  the chloro organics of interest to this
program  is given  in Table  B.I .1. Details on various compounds are given below.

     C,  Compounds. The  compounds in this  category include: methyl chloride, methyl
bromide, methylene  chloride, chloroform, carbon  tetrachloride, trichlorofluoromethane,
and dichlorodifluoromethane. A few isolated plants may have  sufficient waste volume to
perform  their own treatment.

     Methyl Chloride. Roughly a dozen producing plants make methyl chloride. All but two
are located in the Middle Atlantic, Southeastern and Gulf Coast states; the remaining two
are in  the Midwest and the Far West. Two basic  processes are used to make methyl chloride.
The first is based on the reaction of methanol and hydrochloric acid and leads to higher
direct  yields of methyl chloride. Plant capacities range from 0.5 million to 13 million gallons
per year. The second method  utilizes the chlorination of methane with  plant  capacities
ranging from 1 million to 13 million gallons per year. Total production  for 1970 was about
56 million  gallons for both processes.
                                        18

-------
                                        TABLE B.1.1

                              CHLORO-ORGANIC COMPOUNDS
                                Estimate of Production for 1970
Category
Compound
No.
                                                   Plants^
                                                 Capacity (MM gallons)
Largest    Range of Remainder
Production Volume*
   (MM Gallons)
           Methyl Chloride             13        13
           Methyl Bromide             —         —
           Methylene Chloride           9         8
           Chloroform                  8         6
           Carbon Tetrachloride        10        15
           Trichlorofluoromethane      —         —
           Dichlorodifluoromethane     —         —
                                             2-7
                                           0.5-2.5
                                           1-10
                                                   56
                                                  <2
                                                   37
                                                   19
                                                   76
                                                   20
                                                   30
   C2      Ethyl Chloride               8        36
           Ethylene Dichloride         15       100
           Vinyl Chloride              14       115
           Methyl Chloroform           4        36
           Trichloroethylene           10        22
           Perchloroethylene           14        16

   C3      1,3-Dichloropropene         —         —

Aromatics  Chlorobenzene              12        40
           Dichlorobenzenes           14        —
           Trichlorobenzenes            4        —
                                           3-13
                                           8-85
                                          20-80
                                           512
                                           2-7
                                           1-8
                                            0.5-8
                                                   90
                                                 620
                                                 540
                                                   34
                                                   49
                                                   56

                                                 HO

                                                   70
                                                   30
                                                 <5
   Arthur D. Little, Inc., estimates.
   Taken from "Synthetic Organic Chemicals, U.S. Production and Sales, 1970, "U.S. Tariff Commission TC
   Publication 479.
                                              19

-------
     The reaction  of methanol and hydrochloric acid leads to methyl chloride, me thy lone
chloride and water. Although the process yield of desired component is usually greater than
907( based on the initial HC1, most of the unreacted HC1 leaves the process as an HCI   H2 O
stream containing methyl chloride and/or methylene chloride. The v/aste organics probably
represent no more than 1-2 percent  of the  final  product so  even in the largest plants,
concentrated waste organics would  amount to less  than 200,000 gallons. However, since
these compounds exist from the process mixed with large volumes of aqueous hydrochloric
acid, the waste stream volume could reach 40 million gallons per year in a few isolated  cases.

     The production route which uses  chlorine and  methane  should not  lead to any large
waste streams. After chlorination, the product is distilled; low-boiling fractions are recycled
and  pot residue is used to make perchloroethylene. Because of the need to condense the
desired product, some  water is produced that contains  hydrochloric acid, but mostly this
stream is pretty clean  and can be sold as a commercial product. (Some is waste but large
volumes are not common.)

     Other Chloromethane Products.  These products include methylene chloride, chloro-
form, and carbon  tetrachloride. They  are made via  the  chlorination of methane and most
plants that make one compound make all three. Each product is made in roughly 10 plants
with geographical  distribution similar to those for  methyl chloride. Plant capacities  range
from 2 million to 8 million gallons per year  for chloroform and  1 million 1o 15 million
gallons per year for carbon tetrachloride.

     As with methyl chloride, the only potential waste stream is  the water used  to aid
condensation and this water tends to be fairly clean. In fact, the trend is away from direct
contact between product and water so even less  water  probably will  be used. Impure
product is distilled and recycled, or used to manufacture perchloroethylene.

     C2 Compounds.  In this category  there are several plants where the waste volumes are
sufficiently  large to justify  having  waste processing facilities on site  Solvents included  in
this group  are: ethyl  chloride, ethylene dichloride, vinyl chloride,  methyl  chloroform,
trichloroethylene, and perchloroethylene.

     Ethyl Chloride. Ethyl chloride can be  made by chlorination of ethane, reaction of HCI
and ethanol, or addition of HCI to ethylene. This last is the primary process. The eight plant
locations include five on the Gulf Coast, one in Virginia, one in New Jersey and one on the
West Coast. Capacities are 3-30 million gallons per year and total production for 1970 was
90 million gallons.

     The discussion for methyl chloride applies here for  the two processes that are common
to both.  The plants based on ethanol have capacities of less than 15 million gallons per year
so  similar maximums for waste volumes can be anticipated. The reaction of ethylene with
HCI should  not  lead to large waste-water streams, and as with chlorination, the pot residue
can be utilized to make perchloroethylene.
                                        20

-------
     Ethylene Dichloride. Because it is an  intermediate for many other chloro-organics, this
is the largest single chemical consumer of chlorine, including vinyl chloride and thus vinyl
chloride polymer.  Two basic processes are  used —  chlorination  of ethylene or oxychlorina-
tion (HC1 + O2) of ethylene. Within the 15 or so plants, capacities can be large (up to 100
million gallons per year).  Total production for 1970 was 620 million gallons.

     For the process based on reaction  of HC1 with ethylene almost all the waste goes into
trichloroethylene or perchloroethylene production. The oxychlorination reaction requires a
separation  to remove the water produced during the reaction. These resulting water streams,
which contain  traces  of  organics, can  be very  large - hundreds of millions of gallons per
year. Thus, this  process represents a  possible  situation where on-site processing may be
attractive — but the initial processing  step would have to be seperation (not incineration)
because  the  chloro-organics  are  present at only the parts per million level. Most of the
product ethylene dichloride is used to make vinyl chloride and the processes are interrelated
so the HC1  is recycled.

     Vinyl Chloride.  As  noted above, most of the vinyl chloride is made by pyrolysis of
ethylene dichloride with resultant recycling of  the non-vinyl  chloride  stream. Therefore,
little chloro organics show up as  a waste stream even though the production quantities are
huge (as high as 115 million gallons/year in one plant).

     Methyl Chloroform, Trichloroethylene, and Perchloroethylene.  These compounds are
produced by interaction  of HC1 with other organics under appropriate thermal conditions.
Waste from methyl chloroform  goes  to the perchloroethylene plant; the ultimate waste
product from trichloroethylene and perchloroethylene is a  solid high-melting material that
can be burned or buried.

     C3  Compounds. 1,3-Dichloropropene  an(j  \ ;2-dichloropropane are  obtained by up-
grading allyl chloride  to  a more saleable product. Total production for 1970 was about 10
million gallons so total waste streams are not likely to be over a few million gallons at the
most.

     Aromatic  Compounds. The  aromatics of interest to this program are: mono-, di- and
trichlorobenzenes. Of these, mono is by far the largest (70 million gallons and 12 plants).
Dichlorobenzenes are  produced in a similar number of plants but total production in 1970
was near 30 million gallons. The  total  for trichlorobenzene amounted to less than 5 million
gallons in 1970.

     In making chloroaromatics,  almost 98% of the HC1 used in the oxychlorination process
ends up  in the final  product. Thus, only  2 to  3 percent  of  the HC1 ends up in the exit
wastewater stream and most of this is as HC1. However, this waste stream will be saturated
in  chlorobenzenes. One  very large producer  may have a waste  volume greater than 40
million gallons/year, but  the rest should be well below 10 million gallons/year.
                                        21

-------
     Uses of Chloro Organic Solvents.  The major uses and estimated volumes for the chloro
organic solvents  are  given  in  Table B.I.2. By and  large, they fall into three general
categories:

     •   A component in a manufacturing process;
     •   A solvent for a manufacturing process; or
     •   A solvent or vapor degreasing operation.

     Most of the applications of these solvents consume in total, less than 20 million gallons
of solvent a year. In addition, in most cases, this total volume is distributed among several
locations, so except for the situations listed below, there is little chance that a user will have
more than a maximum of 10-20 million gallons of waste a year. Those where large volumes
might be found include:

     •   Production of fluorocarbon — carbon  tetrachloride.

     •   Production  of  tetraethyl lead —  ethyl  chloride. However,  because  this
         material is unstable when exposed to water, aqueous waste streams are not
         feasible. Organic waste streams from this process should be well below the
         30-million-gallon-per-year level.

     •   Production of vinyl chloride -  ethylene dichloride.

     •   Production of polyvinyl chloride - vinyl chloride.

     •   Vapor  degreasing —  trichloroethylene. Although  total quantities  in the
         United  States probably are huge, the final waste  usually is a sludge or spent
         solvent and involve low volumes per unit operation (500 gallons or less).

     •   Dry cleaning —  perchloroethylene. These tend to be numerous  and  small-
         volume operations.

     Thus, a few situations  may  involve large-volume waste streams, but most  users of
organo chlorine wastes will have waste quantities well below the breakoff limit of tens of
millions of gallons.

                                      Pesticides

     The pesticide industry is composed of a few producing plants, a  large  number of
formulators and a great number of applicators. Only a cursory examination of the pesticide
industry was conducted. However, it is clear that although there may be a few large waste
producers, most of this industry will have waste streams well below  the volume where it is
economically attractive to treat on-site.
                                        22

-------
                          I

                         "o
                       g      -co
                                                   «-  o
                                                           CM
                                                                           to
                                        cu
                                       J2
                                       EC  O      O  O
                                                       •M  +-I
                                                       o  o
                                                                                    CD
                                                                                    -c
                                                                                Q
                                                                                Q
09
m
<
LU
GO
D

Q
Z
LU

D
LU
        CO
                                                   oo  oo
                                X

                               To
                                                               CD  00
                                                                   CM
                                                                           LO
                                                    %
     CD
O   C

l*»   i
C>  2
i-   O
o

 x

!
TJ
rtJ
QJ
i
etramethyl I
1-



O)
c
"vi
ro
o>
&>
cu
Q
•*-»
c
o>
>
O
to



1_
M—
CD
DC

luorocarbon
LL





roduction of
o.



c
o
Fluorocarb




L-
3
U
CO
•4—
D
C
ro
S
o>
c
cu
X-
>
w



V)
cu
c
E
<
cu
c
cu
>
r:
4->
LU



C3)
C

ro
cu
i °>
! a
o
Q.
ro
>





W

TJ
ro
+-•
c
'co
Q.
Removers
Fluorocarbon Pla
Production of
Fluorocarbon '
Tetraethyl Lead
Vinyl Chloride
vj
73
O
jr
O
">
c
'>
>>
0
OL
O)
c
'E
ro
cu
O
TJ
O
O
Vapor Degreasing
CO
c
'£
ro
cu
O
>
Q
                                                                                            C
                                                                                            cu
                                                                                            D)
                                                                                            C
                                                                                            £
                                                                                            en
                                                                                           -S
                                                                                            i/r
                                                                                           •f-f
                                                                                            c
                                                                                            a
                                                                                            e
                                                                                            3
                                                                                            O  00
                                                                                            CM
                                                                                                    cu
                                                                                                    C
                                                                                                    cu
be
on
                                                                                                        O)
                                                                                                        .c
                                                                                                   O  O
                                                                                           o
                                                                                           CO
Con
Mo
                                           01
                                          -a
Chloride
                                          6
                                          cu
                                          c
                                      	  _cu

                                       >  >
                                      SL  £.
                                      •4-1  4-1
                                       cu  cu


hloroform
O
CD
TJ
_0
£.
U
ro
4-1
01
0
_Q
k_
CO
0


cu
TJ
_0
6
~>-
^
^-i
LU
cu
TJ
_0
£.
O
Q
cu
c
cu
>-
^:
LU


CU
TJ
C
O
.C
O
">
c
>

E
0
H—
O
o
6
"x
^
4-1
cu
2

cu
c
cu
richloroethyl
1-

cu
c
HI
jrchloroethyl
Q.
cu
c
31
0
3-Dichloropr
«-
CU
c
ro
Q.
O
2-Dichloropr
<-"
CU
CD
N
C
onochlorobei
S


-------
     The number of plants producing the pesticides included  as Category 1  wastes, along
with production volumes and  waste  quantities, is given in Table B.1.2A. This data shows
that only a few plants in the United  States produce these chemicals and that none of their
waste streams would amount to more than  5 million gallons per year. Only three of the
plants are located in the Pennsylvania-New Jersey area.

     Although detailed data was not developed on the numbers of formulators  and appli-
cators in the United States or  within the Pennsylvania-New Jersey area, it is  assumed that
the total is fairly large. For example, Newark and Philadelphia have a combined total of over
200 listings for exterminators,  fumigators and pest control companies. Obviously, many of
these are extremely small operations, but the main point is still valid — there is a large
number of potential sources for pesticide wastes. In no instance will an individual company
be  generating large (more  than  one million gallons) volumes of waste.  Normal business
practice would not permit 20% total wastage.

     In  addition  to the pesticide wastes  generated  by the industry during its normal
operations, there are growing amounts of waste product due to the collection and storage of
used or aged pesticide  containers. In this evaluation, these collection depots  have been
assumed to  be off-site  processors so that these wastes already fit  the "process off-site"
classification.

                                       Paints
     The U.S. paint industry is a source of waste sludge that contains a variety of heavy
metal compounds including three based on lead, cadmium, and chromium. The manufacture
of paint contributes a relatively  modest amount  of sludge  for disposal. In  total, this
probably approximates six million gallons per year. On the basis of 1970 pigment consump-
tion  by the coating industry,  this  sludge contains over 600,000 pounds of lead pigments,
150,000 pounds of chromium pigments, and about 5,000 pounds of cadmium pigments.*
About 1700 establishments most relatively small, make paint.

     The amount of waste generated by the production of paint is modest compared to the
paint sludge that originates  with spray paint operations which utilize production finishes.
We estimate that close to  100 million gallons per year of paint sludge are generated through
spray painting. The pigment content per gallon is lower than that of the sludge from paint
manufacture both by virtue  of the method of generating the sludge and the types of paints
used  for  industrial  product finishes.  Nevertheless, the  total poundage of heavy metal
pigments produced as wastes from spray painting operations is quite probably an order of
magnitude  larger than the  pigment contained in wastes from paint manufacture. Also,
considerably  more locations undoubtedly use paint than produce it, so from the point of
view of number of locations, the paint industry will probably provide a hundred or more for
each national treatment facility.
 *TRW 11th Monthly Report.
                                        24

-------
•H
 co
 to
 O
       ft
D
O
rH
       60
                    rH CM O rH  O
                           V  V
                                                              CM

                                                              CM
m

o-
                                                                                   *H
CJ
rH 3
cfl 13
4-1 O
O !-i
cn
Q)
T)
•rl
CJ
•H
4J
CO
OJ
UH
o
c
o
•rl
^J
O
3
13
O

PM
H PU

X
cn
T)
C
3
o
ft
^-X







CO
CO
LJ
C
cfl
rH
PH
M-4
O

S-i
QJ
"s
3
"Z




CO
PM
.
t~3
•









•
W
J;J

rH
CO
4J
O
H









                CO
                                                        m
                    I   I
                    I   i
                                                 00
                                                        oo
)H QJ
QJ O C!
(3 C rH QJ
Cfl -rl J2 J3
C 13 (_i f- y ft
ft "H M ^ »rl CO CO
3 M O rH VJ 4-1 X
O 13 rH CU 13 ft O
J-l rH J2 -rl C OJ H
o <; a p w a ^

n
•rl
t-J
^rj
, — |
<;
xachloride
QJ
33

QJ
C
0)
N
C
OJ







Q
i

,£

QJ
a
athion
M
Cfl
PH

rH
^
£,

OJ
2


C
O
•H
r;
4-J
cfl
^4
cfl
PH




C!
O
4J
QJ
B
QJ
P




C
O
•rl
("1
JJ
3
O
esols
^i
0

o
rl
4J
•H
0
•H
P
 I
oo
                                            ft
                                            Pu






C
o
•rl
4-1
Cfl
B

o
*4H
rj
•H

0
I —
c^
i— |
|
O*\
vO
O^
rH

C
0

13
0)
CO
cfl
FQ
1
CO
zion and Sales of Synthetic Organic Chemica
o
3
-O
O
ft

•
CO
•
( — i

*>
C
O
•H
tn
cn
•H
£
j{3
O
U

14H
t4-i
•H
p
S-i
cfl
H

•
tn
•
t3
1
,Q













•
-O
QJ

^4
0
ft
OJ
^4

c
o
•H
4-1
O
3
13
O

ft

O
•z
\
o
0)
^3
•H
CO
J~
60
•H
rC
C
O

QJ
T3

a

^
r— |
QJ
tn
o
ft
^_i
3
ft

r.
01
4-1
Cfl
6
•H
1 >
tn
QJ

,_J
O

1
T3
j bromide.
u/
0)
, — i
>i
4-1
QJ

T3
C
tfl

QJ
13
•H
^_j
O
rH
r!
O

r- 1
K^
{1
4-1
QJ
E

tn
QJ
13
3
r-H
o
c
M
1
QJ
                                                      25

-------
     Paint Industry Wastes. Total pigments consumed by the coating industry in 1970 are
given in Table B.I.3. The inorganic pigments — which include compounds of lead,  chrom-
ium, and cadmium — are principally responsible for the toxicity of paints and paint sludges.
Table B.I .4 describes the most commonly used pigments that contain toxic ingredients.

     Paint waste also contributes modest amounts of other toxic materials added to improve
stability or performance. These include phenyl mercury compounds, used as a mildewcide.
These compounds are used virtually only in water base paints in very low concentration.
During 1971, about 600,000  pounds of mercury were consumed by the paint industry.* In
addition, modest amounts of other toxic materials, such as lead-based dryer additives, are
used in  the  manufacture of  solvent-based paints. The contribution of heavy metal com-
pounds  to the paint by these additives is modest,  however,  compared to the amount of
heavy metal compounds present in the paint as pigments.

     As a consequence of paint manufacture, toxic  wastes are produced in the form of: a)
finished  paint which is  insoluble  for whatever reason; and b)  waste from washing  and
cleaning operations. Waste contained in wash solvents is eventually concentrated either by
settling or, in the case of solvent paint, by settling and distillation.

     Industry sources indicated  a very wide  range of waste in actual practice —  from one
gallon of sludge per 60 gallons of finished paint for a large plant with varied output to as
little as  one gallon of sludge  per 500 gallons of paint for small plants manufacturing a  high
proportion of the same product. There is a strong inclination, particularly among the smaller
producers, to utilize every bit of raw  material possible and, with continuous batch produc-
tion of the same product, washings normally go into subsequent batches.

     Generally  speaking, there is more waste in the production of latex paint; we have
estimated that  one gallon of the  sludge is  obtained from  the  decantation and  solvent
recovery operations for every 120 gallons of solvent based paint produced. This value is in
agreement with TRW's  11th Monthly Report.*

     Wastes from paint manufacture,  both as sludge and  finished  paint, are normally
drummed and  disposed  of in  landfill operations,  but local regulations are making  this
practice more and more difficult. There is an increasing dependence on disposal contractors
who are paid to haul wastes  away and assume responsibility for disposal. In  the past there
has been a continuous  tendency for a small paint plant to "store" its wastes for future use.
This practice has probably grown  in recent  years because of the problems presented by
disposal. Storage is used primarily with solvent paint systems since latexes do not mix arid
store well.
 *TRW 11th Monthly Report, Contract No.
                                        26

-------
                      TABLEB.1.3

  PIGMENTS CONSUMED BY THE COATINGS INDUSTRY -
                         1970*
                                              Millions of Ib
White pigments:                                     800
   Titanium dioxide                                  800
   Zinc oxide — lead free                               50
   Zinc oxide — leaded                                10
   White lead                                        10
   Other                                              5
   Total                                            875
Colored and black pigments:
   Carbon blacks                                      15
   Red lead                                          20
   Chrome green                                       5.4
   Chrome oxide green                                10.4
   Chrome yellow and orange                           63.5
   Molybdate chrome orange                           21.7
   Zinc yellow                                       15.6
   Iron blue                                          10.0
   Cadmium  red, yellow, and orange**                    0.7
   Other inorganic colors                              116
   Organic colors                                      12
   Metal!ics (aluminum pastes, etc.)                      20
   Zinc dust                                          50
   Total                                            367
Extenders:
   Calcium carbonate                                 350
   Magnesium silicate (talc)                            330
   Clay                                             280
   Barium sulfate  (barytes)                            100
   Mica                                              60
   Others                                           200
   Total                                          1,320
Total pigments and extenders                        2,562
**Taken from TRW 11th Monthly Report, Contract No.
**The estimates are based on the assumption that 25 percent of the
  cadmium pigments produced is consumed by the paint industry.
  Consumption figure of 0.7 million  Ib is as the cadmium metal.
  About 51,000 Ib of selenium are used in the cadmium pigments.
                          27

-------
                   TABLE B.1.4

              PIGMENTS CONTAINING
              TOXIC INGREDIENTS*
   Pigment                      Toxic Ingredient

White lead                      lead

Leaded zinc oxide               lead

Red lead                       lead

Cadmium yellow                cadmium

Cadmium orange                cadmium, selenium

Cadmium red                   cadmium, selenium

Chrome yellow                  lead, chromate

Chrome orange                  lead, chromate

Zinc  yellow                    chromate

Molybdate  orange               lead, chromate

Chrome green                   lead, chromate, cyanide

Chrome oxide green              chromium oxide

Iron  blue                      cyanide


"Taken from TRW 11th Monthly Report, Contract No.
                       28

-------
     During 1970, 830 million gallons of surface coating materials were produced in the
United States. Of this total, 540  million gallons are estimated to have been solvent-based
and 290  million gallons water-based paints. On the basis of our previous assumptions of one
gallon of sludge generated for every  170 gallons  of water-based paint and for every  120
gallons of solvent-based paint, on average, the manufacture of paint generated approxi-
mately six million gallons of sludge per year on a national level.

     As  shown  in Table  B.I.5, the paint industry is not concentrated very highly; it is
characterized by a large number of small plants with relatively small annual production. Of
the 1700 establishments listed by the Bureau of Census in 1967, only an estimated 10 of
these produced  more than  10 million gallons of paint per year, while over half of them
produced less than 200,000 gallons per year. Consequently, the six million pounds of paint
sludge produced annually are dispersed broadly over a number of small producers. As shown
by Table B.I.5 more than 1000 of the 1700 establishments would produce  less than 1500
gallons of sludge per  year. Even the largest producers will generate a relatively modest
amount of sludge for which they have no totally satisfactory means of disposal.

     The  paint  industry  in Pennsylvania and  New  Jersey includes 266  manufacturing
establishments, or  15.6 percent of the nation's total paint producing plants in 1967. These
plants, however, are somewhat larger than the national average. In 1967, the average U.S.
paint plant shipped products valued  at  $773,000. In Pennsylvania and New Jersey the
average in that  year  was almost  three times as great  at slightly less than $2 million of
product.  Pennsylvania and New Jersey, therefore,  appear to represent a geographic area in
which the disposal of toxic waste from paint manufacturing would be a significant problem.

     Spray Painting Wastes.  Industrial spray painting generates  significantly larger quanti-
ties of toxic paint waste  than does the manufacture of paint. In 1970, an  estimated 330
million gallons of product finishes were produced  and the great  majority of these finishes,
perhaps as high as 90 percent, were applied by spray painting.

     We estimate that on average,  one gallon of sludge is generated for each three gallons of
product  finish  supplied by  spray  painting.  It is believed, therefore, that industrial spray
painting generated about 100 million gallons of sludge in 1970.

     Paint loss in the spray  painting process varies tremendously, the amount depending on
the objects being painted and the technique used. Electrostatic painting techniques and the
use of airless equipment tend to reduce loss, and in some instances,  losses are as low as 10
percent of the total paint  utilized. When objects with small surface areas (compared to the
total spray pattern) are being painted, losses can run as high as 80 percent of the total paint
utilized. Normally, any spray that does not adhere to the object being painted moves into a
water-wash spray booth and is carried down  as sludge. This sludge  is then  scraped off or
skimmed off and put in barrels for disposal.
                                        29

-------
                            TABLE  B.I.5

              Estimated U.S.  Paint Sludge Production
                          By Company  Size


(thousand gallons/year)
Per-Plant Paint
Production
Number of Establishments
468
242
311
350
171
113
36
8
2
24
81
171
382
400
2,090
4,600
10,900
25,400
                                                         Per-Plant Sludge
                                                             Production
                                                              .17

                                                              .58

                                                            1.2

                                                            2.7

                                                            2.9

                                                              15

                                                              33

                                                              78

                                                            180
SOURCES:   1967 Census of  Manufactures  and Arthur D. Little, Inc., estinato
                                    30

-------
     Spray painters have the same disposal problem as paint manufacturers. Normally, the
company  performing spray  painting will pay a contractor to pick up the barrels of sludge
and he in turn disposes of it in landfill projects.

     Spray painting,  and consequently generation of paint sludge,  is even more widely
dispersed than the manufacture  of paint. Producers  of automobiles, wood furniture  and
fixtures, metal containers, metal furniture and fixtures, appliances, machinery and equip-
ment,  factory finished wood and  non-automotive transportation  are  all  major  users of
product finishes applied by  spray painting. Paint sludge is quite probably generated in tens
of thousands of individual locations  and in individual amounts varying from  hundreds of
gallons per year to hundreds of thousands of gallons per year.

     It is  estimated  that Pennsylvania and New Jersey are  also major producers of waste
paint sludge from  spray painting. These two states accounted for close to 12 percent of the
total value of shipment of manufactured goods as reported by the Bureau of Census.  Our
best estimate  is that the  generation of spray painting waste would be proportional to the
national figure on the same basis and that Pennsylvania and New Jersey  would generate
about 12 million gallons of spray painting sludge annually.

     All of the spray painters face the same problem of disposal in varying degrees. As with
the paint industry itself, there is  no satisfactory means of handling spray paint wastes.
Wastes discarded in  landfill operations often contain toxic ingredients that could lead to
contamination of ground water and soil. As it becomes more broadly recognized and rigidly
controlled, the industry faces increasing  problems of disposal without, as yet, any satis-
factory solution.
                                        31

-------
            WASTES CONTAIN ING HEAVY METALS AND/OR CYANIDES

     All  Category I  metal-containing wastes  are  included  here except:  wastes that are
primarily organic but also contain metals (paints, pesticides, etc.), and sludges with organics.
The  industries that generate most of these wastes are:  tanneries, metal finishing,  batteries,
mining and smelting, cooling towers, and chloroalkali plants.

     With the  metal-containing waste streams, three basic  waste  forms were considered:
dilute heavy metals, concentrated heavy metals, and dilute heavy metals containing organics.

     Sources with dilute  metal wastes will be  found in many industries such as:  metal
finishing, tanning, battery production, refining, etc. In most  cases, the volumes of water are
well  above one million gallons per year so  that  on-site treatment should be attractive. In our
field study, only  a few sources were identified as ones which might ship the dilute aqueous
waste (two metal finishing, no tanneries, and possibly one battery manufacturer). However,
a large number of potential sources were  identified as having a potential need for sending
sludge or  concentrated  wastes to a  central  processor  (300  metal finishing plants, 70
tanneries, plus many cooling towers, several dozen smelters, etc.).

                                    Electroplating

     Industry  Statistics.  The  electroplating metal finishing  industry is divided  into two
major segments, contract or job finishing  plants which primarily process material owned by
others and captive plating plants set up in manufacturing establishments for finishing their
own products. Although no exact figures  are available, the two segments are considered to
be about equal in number of establishments. The  latest data available  on the contract
portion of  the industry are for  the year 1967 (Table B.I.6). Data for  1972 are being
compiled by the  Commerce Department but will not be published until 1974. In 1967 the
total number of contract establishments reported was 3235, of which 853  had 20 or more
employees. From the growth rate indicated from the 1958 and 1963 census, we believe the
total number now is in the order of 3500, of  which about 1000 employ at least 20 people.

     No  equivalent statistics are available  on  captive plants but assuming the job  plating
shops  are one-half the total, we  estimate the  United States  has 7000  plating plants —
contract  and captive -  at present. (Other estimates placed the total in  1968 at 15,000 to
20,000 facilities,* but we have chosen to use the more conservative number.)

     From a review of the plating establishments in the New Jersey and Pennsylvania area,
and extrapolating from the  1967  census, we estimate that in 1972 New Jersey had 162 job
plating shops and Pennsylvania 134. Of these  49 and 40, respectively, employed more than
20 people.

*State-of-the-Art Review of Metal Finishing Waste Treatment, Water Pollution, Control  Research Series
 12010Ele 11/68. U.S. Department of Interior, Federal Water Quality Administration.

                                         32

-------
                                 TABLE B.I.6


                 Number of Establishments by  Geographic Area



                     Plating and Polishing.   SIC Code 3471
Geographic                     Total               Establishments with
Area	                       Establishments      20 employees  or  more
Total U.S.

East North Central

Middle Atlantic

Pacific (including Calif.)

Pacific (California only)

New England

South Atlantic

West South Central

West North Central

East South Central

Mountain
3235
1098
680
548
502
367
157
138
129
67
51
853
321
168
137
127
96
32
32
33
21
13
SOURCE:  U.S. Department of Commerce, U.S.  Census of Manufactures,  1967
                                     33

-------
     We  have assumed  that  the  materials and  volumes of wastes generated in  job  shop
operations  are quite similar to those encountered in captive plants although  there may be
more extremes in the size of parts plated in the captive plants - from common pins to large
rolls of sheet stock. The total effluent volumes, therefore, will be double that calculated for
contract plating shops.

     Source and Character of Plating Wastes. The most important source of plating wastes
is the rinse water which is used after every processing step in the plating cycle. Since water
usually flows constantly through the rinse tanks, the volumes involved are very  large and
transportation to a  central disposal facility without  concentration of some kind seems
impractical  except  for  the very  smallest units. Historically,  very large volumes of  rinse
waters were  used by platers to ensure  quality finishes and to dilute contaminants to an
acceptable  level,  and little attention was paid  to  conserving water.  In  the last decade,
however, water  conservation  and  treatment  of effluents to remove  contaminants  have
become necessary not only for economic reasons  but because of environmental concerns
and  pressures. The  emphasis today, therefore, is on saving water  through  counter-current
rinsing and  recycling techniques and some compromise with the quality of finish - which
is affected by rinsing — has to be tolerated.

     The composition of  waste rinse waters may vary  widely from shop to shop and even
from hour  to hour  in the same  shop,  particularly in  the  smaller facilities.  For instance,
information  from five plating plants shows variations in concentrations of cations in  their
rinse water of: 15-300 ppm Zn, 5-22 ppm Cr, and  10-100 ppm Cd. Many  other  cations -
such as Ni, Cu, Pb,  and Al - are present in variable amounts in most effluents  depending on
the metals  being treated. Although strictly not  in this category, cyanide is an integral part of
the plating industry. It will vary from 0 to 500  ppm depending on the  bath. Sludges from
filters in  the operating cycle and  from the treatment of waste rinse water represent another
significant  source of concentrated wastes  which  may be even more variable in composition
than rinse water.

     We have attempted to estimate within an order of magnitude  the sludge volume which
might be produced  as a function  of rinse  water volume. Much  of these sludges eventually is
transported from the plating plant, either directly after  consolidation by  filtering, settling or
centrifuging, or after settling in outdoor lagoons or ponds for extended periods.

     Another source of wastes is  the discharge of plating or finishing baths from the  plant
into the  effluent, either intentionally or by accident. If a treatment plant  is  provided, the
contaminants are removed and eventually end up in the sludge.  In most cases, it would be
practical to ship the discarded concentrated plating baths to a central disposal  area since the
volumes are relatively small.

     Other sources of wastes are equipment cleaning, vent scrubber waters and concentrated
regenerants from ion exchange units.  These materials also probably would end  up in the
sludge of a treatment plant, although  they could be segregated and shipped  to a disposal
area.

                                         34

-------
     Treatment of Wastes. Rinse waters which are to be  purified and generally segregated
into at least three streams: cyanide containing wastes, chromate wastes, and waters contain-
ing other heavy metal ions.  The latter streams may be combined with acid-alkaline waste
streams to neutralize and precipitate the metal hydroxides. Waste treatment details for these
materials  are well covered in the literature and will not be repeated here.*  If rinse waters
were to be transported to a central processing station, the same separation of streams still
would be required.

     Although  the  shipment of large volumes  of dilute  wastes  seems impractical, some
combination  of segregation,  concentration and recycle might be  less  costly  than complete
treatment at the  plating plant.  A complete recycle of water and chemicals  by evaporative
recovery or possibly by reverse osmosis seems a possible answer to  waste  control  in the
plating industry, but this approach is  not feasible or economic for all plating  baths or for all
installation sizes. Impurity  build-up  is an important factor to be considered  in applying
complete  recycle  of plating material  and wastes. Complete recycle of plating drag-out and
rinse water appears applicable to only a few more favorable situations and some contamin-
ated effluents will always be discharged from the average plant.  However, as  contaminant
limits are regulated more severely, the destructive methods of control  will become more
expensive and  perhaps not  applicable, so  recycling will  become  more attractive. Unless
transportation and treatment costs at central stations can be made competitive,  it appears
the trend will be  toward more and more recycling and reuse of rinse waters. Therefore, the
installations of large central process  stations that might  depend on plating wastes should
take into account these trends.

     Because of the high cost  of cyanide  destruction plating companies are turning more
and more to non-cyanide type  plating baths. For instance, there is a definite trend away
from the high cyanide zinc bath to either a low cyanide composition or an alkaline or acid
type bath without cyanide.  The same trend is noted with respect to  cadmium and gold
plating. Therefore, the volume of cyanide wastes emanating from metal finishing plants is
bound to decrease at an accelerated pace. Complete elimination of cyanide is much further
away since no practical substitutes for the widely used cyanide  copper strike on steel or
zinc-base diecasting basis metals, nor  for plating brass, bronze or silver have been developed.

     Volume of Effluents in the New Jersey — Pennsylvania Area.  As noted above, we
estimate there are 296 job plating shops in the New Jersey and Pennsylvania area  divided as
shown on the following page.
'Ceresa, M., and Lancy, L.E., "Waste Water Treatment," Metal Finishing Guidebook and Directory for
 1972, Metals and Plastics Publications, Inc., Westwood, N.J., pp. 761-783.
                                         35

-------
                                  Total                    Plants Having
                              Establishments            20 or More Employees

       New Jersey                  162                         49
       Pennsylvania                 134                         40

     From  a review of rinse water volume data from 30 small, medium, and large plating
facilities (Table B.I.7) we estimated the median volume of rinse waters in the larger plants
to be 20,000 gallons per hour and  4,000 gallons per hour in the remainder. Rinse water
volumes in individual  plants ranged from 960 to 318,000 gallons per day. The total rinse
water volume from all job shops in  these two areas, therefore, would be about 21 million
gallons per 8-hour shift.

     A review of the volume of rinse waters containing chromates and cyanides produced in
15 captive plants is given in Table B.I.8. Most of these plants were considerably larger than
the job shops we reviewed, but  the  average water volume  was about the same, 20,000
gallons per hour (for large shops). Assuming about the same distribution of small, medium,
and large captive  plants as job shops, the total rinse water volume in the New Jersey and
Pennsylvania area is on the order of 40 million gallons per day.

     Data from one plant provided some indication of the sludge volume which may result
from treatment of waste water containing Cu, Ni, Cr,  Cd, Zn, Pb, and cyanide contaminants.
The rinse water volume  in this plant was about  12,000 gallons per day and it accumulated
50 to 75 gallons per day of sludge containing 17 percent solids. This is equivalent to 0.4 —
0.6 percent of the total rinse water. Using a range of 0.05 to 0.5 percent for the total sludge
volume that might be expected from  treatment of  all  the rinse  water in New Jersey and
Pennsylvania plating plants, we estimate total volume of sludge from the rinse water from
both job shops and captive  plants would be 21,000 to 210,000 gallons per day. Volumes
from individual plants might range from less than a gallon to 5,400 gallons per day.

                                The Tanning Industry

     Character  of the  Industry.  The  hazardous material found in  tanning  effluents is
chromium. The  1967  Census of Manufactures  lists 519  leather tanning and  finishing
establishments, of which only 258 employ  more  than  20 persons.  The total industry
employment is given as  30,700, including 26,400 production workers. While the number of
tanneries has undoubtedly declined since the  1967 Census,  the  geographical  distribution
indicated in Table B.I .9  is probably still valid.

     The chrome  tanning process is used in virtually all  tanneries at present. The major
exception to chrome  tanning is sole leather,  most of which is still vegetable tanned. One
West Coast tannery does vegetable tanning exclusively, and a  few small specialty operations
use other types of tanning.  Deerskins, for example, may be oil tanned, and  a Tennessee
                                       36

-------
s -
«
> 4J M -H 4
•H m o o
u cd iH o 7

H 3 =
o w "-> -
Q. W CO


: PM n)

O rH - &
r-H i— 1 O
co to r- 1-1
•rt ,0 i-H CJ
S3 0>
OK - "H


CJ 0) t C!
W > rH OJ

• SG X IjJ
E -O E S
» d •«;
n to *

§- 0) CJ •
ffl 4J d d
^ -H 4J CO QJ d
P! n o -y tu <3
d u d o X-H
U 1 C cd 4-> A 3
.a o ra rH c i-i o
S o o. g 01 o
u ai • u-. *j n *o
Su oi o d S G
n) •  t« >, V. -rH
•H U H 0) 00
CM r< - o) w d
 P- Q > CO CO W
i-H rH O 4-J i-H
,J rH U CO rH ft
<*T 9 5 & £ S 55
CN f) •*.
-1
0 O
J 00
s 3
•H

CJ
d >>

w •
d -^
O CM
•rl r^


^-> oo n
rH CO 3
i- ft! 00

* -H
tH 4J r-»
H) 3
"i rH GO"
d/ O

S5 OOrH 0
^5-2
CM 4-»4-l Cfl
4 | | §
rH " 00 B
o\ pa « u
^ 3" * to

00 - co rt
d t) rJ >
•H h to -H
J! O J3 H
co tw m fx.
iH a iH
S 25 | |
^ m vo r-
rH rH {3
r r- oj to

U rH 4) 01
d c oo

•o § ,c" "a d
d 4-i y 0) cd
co n w ax
cd Q ;

C at -^ - ca
S " ^


n c cm
ai -H - O -H

•rt « CO FXI
4J d 
o S 0 . d ss
" j§ c° tC oi: "s

• O CO O
pj ,-4 • 4-1 «H

(j a; jj o) o "
QJ > 4-1 t-i -iH r-. tj
coo qj 4-1 5
3 GOO) T3(d"-<
t -rt.cU.-i CN\O 2
CL, OJ CJ «C -H rH I
oo ^ c












- . i


r-.

rH
u
JS
3
01
ex. oo
0* rH
c/i d
^ o
•> 4-1
I-H a
•rl U
* C -H
os 3 o
I*N O O.
a)

d cd os
0) >
S iH -
0) rJ V4 4
H 00 (Li 0)
y i ii






i

















c
4J
n)
f-t
I


ret
tH
3 !-•
1 &4
i § I

CM
T3 r~
n) OOrH
d
rH -H -
OJ -G *
U CO -Q
•H -H tO
4J d rK
SiH •*-•
Eh
rJ C7>
ft4 rH CM
= Q rH
4J
* r§ CM*"
Q

• O en
J3 S tn
u S
nj o -
rl O 00
w d
X W 4-1


R 0>
fl J= =
*iw a
3 O 01
- C CO
OJ O t-i
rfi -H
Q 1-1 4-1
z n d
-i-S
. 5 S
w u «
D
rJ U rl
-H E-"
' S
X O 01
U C 4J
C 0 CO
m cj co

                      -g
                                 8   8
                    37

-------
38

-------




















00
CO
UJ
m
H





























"j
O
cT
^_
P~
5
o
cc
u.
CO
UJ
CO

g
Z
E
UI
CO
UJ
o
I
u
o

1
D
CC
I
o
u.
o
CO
U)
5
D
O
>
















*
cc
^
CO
O
z
o
z
H
_l
Q.
0
CC
u
UJ
UJ
UJ
X
z
"•
CO
o
5
cc
a.
O
o
z
p
^

Q.













s
&
s
a
e


|
&







»
1
ex
•c
ium-Bea


u




















To
"E
a
a
«
%
1
k



aT
"5
^


"3
"%
E

To
c


i
"5
















S



N

3



§


•!"
^
*^


<3

z

o


(0
XI
I







-o
£
(0
a.
^^
|
•5
a


1 1 1 1 1 1 1 1 1 1



1 1 1 1 1 1 1 1 1 1

1 1 1 1 1 1 1 1 1 1


o
o
in
1 1 1 O 1 O5 1 «— I I
i i i oo ' co ' <•;, ' '
CN

O O O O O O
CO O O O O O
^ i i °. i i °. ^ P. P.
CO ' ' CN ' ' CO 05 00 «-
CO CO t- LO O <-
CM CM i-


1 1 1 1 1 1 1 1 1 1

1 1 1 1 1 CO 1 1 1 1

O •- CO
11° 1 "~ 1 1 1 1


oooooo oo
CDOOOOO OCM
o o" o" o" TJ-" o" ' oo" co" '

I
a)
p
.a
y> '5
4J cy

l|
01 TO +3
t EC
S « 8
a in 0 u
73 Jjj jg "D a> jg

 3 ^ QJ *~*
^ ^ ^ S O H™ -™ I_M H ^
1 1 1 1


«— CO
«- 1 r- 1

S° 1 1 1



P! i § i
r- CN


o o
o o
in o
CD «-



in o .

S 1 § 1

in o
1 " 1


III
O" CN O" '
rt «- CN
r- CO


^
8
u

• —
i=
S
a> £
•a 2
t- Q
(/> **-
2 i
o 2
1 E
<- - P
^ — .— (D
111!
-^ *-< +-* w)
-2 w 3 C
W £ < ^
1



1

1



1


|




1

CN
O
CO

CN
in


o
o
o
en
00










c
ro
a.
fc
I
J
a>
"o
a
cu
Q
CO
^
S
7i
*~
UJ"
UJ
0
0
CN
CO
'i
in
1
CO
8
Qv
£T
1
C
o
CJ
c
o
^
"o
0.
CO
^

§
5
O)
c
'E
iZ

1
s
•£
^t—
|
.2^
§
cr
k_
<
i
5
H^-
o
2
CD
•M
CO
<
*






















d
CN

Q_
.2
™
2
.t£
'c
"D

^
"53
3
a
te
ro
"co
L
0)
•D
0)
LL
t-.*"
,2
*c
s
c
0)
€



























ai
J3
_co
'ra
e?
4_*
o
c
ro
1
^:
ty)
4-J
O
C
to
s
^•
CO
<
"io
39

-------
                               TABLE B.I.9
                Geographical Distribution of U.S. Tanneries
Region
New England
Middle Atlantic
State
                   Mass.
East North Central
West North Central
South*
West
No. of Tanneries
                    183
                    176
                          146
                                  Total 519
No. of Employees
                             9,700
                             6,700
                                    5,900
N. Y.
N. J.
Pa.

Wis.
111.



Gal.
108
48
20
74
30
19
13
47
26
15
2,500
2,300
1,900
8,200
4,400
1,700
800
4,600
800
700
*Small tanneries are located throughout the south in Del., Md., Va., W. Va.,
 No. Car., Ga. , Ky. , Tenn., and Texas.

SOURCE:   U.S.  Department  of Commerce, Census of Manufactures, 1967.
                                     4Q

-------
tannery which manufactures a very  white leather for baseballs uses zirconium tanning. In
1967,  the  value  of all tanned and finished  leather was  $846.2 million, while that of
vegetable tanned sole leather was $86.7  million, or roughly 10 percent of the total.

     Source and Character of the Waste.  Hides are  normally  received in the green-salted
condition. They  are salted at the slaughterhouse, stacked, and tied with twine for shipment.
The  chrome tanning process is shown  schematically in  Figure B.I.I. All operations up to
and  including  the  chrome tan step might  typically be done in a single cylindrical rotating
mill, 10 feet long and 10 feet in diameter. The mill is loaded with about 9,000 pounds of
hides, and the required solutions for each  operation are  added  successively and drained out
when that operation is completed.

     As indicated  in the flow diagram, the hides  are washed and soaked to remove blood,
dirt, dung  and free  salt and to  soften the  hide. Muscle  and fatty  tissues are removed
mechanically in  the  fleshing operation, if necessary. In modern practice, the green-salted
hides have already been fleshed. For the liming operation, a suspension of lime hydrate and
alkaline reducing agents, such as Na2S, and amines, as accelerators, is introduced to loosen
the hair and epidermis and to remove grease.  In "bating," a solution of proteolytic enzyme
(pancreatin  or trypsin) and an acid salt (e.g.,  [NH4]2SO4)  are introduced to remove
absorbed lime and to hydrolyze  undesirable proteins.  Pickling involves a soak in 0.75
percent H2SO4 and 5-8 percent NaCl to bring the hides to the acid condition necessary for
absorption of  chromium.  Finally, the  chrome tanning solution, typically a basic chromic
sulfate or chromic  chloride, is added on balance. The wastes from the processes described up
to this point  are  alkaline.  The coloring and fat liquoring are done  in acid  solutions. A
separate mill is typically used and the waste stream is kept apart from the alkaline tanning
wastes.

     Treatment of the  Waste. At present, waste streams are either allowed to flow un-
treated into a municipal  system  (or other water receiving system)  or  the chromium is
precipitated and landfilled.  The  latter may  be a separate operation  or  an addition to a
municipal (or private) landfill facility.

     Volume of Effluent. About  1,000 pounds of hides are tanned per mill, with a total
water volume of 8,000-10,000 gallons being consumed in the process. Assuming segregation
of the  chromium effluent, the volume of hazardous waste would be about 4,500 gallons per
1,000 pounds  of hides. If the chromium effluent is not segregated (as is the case more often
than not),  the volume of waste would  be 9,000 gallons  per 1,000  pounds of hides. In the
simplest case,  therefore, where a tannery  operates one mill daily, the daily waste effluent
would  be  either 4,500 or 9,000  gallons (1-2 million gallons/year). Such a tannery would
have only a few employees  and probably not be representative. An average tannery might
have 3-5 mills in operation.

     Estimates of effluent volume for various production volumes are given in Table B.I. 10.
The  major conclusion drawn from this  data is that the waste water volumes tend to be very
large and thus require some form of pretreatment prior to shipment to a processor.

                                        41

-------
Hides
 I


Intermittent
Wastes



Wash and Soak

Lime


Ha
\
te
f
Pickle


\

x 1
^j
Fie
cth

^^ ^

s ^
Unhair 0
v


Wasl




1 c
> 1 — i




Color
Fat Liquor
1
Finish


\
1

r
i
hrome Tar
\

Wash and
Neutralize
•>

X.
Exterior Waste
i

>,

5S
^
Intermittent Wastes
                    FIGURE B.I.I




            The Chrome Tanning Process
                          42

-------
                                 TABLE  B.I.10

                              Tannery Wastes
                                      Yearly Waste water Volume  Yearly Chromium
                                      	(106 gallons)	Waste	
No. of            Hides Tanned        With  Chromium                          Sludge*
  Mills            per Day*	         Segregatedt     Total^     Amoun_t=    Volume
                  (103 pounds)                                  (1Q3  pounds)  Gallons  xlO


   1                   5                  4.5            9           10         15

   2                  10                  9             18           20         30

  1C                  50                 45             90         100        15°

  20                 100                 90            180         200        30°
* - ADL estimate.
f - ADL estimate based on 4500  gallons per 1000 Ib   of hides.
$ - Based on 9,000 gal/1,000 Ib   hides and 200 eight-hour days.
§ - Based on 10 Ib   chromium effluent per 1,000 Ib    hides.
H - Assume 7.5 gallons sludge from 10,000 gallons effluent.
                                       43

-------
     Assuming precipitation of the chromium prior  to  shipment,  one can expect  5-20
pounds of chromium per  1,000 pounds of treated hides. Thus, as shown in Table B.I.6,
sludge volumes probably will be less than 100,000 gallons per year except for very  large
tanneries.

     There is some variation in the available data as to how much chromium will be found
in the effluent per  1,000  pounds of hides processed. For example, in an industrial v/aste
study of the leather tanning and finishing industry (Contract  No.  68-01-0024, October,
1971, Water Quality Office), Stanley Associates collected  data on the chrome effluent from
a number of cattle hide, sheepskin, and pigskin tanneries. The total chromium output varied
considerably from one plant to another, with a range of 1 to 67 pounds of total chromium
in the waste  stream per 1,000 pounds of hides processed. The average value was about 6
pounds/1,000 pounds green salted hides.

     During  a visit to a pigskin tannery employing about 100 people, we learned that at full
capacity the  tannery processed almost 65,000 pounds of pigskin each day. To  accomplish
this, it utilizes 2,250 pounds/day  of chromium in the chrome  tanning step. The effluent
from the chrome  tanning  tank contains about one pound of chromium per 1,000 pounds
processed hides.

     Activated  sludge  treatment  of chrome  tannery wastes  was  studied by the  A.C.
Lawrence  Leather  Company  for its  South  Paris, Maine,  tannery (Grant  No. WPRD
133-01-68, September, 1969). In  conjunction with that  work, chromium analyses of the
total waste water discharge were made over a 48-hour period. The results are shown in Table
B.I ,11. The tannery employs about 220 people. The average chromium concentration in the
waste water effluent is somewhat less than 2 pounds/1,000 gallons.

     In cattle hide  tanning, which accounts for  80 percent of the industry volume,  total
waste water  flow averages 8,000-10,000 gallons/1,000 pounds  of green salted  hides pro-
cessed. The chromium effluent averages 5-20 pounds/1,000 pounds of green salted hides or
0.5 — 2.5 pounds/1,000  gallons  of waste water. If these  three tanneries surveyed are
representative of  industry,  roughly 500,000-600,000 pounds/day  of  green salted  hides
would be processed per 1,000 employees.

                                    TABLE B.I. 11

                 WASTE WATER DISCHARGE FROM THE A.C. LAWRENCE
            CHROME UPPER SIDE LEATHER TANNERY IN SOUTH  PARIS, MAINE

     Waste Water                   Green Salted Hides
        Flow                         Processed                    lbCr/1,000 Ib hide
      (gals/day)                          (Ib)

       911,000                        90,000                           21
       958,000                        121,500                           15
       934,000                        105,750                           17

                                        44

-------
                     Cadmium Wastes from Battery Manufacturers

     Introduction. In the United States 10 nickel-cadmium battery manufacturers generate
wastes containing cadmium. Two of these — both in New Jersey - fall within our primary
area for field investigation. The waste water volumes for all 10 are less than a million gallons
a year so shipment to a central processing facility might  be feasible in each case. However,
the cadmium tends  to be present as suspended solids  and recovery by centrifugation is
readily achieved. Therefore, in view of the small number of plants and the strong likelihood
that many will treat the waste themselves for economic reasons, these battery manufacturers
are not expected to be a major factor in a National Treatment System.

     This section describes briefly the manufacturing processes for the negative  (cadmium)
plates of nickel-cadmium batteries. It identifies those steps in the process in which cadmium
losses occur  and  assesses  the efficiency  of recovery in  normal practice. The difference is
assumed to be the quantity to be treated in the waste water.

     On the basis of informal  discussions of the problem with manufacturers, we estimated
the quantity  of waste water as a function of production capacity. From this information we
than  assessed the annual effluent disposal requirements in the nickel-cadmium battery
industry as a  function of its locations in the United States.

     Manufacturing Processes  for Nickel-Cadmium  Battery_Plates._ There are two types of
nickel-cadmium  battery plates, the sintered plate and the pocket plate.  In the former, the
active material, cadmium hydroxide or nickel hydroxide, is deposited chemically in a highly
porous nickel sinter. In the  pocket plate battery, the active material is packed mechanically
into a  perforated  cylinder of nickel plated steel.  The  methods of manufacture  are quite
different and will be discussed  separately.

     The process for sintered plates is set out diagramatically in Figure B.I.2. Initially, the
porous nickel sinter — in strip form or precut to plate size — is vacuum impregnated with a 2
molar solution of cadmium nitrate containing some nitric acid. The nitrate is then converted
to the hydroxide either by drying followed by immersion in 40 percent potassium hydrox-
ide  at  80 C (SAFT  process)  or  by immersion  without drying but  with simultaneous
cathodization at  150 milliamps/cm2 (Fleischer process). The impregnation and conversion
steps are repeated up to five times to obtain the required amount of cadmium  hydroxide.
The plates are washed and dried between each cycle, and particularly after the final cycle
where the  objective  is to remove all residual potassium hydroxide  and cadmium nitrate.
Carbonate  ions formed from  the  hydroxide ions and nitrate ions are very detrimental to
battery operation and  this necessitates the thorough washing. It is also important to avoid
contamination with  calcium and magnesium ions; for  this reason  it  is essential  to use
deionized water.  This  introduces an economic constraint on  the quantity of wash water
used.
                                        45

-------
                 PROCESS STEPS
                Vacuum
              Impregnation with
                Cd(N03)2
  Up to
five cycles
       V
                Conversion to
                  Cd(OH)2 in
               40% KOH at 80 C
                 Washing and
                Surface Scrubbing
                       _y
                  Formation
"hashing and
Surface Scrubbing
                                  RECYCLED CADMIUM
                                       LOSSES
                                                     Acidified
                                    Cd(OH),
                                    sludge
                                                     Settled
                                                     Solids
                                    Cd(OH)2
                                    solids in
                                    suspension
Cd(OH)2
solids in
suspension
                                                                               CADMIUM IN
                                                                               EFFLUENT
                i \
                                                                            7
Fines in
Effluent
                                         FIGURE B.I.2

                    Manufacturing Process for Nickel-Cadmium Sintered Plates
                                           46

-------
     The fully impregnated  plates are scrubbed during the final wash process to remove
loosely adherent cadmium hydroxide on the surface of the plate.

     There are minor variations to these processes  in which  the  cadmium nitrate or
cadmium  formate  is partially  decomposed  thermally before immersion in potassium
hydroxide. In this action cadmium vapor, particularly from the formate, is vented to the
atmosphere.

     Prior to assembly into cells the plates are exercised or formed in dummy battery packs.
After formation these packs are disassembled  and the negative plates again scrubbed and
washed in deionized water.

     The sources of cadmium losses, i.e., that quantity of cadmium that is introduced to the
process but does not end up in a battery plate, are:

     •   The cadmium hydroxide sludge that forms because of precipitation outside
         the  pore  structure of the sinter in the  potassium  hydroxide conversion
         process;

     •   The wash  water used during scrubbing after the impregnation process;

     •   The wash  water used during scrubbing after the formation process; and

     •   The trim waste  when plates cut from a continuous strip are trimmed to size.

     These losses are  estimated to amount to as much as 50 percent of the cadmium that
ends  up in  the plates. The  sludge would account for 35  percent of  the loss and the
scrubbings about 15 percent. It is difficult to assess  the cadmium lost in trimming but this
waste does not constitute  liquid effluent and is easily  disposed of.

     Since cadmium is the  most expensive component in the cell, every effort is made to
recover as much as possible. This is relatively easy with the sludge which may be redissolved
in nitric  acid and added  to  the  impregnation bath. There may be circumstances,  such as
accumulation of impurities or shutdown, when this recycling process is  broken, but what
remains is  a solid waste disposal  problem that is  relatively straightforward  because the
cadmium hydroxide is highly insoluble. This high  insolubility also insures that the soluble
cadmium  component in  the  effluent  is less  than  1-2 ppm; however,  suspended solids
(cadmium hydroxide) can dissolve quite readily in the presence of a complexing component
such as ammonium ion or in a low pH environment.

     The suspended solids in the wash water could account for losses of as  much as 15
percent of the total  cadmium utilized, and it is unlikely that this quantity  would be reduced
significantly by filtration or settling. Typically, for a plant  capable of producing 10,000
ampere-hours of plate material  per day,  the  wash water would carry  off 4 pounds of
                                        47

-------
cadmium per day as suspended cadmium hydroxide. This quantity is large enough to make
centrifuging an economically attractive means of eliminating almost all the  solids content,
particularly  since the  volume  of wash water is small, about  3,000 gallons/day.  However,
wash water is not treated routinely.

     The processes  for pocket plate manufacture are quite different from those for sintered
plates. One  involves the electrolytic coprecipitation of cadmium and iron  sponge; the other
involves the dry mixing of cadmium oxide or hydroxide with iron sponge  in an edge runner
mill. In the  coprecipitation method, the active mix is washed extensively with water, which
carries off some cadmium and iron sulfate. After the material is washed,  it is pressed  into
cakes which are subsequently ground in a ball mill  with a small  quantity of paraffin to
reduce  the  quantity  of cadmium  dust. The ground material eventually  is packed  into
perforated steel envelopes to  form the pocket plate. The  plates are formed in  a manner
similar to that used  for  the  sintered plates  and are  subsequently  washed. The loss of
cadmium hydroxide is significantly less in this case.

     Though it has not been possible to obtain any firm figures for cadmium  losses in
pocket plate manufacture, it  is an  inherently cleaner process than sintered plate manu-
facture. The level of cadmium in the effluent from such a process is critically dependent on
the cleanliness of the housekeeping operations. All soluble cadmium can be precipitated as
the hydroxide if the wash water streams are treated and a very high percentage of the solids
can then be removed, resulting in very low cadmium losses.

     Location and Effluent Levels of Nickel-Cadmium Battery Manufacturers. Of the 10
battery  producers,  seven manufacture  sintered plates. These 10 companies  are located
throughout  the United  States with one in Massachusetts, two in New Jersey, three in the
Southeast, one in the Midwest, one in Texas and two in the Far West.

     Our estimates  for the volume of effluent from the sintered plate operation range from
40,000  to  900,000 gallons/year  with an average of 450,000 gallons/year. Although the
specific level is not known, the waste effluent from the  three pocket plate manufacturers
should be less than  that for sintered plate. The cadmium losses are primarily as suspended
solids since  the solubility  of cadmium hydroxide is less than 2 ppm at pH 8 and 25 C.  The
effluent will also contain potassium nitrate and potassium carbonate, possibly up  to 1,000
ppm for each component.

     As noted earlier, the quantities of effluent are small because of the requirement to use
de-ionized  water.  With  no treatment  beyond a settling  tank, it is estimated  that the
suspended solids  could  account for  losses of up  to 20 pounds/day of cadmium from the
larger manufacturers. These losses  can be virtually eliminated  by the use of a centrifuge to
collect the fines generated in the scrubbing process.
                                        48

-------
             Other Sources of Waste Water Streams Containing Heavy Metals

     In  addition to those in  the  three categories discussed  above, a number of industrial
operations  generate waste  streams containing heavy metals of interest to this program.
However, it is not  likely that many of these will have a major impact on a Central Pro-
cessing System. One exception is  cooling towers where chromates are frequently used as
a corrosion inhibitor.

     Cooling Tower Blowdown Containing Chromates. Protection of the materials of con-
struction in  cooling towers and  cooling  systems requires the  extensive use of corrosion
inhibitors as  well  as the control of biological growths. Consequently, the water chemistry of
a cooling tower depends upon the nature  of the  make-up water, the materials of construc-
tion of  the system, and such operational characteristics as preventing heat transfer fouling
from biological growths or  chemical scale. In general, a cooling tower will concentrate the
make-up water to one-third or one-fourth its original volume, but the concentration ratio
depends upon the total dissolved solids concentration of the make-up water. That is, higher
concentration ratios are possible with low total  dissolved solids (TDS) make-up water and
vice-versa.

     The dissolved  solids concentration is usually established by the scale formers such as
the calcium salts, and  since sulfuric acid is often added to cooling towers, calcium sulfate
solubility most often  determines  the limits on total  dissolved solids. Corrosion inhibiting
chemicals such as chromates, phosphates, zinc,etc.,  are usually added  to the  circulating
cooling  waters in varying concentrations.  Some  cooling towers  may maintain a  concentra-
tion of  over 200 ppm sodium chromate when this chemical is used as the only corrosion
inhibitor. However, lower concentrations,  such as 40-60 ppm, are often used in conjunction
with polyphosphates.   Chemicals  for the  control of  bacterial growths,  either biocidal  or
biostatic, are also included  in cooling tower and  cooling system designs. Consequently, the
composition  of the circulating cooling water is usually a complex mixture of chemicals from
the make-up water and  those added to control conditions unique to the system.

     Cooling water is  emitted into the environment from  two sources:  the  "drift"  or
mechanical loss of water droplets that are carried out by the air passing through the tower,
and  the "blowdown"  or bleed stream necessary  to control the  concentration  of total
dissolved solids within a satisfactory operating  range. Although drift losses  may cause a
considerable  build-up of cooling tower chemicals in the ground around a cooling tower, the
major concern in this study  is for the disposal of the cooling tower blowdown.

     The magnitude of cooling tower blowdown depends upon a number of parameters such
as drift  loss, the temperature difference across  the cooling tower, and the chemical
composition  of the  make-up and circulating water. Present day industrial cooling towers are
guaranteed to have a drift loss of less than  0.2 percent of the  circulating water; that is, if the
circulation  rate is  1,000 gallons/minute (gpm)  the drift loss will  be less than 2 gallons/
minute. Since the  drift rate is not highly  dependent upon the temperature differences
                                        49

-------
across the cooling towers, it is possible for a cooling tower with a high drift rate and a low
temperature difference, i.e., 1 to 10 F, to require  no blowdown; the drift rate  will  keep
build-up in concentration of TDS within an acceptable range.

     As a general "rule of thumb," the blowdown from a cooling tower will approximate
0.3 percent of the  circulation rate  for each 10 F difference between  incoming (hot) and
outgoing (cold) water. That is, for a cooling tower operating with incoming water at 1 10 F
and  outgoing  water at  90 F the blowdown would be approximately 0.6 percent of the
circulation rate. Since approximately 1 percent of the circulated water must evaporate for
each  10  F  difference,  a  0.3 percent  blowdown would  allow the total  dissolved solids
concentration  in  the  make-up  water  to increase by  a factor of 3 1/3 if no  drift losses
occurred and no conditioning chemicals were added. If a drift loss of 0.2 percent  occurred,
the concentration ratio would be 2 for the same 0.3 percent blowdown.

     To provide another  perspective  to the magnitude of  the cooling tower blowdown
problem, assume a cooling tower handling a  100-ton refrigeration system such as might be
installed  on an office building.  This cooling  tower will probably require the circulation of
about 300 gallons/minute of water  with a 10 F temperature difference, i.e.. a rejection of
1.5 x 106  Btu/hr to the atmosphere* via evaporation with a blowdown of approximately
1300 gallons/day or another 50,000  gallons/month.  The removal of toxic  or hazardous
polluting substances from these blowdown streams before disposal into receiving waters will
obviously depend upon  specific local conditions and the size of the blowdown stream. For
large  industrial cooling towers,  the use of chromate  corrosion inhibitors  -  probably the
most effective inhibitor — may be continued and the blowdown treated on-site for removal
of chromium and disposal as a sludge.

     In the case of  small commercial cooling tower  installations, it may be most expedient
to change to a different, less hazardous, but less effective system of corrosion inhibitors.

     Smelting and Refining. Another source of wastes that contain heavy metals of interest
to this program is the smelting and refining industry. Because of the nature  of this industry,
however, it is  not likely to have a major impact on  a Central Processing System except in a
few  geographical regions. For example, almost all of  the direct refining of arsenic ores or
oxide powders is done by the American Smelting and  Refining Company (ASARCO) in the
State of Washington.  Thus, there really is only a local area where arsenic wastes from the
refining of arsenic ores would be possible.

     Arsenic is an impurity in most copper ores, so in the production  of copper metal it is
generated as one component in the  waste product. However, the arsenic is generated mostly
as particulate, which  is  collected  and sent to ASARCO for  treatment. Aqueous wastes
 * The difference between the 1.2 x 106 Btu/hr for the 100 tons of refrigeration and the  1.5 x 106 Btu/hr
 rejected arises from the inefficiencies of the refrigeration system.
                                        50

-------
containing  arsenic also come out in the copper refining process at several points,  but (his
waste is also sent to ASARCO. Therefore, arsenic wastes from mining and smelting really are a
potential problem only to the Northwest.

     Antimony plants  are either in Texas or in the Northwest; thus the direct refining of
antimony is also  a very regional and localized problem. However,  there are a number of
secondary smelters for lead in which antimony is a by-product, and these plants probably
can be found throughout the country. Mostly, these smelters utilize recycled material, such
as batteries, and  the waste  comes from  sludge or water effluent containing heavy  metals.
Most  of  the secondary smelters are relatively small, so waste streams would not be large,
although there are a few big ones, with National Lead Industries being the biggest.

     Cadmium is  found with zinc ores,  so cadmium-containing wastes are generated when
zinc is mined  and refined. Because these operations are large, however, the waste streams
would be extremely  large and  any  treatment necessary would be  done on-site. There are
some zinc  smelters scattered around the country, but not too many   a few in western
Pennsylvania, a few in St. Louis, one in Corpus Christi, one  in Idaho, and possibly a few
others; but by and large, because of the relatively  small number of these, the impact on a
Central Processing System would be minimal.

     Mercury is extracted by a dry process through volatilization and thus would not lead to
much aqueous or solid waste. Once again, this problem is localised  in the West. There are
other places where mercury could be a problem, e.g., chlor-alkali plants and  the mercury
emissions from power plants that burn coal. Water streams of the former already are being
treated, so at  most,  only  sludges would show  up  in a National Treatment System. If the
mercury  vapors from coal burning are collected by oxidative aqueous scrubbing (which is a
likely route) then the influence on a National Treatment System would come from the
treated sludge. This problem may have to be  faced by power  plants in the future, but does
not exist at present.

     All of the chromium ores are imported, and go into making iron and steel, electrolytic
chrome,  or chromate chemicals. In iron and  steel  the wastes  would be of large volume so
that on-site processing probably would be preferred. However, it is likely that frequently the
sludge would be sent to a Central Processing Center. Chromate chemicals are produced in
only a few plants so this would not be  a major issue. Electroplating wastes are covered in
another section.

     Mercury.  Outside of mercury metal production, which  has little  waste, the primary
sources of mercury waste material are chlor-alkali plants, paint manufacture and production
of organic chemicals  such  as pesticides. Pesticides and paints have been discussed earlier in
this appendix.

     Based on information  supplied by TRW, it  would  appear  that  brine  sludges  from
chlor-alkali plants very likely will be candidates for shipment to  central processing plants.
                                       51

-------
Common practice now is to treat the original waste water stream with precipitating agents
to form a salt sludge which contains small quantities (100 ppm) of mercury that has been
carried along with the precipitate.

     Total quantities of brine sludge range  from practically none to about 1.3 million
gallons. In almost all cases, therefore, it is likely that on an economic basis, these sludges
would be shipped to a regional (local) processing facility. Although there are 29 installations
in the United States, only one  is located in our primary field  area (Pennsylvania-New
Jersey). Because of the few locations these wastes will not likely have a major influence on a
regional waste treatment facility.
                                         52

-------
          APPENDIX B.2




IDENTIFICATION OF SPECIFIC SOURCES

-------
     Tables B.2A-B.2H  provide details for known waste sources within the Northeast and
Middle Atlantie States. The data in these tables were obtained through telephone calls and
personal visits by ADL personnel, as well as  from information  from companies treating
industrial wastes. The categories covered are:

          Table No.                             Category

            B.2.A             Concentrated Heavy Metals

            B.2.B             Dilute Heavy Metals

            B.2.C             Dilute Heavy Metals with Organics

            B.2.D             Heavy Metal Sludges

            B.2.E             Concentrated Cyanides

            B.2.F             Dilute Cyanides with Heavy Metals

            B.2.G             Liquid Wastes with Chlorinated Hydrocarbons

            B.2.H             Organic Wastes Requiring a Rotary Kiln
                                         55

-------


cu
OJ S
4-1 3
CO rH
cd o
3 >



M
co
e
H
rH
cd
bO


o
o
o
ft
o
o
in



o
o
o
o
-3-
OS



§
o
o
o




o
o
o
o
co
rH



o
0
o
o
m




0
o
o
v£)
vD




o
o
o
in



CO
1
rH
o
o
o
o
m
CM

CO
%
M
Tl

o
o
o
o
CM
m

3
rH
o
o
o
o



CN
m
m
<
























V)
_J
^
t-
UJ
S
>
>
<
Ul
x

o
01
p-
^
DC
t-
2
LU
Q
JP
o
o
















































C
o
•rl
4-1
A
•rl
M
CJ
CO
CU
Q
cu
4-1
CO
cd











rl
OJ •*
43 O
4-1 CO
O CM
cd
ss

M
rH
u
cd
z









rH
cd

tH
cu
4-1
cd
•g*

CO
3
o
T3

cd a
N -rl
cd c
EC CU
ca

cd

gsg
in

o










ft
 e
rH a
u a
EC
o
gsg lO
,
i-H 43




















^
rl
3
o

cu
e

43
a


m
00
c
o
M
•rl

r>
T3
cd
0)


a)
0
cd
r-l
4J

*
^-
o
CO
CM
EC

gsg
o
CM


















T)
•H
a
Cfl

o
•r(
g
o
^4
43
o

gsg
in
•
oo


^g
cu
a.
a
o
CJ

e
a
a

o
o
oo

f\
^-
o
CO
CM
EC

5s?
^
rH



















•a
•rl
u
cd

o
•H
£5
o
M
43
CJ

B-S
rH
rH






•a
•H
cd

rl
cu
4J
rH
•rl
UH

•S
fV)
o
CM
rH


B^S
CO
CO





















p
rj
•H
e
o

r*.
o

B^
m

CM















-
-------
                                                                      co
                                                                      B

01
cu B
4-1 3
CO rH
Cfl O
5 >


^
^
*-^
CO
e
o
tH
cd
60
0
o
o
n
o
vO
CM


0
O
O
f*
O
^3"
^o
00

o
o
o
n
o
\o



o
o
o
»*
CO




o
o
o
rt
0
o



0
o
o
*N
o
o
o
m

0
o
0
*i
o
CM
  4J
                                     PS 'O

                                     B-s  <*-(
                                     in   o
                                                                                                       0)
                                                                                                       4-1
                                                                                                      ^ -H
                                                                                                       3  O
                                                                                               e   o
                                                                                               3  -H
                                                                                               C   !-i
                                                                                              •H   3
                                                                                               g  4-1
                                                                                               3  rH
                                                                                              M   3
                                                                                               nj   w
                                                                                              o  m
                                                                                              CM  CM
                                  CO
                                 rH
                                  a
                                 4-1

                                  I


                                  cu

                                 4-1   CO
                                  o  -a
                                     •H
                                  B   cj
                                                                                                          o
                                                                                                          O
                                                                                                                                   cu
                                                                                                                                   o
                                                                                                                                   cu
                                                                                                                                   4-1
                                                          CO  J-l
                                                              to
                                                          B  o
                                                          3  O
                                                         •H  (-1
                                                         T3 'O
                                                          O  >,
                                                          en xi
        e/5
CO
e\i
00

LU
_i
ffl
LU

S
LU
z

LU





c
o
•H
4-1
ft
•rl
^j
O
M
CU
O

CU
4J
CO
cd











H
tO
•H
V-l
0)
4-1
cfl
s

CO
3
O
-a

cfl
N
cd
ffi




T3
•H
O
cd

o
•rl
C
CU
CO
M
cd

6-5
rH
•
0
1
in
o
•
0


CU
CO
e

M

00
c
•H
4-1
cd
rH
ft

B
0

M~4

cu
4-1
cd
g
0

XJ
a







B
ft
ft

o
^O

f.
1^1
M
3
O

cu
B B
3

ft 6
ft 0

CM XI
CM CJ
















K*-I
L4
3
O

cu
e

g
a
ft

m
B
O
V-i
XI
o

00
e
•H
13
3
rH
O
c
-H

*
CO
rH
cd
4-1
CU
g

(X*
p>
CO
cu
X!


£3
cfl
CU
S-J
4-1
CO

a)
4J
CO
CO
S

00
e at
•H 4-1
4-1 CO
to B
rH O
ft V-i
0 X!
M 0
4J
O X!
CU 4-1
rH -H
cu £







B
3
•H
B
O
M
XI
o

B
ft
ft

O
o
o
en
1
O
o
o
CM







B
3
•H
e
0
J-i
XI
CJ

g
ft
ft

0
0
o
in
1
O
o
o





*
6
3
•H
B
tJ
cd
o

»«
B
3
•rl
B •
o a
rl 4J
xi cu
o
*
<+J t-l
o cu
ft
B ft
ft 0
ft CJ







cu
4-1
cfl
B
o
}-i
XI
o

B
ft
ft

0
o
o

1
0
o
0
m
g
1
Pn
T)
•H
3
cr
•H
T3
•H
cr
•H
•a
•H
3
cr
•H
-O
•H
cr
•rl
T)
•H
3
cr
•H
*a
•H
3
cr
•H
•rl
3
cr
•H
•H
3
cr
•H
T)
•H
3
cr
•H
T)
•H
3
cr
•H
                       cu
                       4J  CU
                       CO T3
                       cd  o
                       3 o
                                     PQ
                                         CM
                                          I
                                         cq
                                                                     PQ
m      ^o
 I         I
m      PQ
I—-
 I
OQ
                                                                                                          OO
 i
PQ
                                                                        57

-------
                           0)
                       cu  S
                       4-i  3
                       CO H
                       CO  O

                       IS >
>»  O
•^   o
to   o
c
o   o
H   O
H   U1
CO
oo  CN
   o
   o
   o
    ft
   o
   o
   o
o
o
o
o
o
o
o      o
o      o
O      
CN      LU
03
                       O
                       •H

                       a
                       •H
                       
              •H
               3
               cr
            3
            cr
         3
         tT
         •H

         r5
                        cu
                        J-l  CU
                        CO TJ
                        CO  O
                        9 o
        I
       PQ
 I
pa
                         PQ
          I
         PQ
                                                                  58

-------
U
fj

CO
       00
       o
o
QC
O
I
I-

i
V)

o>
6
3
rH
O
>



IH O
t^ O
--. O
to
C O
0 O
rH in
•rH "
,Cfl i — 1
00
^-^



S
ft
ft









u
•H O
C O
CO O
M
IH CM
O rH

O
0 Q
0 0
M -tf rt
01
l~{
4-1
o

















O
•H
f*
CO
00
|H rH
O rH
C 1
1 — 1 CT»

33
ft
O
0
o
vt
in
^j-
rH





Cfl
M
0)
C
efl
0)
rH
o

a
•H
C
cfl
00
M
O





B
3
C
•H
6
3
rH
Cfl

&*•£
en
1
CM
O
0
o
•s
m
CM





*
0)
'O
•H
O
•H
)H
CD
4-1
a
cfl
,c

B^S CO
en rH
1 -rl

vD
CJN








rH
CO
4-1
0)
B

0>
C K
•H 0)
rH C
CO cfl
Vi QJ
rH rH
Cfl O












1
1
1



o
o
o
*•
o
o
O
O
O
rH


























B
O
)H
UH 00
PI
OJ -H
•W C
CO (3
cfl cfl
15 4-1
O
O
O
*
O
o
en







O
O
O
^
o
CM
rH
1
o
O*)

Q B
O ft
a ft










QJ
C
•H
rH
CO

rH
Cfl
O
O
0
f,
o
CM
m








CO
o
•H
C
CO
bO
^4
O

6s?
CM
1
T-H




'4H
O

CO
0)
o
ed
}_i
4J CO
rH
•> Cfl
cd 4->
•H gj
en B
o
o
o
A
o

O"


CO
IH
0>
C
CO
0)
rH
O

O
•rl
C
rfl
00
^
0

B-5
rH












1
1
1



O
O
o

o
o
m
en

*
rH
O
C
OJ a)
f*i ^,
e^ , ^O

& ^
PL, c^J
ft 4->

O rH
O cfl

4J
CO
cfl
3
0
o
o
n
O
o
rH







CO
ft
cfl
O
CO

«•,
CO
rH
•H
O

6s?
rH











3
O

gsO
CM
1
rH
CD     £
<     2
I-     >
ous Material
•a

cfl
N
co
p"]
0
•H
C
OJ
to
M
cfl

S
ft
ft

m
1
CM
dmium
efl
a

B
ft
ft

o
0
m
I
o
o
en

VJ
3
o
V-j
o>
£3

£3
ft
ft

0
o
CN|

^1
M
3
a
^1
o>
g

n
ft
ft

m
rH







g
rj
•H
B
o
|H
r;
O

^
j_i
3
O
^i
O»
B

n
ft
ft

CM
en
romate
r\
u

B
ft
ft

0
m
r^.
1
0
m
CM
chromate

B
ft
ft

o
o
o

1
o
o
o
CM

•H
B
o
!H
f.
O

B
ft
ft

o
0
rH
                                                                                                                                  e

                                                                                                                                  •H

                                                                                                                                  O
                                                                                                                                   cfl
                                                                                                                                   B
                                                                                                                                   o
                                                                                                                                          o
                                                                                                                                         •H
                                                                                                                                         -a

g
o
fa
•o
•H
3
cr
•H
n4
,fl
4-1
•H
13 to
•H T3
3 -H
CT rH
•H O
,-J W

•X3
•H
3
cr
•H


•a
•H
3
cr
•H
J

-0
•H
3
cr
•H
J

-a
•rl
3
cr
•H


-a
•H
3
cr
•H
i-J

T>
•H
3
cr
•H


•o
•H
3
cr
•H
rJ

T3
•H
3
cr
•rl


•a
•H
3
cr
•H
i-j
                      0)
                      4-1   01

                      CO  T3
                      Cfl   O
                                    u
                                       CM
                                                  en
                                                   I
                                                  u
                                                                     I
                                                                    u
m
 i
u
                                                                                          u
I—

u
CO

u
 I
O
o
rH


U
 I
u
                                                            59

-------
                                                                CO
                                                                31





« 1
4J :
CO r-
Cfl C
3N--
f


















V
0
4:
4.
C





3
M
•o
/-s
M 43
^ rH
J CO O
3 G O
3 O O
H rH -
> rH O
• cfl m
£S *"*





-a
•H
cfl

M
OJ
4J
rH
•H
IH

*\
-I CO
J 0)
: 4J
J CO
3 4=
p.
CO
o
J^
p.
3
I-i
T3
43

u
-H
•H
MH

gs5
O
CN



43
rH
0
O
o
*
0
o
CN













T3
•H
cfl

M
01
4-1
rH
•H
U-4

e-s
ro
rH



rH
Cfl
00
O
o
O
M
o
o
m




^
01
43
4-1
O

*.
0)
4-1
CO
(3
O
43
h
cfl
O

rH
01
^
O
•H
C


















'O
c
cfl

CO
(U
4-1
cfl
c
o
43 CO
I-i 01
Cfl TJ
O -H
X
H O
CO r-l
4-1 T3
01 >>




43
rH
O
O
o

0
in
rH
M


&*s
•n
CN

A
01

•H
X
O
^4
T3

43

>-i -H
01 cfl
a.
P* M
O 0)
O 4-1
rH
5^2 *H
CN H-J



i—i
CO
M
O
O
0
n
o

rH




H
cfl
4-1
01
e

'"O
c
cO

CN
/-N
>
43



rH
CO
c>0
O
O
O
•s
o
0
in
CO
C
0
I-l
•H

E
O.
p.

o
o
o


ri
r-j
f*4
CO 01
O T3
•H
" X
-3- 0
O M
CO "O
cfl >•,
O 43
        LU
        O
        O

Q      3
CN      C/l
CO      -J


ffl      ID
        I



C
0
•H
4J
P.
•H

O
to

Q

01
4-1
CO
CO









rH
Cfl
•H
(^
01
4-1
CO
S

to
3
O
•o
P
cvj
N
cfl
ta






0)

•H
14-4
rH
3
CO

O
•H
(3
01
CO

cfl

gsg
00








0)
-a
•H
IM
rH
3
CO

o
•H
C
0)
CO
I-l
cfl

gsg
00










qj
•a
•H
X
o

o
•H
C
01
CO
^
cfl

&*5
CN








0)
Tj
•H
14-4
rH
3
CO

o
•H
a
CD
ca
^1
CO

6-S







CO

rt
3
O
P.
€
C
CJ

o
•H
(3
(U
co
^
cfl

§sg
co
Q)
-a
•H
X
0
l-t
-a
t^*t
43
*-"*.
01
4-1
Cfl
C
o
43
I-i
CO
O

e
3
•H
e
-a
CO
o

B
p.
a.

m
r-
CN

^
g
13
•H
e
•a
CO
o
e
e 3
P, -H
a 0
o
m M
CN 43
i-i a










j>~,
M
3
O
>-
0)
e

43
P,
a

o
0
^o
X
o

•a
t>i
43

E
3
•H
0
O
M
43
a

s

a,

o
o
^F
1
m
i^.
                                    cfl
                                   O
                                            r-l
                                            M
                                            3
                                            rH
                                            C/3
£
                 r-l
         01
        4J
         Cfl
                              3
                             rH
                             C/l
4-1
Cfl
                                          M
                                          H
M
0>
4J
CO
 M
 I-i
 3
rH
co
                                                                                                      I-l
                                                                                                      I-l
                                                                                                      3
                                                                                                     rH
                                                                                                     C/l
                                                                               o>
                                                                               00
                                                                              TJ
                                                                               3
                                                                              rH
                                                                              CO
                                                                                   01
                                                                                   00
                                                                                  •a
                                                                                   3
                                                                                  ^-H
                                                                                  C/3
                      0)
                      4J  0)
                      CO TJ
                      CO  O
                      S O
rH


O
CN

a
                    Q
                                 in
                                  i
                                 Q
                                      I
                                     Q
                                                                              CO
                                                             O
                                                                         60

-------
              CU
          cu  B
          4->  3
          CO  rH
          Cfl  O

          &  >
                     O
                  Cfl O
                  a   "
                  o o
                  cfl
                  60
                                     o
                                     o
                                     o

                                     oo
o
o
o
o
o
o
  M
o
o
drums
o
o
o
  *l
in
                                                                         CO
                                                                         e

                                                                         rl
                                                                        -a
o
o
o
o
o
o
drums
o
o
o
  •s
m
dr
o
o
o
                                                                                                               -a
o
o
m
o
o
o
                                                                                                                          CNJ
o
o
o
  *t
in
CN
                      cu
                      4J
                      3
                     O
                      cO
                     'Z
                              CU
                              c
LU
Q
                                         O
                                         c
                                                rH
                                                 CU
                                                ,M
                                                 U
                                                •H
                                                 C
                                                             3
                                                             CO
                                                             O
                                                             CO
                                                             cu
            •H
            UH
                                                     3
                                                     co
                        3
                        CO

                        B
                        ft
                        ft

                       O
                       o
                       o
                       I
                                                                o
                    P3
                    O
                    cfl
                    a
                                                                        oo
                                                                                   sc
                                                                                   o
                                                                                    cfl
                                                                                   CS1
                                                                                            C
                                                                                            o
                                           CN


                                           O
                            •rl
                            C
                            o
                                        o
                                        CO
                                                           •rl

                                                           O
                                   O
                                   CO
                                                                                                               CO
                                                                                                               T3
                                                                                                               •H
                                                                                                               O
                                                                                                               CO
                                                                                                                           O

                                                                                                                          -2
                                                                                                                           CO
                                                                                                                           O
                                                                                                                           o
                                                                                                                           (1)
                                                                                                                           O
                                                                                                                           M
                                                                                                                           4J
                                                                                                                                   c
                                                                                                                                  Nl
                                                                                                                                   a
                                                                                                                                   ft
                                                                                                                                  rc
                                                                                                                                  o
                                                                                                                                   03
                                                                                                                                  CN
                                                                                                                                   I
OJ

CD

LU


CO
U

Q
LU
K
        O

        O
        u
a
O
•H
4J
ft
•rl
rl
CJ
CO
CU
Q

CU
4J
CO
cfl
s







rH
Cfl
•H
L i
W
CU
4J
CO
S

co
3
O
T3
Ki
CO
N
cfl
W








cu
T3
•rl
c
CO
>.
O

B

•H
•o
0
CO






•*
CU
TJ
•H
C
cfl
>v
O

B
3
•rl
T3
O
CO

6-S
m


/^N
C
CsJ
cfl
O
^^•

CU
13
•rl
C
Cfl
>>
a

rH
cfl
4J
cu
£3



^s
ro
•
O

f\
CU
13
•rl
C
cfl
>s
a

B
ft B
ft 3
•H
o B
0 0
o n
            e

            •H
            *O
            O
            CO
                             CO
                                         r-f  O
                                                    •a  cu
                                                    •H  4J
                                                     c  .
             CJ
             O
             S

            •H
             Cfl
             CO
             Cfl
            J-J
             o
             ft
                                                                        CJ
                                                                        o
                                                                         CU
                                                                        T)
         cfl
         >.
         O

        B^S
        in
                                    B
                                    O
                                    ^1
                                   X!
                                    o
                                                                        0  0
                                                                                                    CU
                                                                                                   T3
                                                                                                    C
                                                                                                    cd
                                                                                                   13
                                                                                                    O
                                                                                                    en
                                                                                           13     >
                                                                                                               o

                                                                                                               e
                                                                                                               ft
                                                                                                               ft U
                                                                                                                   c
                                                                                                               u-i  -H
                                                                                                                          •H
                                                                                                                           N
                                                                                                                           0)
                                                                                                                          T)
                                                                                                                          •H

                                                                                                                           cd
                                                                                                                           O
                                                                                                                           CO
                                                                                                                                          •H
                                                                                                                                          C
                                                                                                                                          CO
                                                                                                                                          CU
                                                                                                                                          ft
                                                                                                                                          ex
                                                                                                                                          o
                                                                                                                                          o
                                                                                                                                  00
                     T)
                     •H
                      3
                      cr
                     •H
                              3
                              cr
                             •H
                                                 cu
                                                 00

                                                1
                                                r-l
                                                C/5
            -d
            •H

             cr
            •H
            cr
                   •a
                   •H
                    3
                    cr
                    •H
                    3
                    cr
                    •H
                   13
                   •H
                    3
                    a*
                   •H
Water/oi

mixture
                            1-1
                            )-i
                            3
                           rH
                           C/3
                               •rl
                                3
                                cr
                                3
                                cr
                               •H
          CO  T3
          CO  O
                             CN
                                         CO
                                                                w
                                                                        w
                                                                                    i
                                                                                   w
                                                                                           00
                                                                                            I
                                                                                                                I
                                                                                                               Ed
                                                                                                                                           I
                                                                                                                                          W
                                                            61

-------
cu
4-J 3
CO rH
CO O
s >
s~+>
o
rH
rH
O
o
o
o
CN
o
o
o
oo
o
o
o
o
o
o
*
o
o
0
i?
o
o
o
o
rH
CN
O
0
o
o
o
CN
o
0
o
o"
                              bO
                                      u
                                      o
                                       CO
                                       e
                                       (X
                                       a
 cu
T)
a
Ul
       Ul



       I
       m
       X
       X
       Ul
       O
       u

       1
^
cu

4->
O
•H

O
CO

m
•
r-|
1
in
*
o
in
i
0

•i
cu
4-J
CO
B
cfl
K*S
U
O

'C)
K**l
^c

B
3
•H
*X3
O
CO



cu
a
rH

^a
4-1
cu
o
M
o
rH
j2
a
•H
)H
4-1

gs£
in
•
rH
1
rH
O
e
cu
c*!
ft
g
ft
ft
a
0 0
o u
co

* 00
G -rt
0 j!

-H *
0)
0 C
ft-H
P.H
^3
O ,.Sg
O rH
CN Cfl
01
CO
C
•H
IH
60
C
•H
4J
Cfl
rH
ft


CO
CD
C
•H
E
cfl

CU
O
Cfl

4-1







K
O
cfl
£5

6^
LO
i —

m
rH
O
C
CU
t_rj
ex

EN?
I"**-


a
o
•H
4J
a
•H
^
0
ca
cu
p
CU
4J
CO
CO
3







H
cfl
•H
M
CU
4-1
CO
Is*

CO
3
O
TJ
cfl
N
cfl
a









cu
T)
•H
C
cfl

O
e
ft

o
in
i
o











cu
•o
•H
PJ
CO
t*-»
a
3
•rt
3
T3
cfl
O
B
cfl
CU

4J
CO

01
4-1
Cfl
Cfl

00
C
•H
4J
CO
rH
ft
O
rl
4-1
O
CU
rH
cu










CU
•a
•rt
C
CO

O

S
ft
a.

o

i
0
rO










0)
^
S
IU


H
P-i
o

1
in
CN




tt)
13
•rt
C
Cfl

U
^4
a)
ft
ft
o
u
B
ft
ft

0
o
o
r^»











CU
•rl
C
Cfl
^i
O
B
ft


o

rH
                                  T3
                                  •rt
T3
•H
 3
 cr
•rt
                                                     3
                                                     cr
                                                     •H
3
cr
•H

 cr
13
•H
 3
 cr
•H
 3
 cr
•rt
                      0)
                      M  0)
                      CO T3
                      CO  O
                      * o
CN
              -a-     m
                i       i
              fa     Pn
                  I
                  fn
                                                          62

-------
                               Cfl
                               §
                                                                     Cfl
                                                                     0
Waste
Volume
;allons/'
20,000
o
o
o
•H
CN
O
o
o
o
CN
o
o
0
CN
rH
O
o
o
o
o
o
o
o
o
m
o
o
o
o
o
o
o
o
o
m
o
0
o
0
o
0
o
o
rH
o
o
o
ft
o
o
o
o
o
o
0
rH '
o
o
o
o"
o
o
o
o
o
0
o
0
rH
                           00
CD














v>
z
o
GO

^


a.
o
X
Q
UJ
r-
<
z
E
o
-I
JF pj
o o
_ -H
S 4J
t ft
2 'H
. rl
 o
W CO
r~ oi
^
£ 01
Q w
S Cfl
3 cfl
a 3

•J



u
0)
XI -W

O O)
r*
H
o
CO
B-S
o
v£>


0)
£J

rH rH
cfl >,
•rl J-

01 CU
4J O
* o

CO XI
3 O
O -rl
-a i*

CO
N B~S
cfl O
33 rH

M
H
Q
n

gx§
o
m





o
CN
pr|

B1"?
m
rH

*
rH
o
XI
0
o
rH
CO

in
vO







co
cu
4J
cfl
ft
Cfl
o
XI
ft
o
'£
4J
o

cd
SO
^_l
0

B-S
in
rH







CO
o
•r-l
n
cfl
60
VJ
o
01
C ^
01 01
1"^ rC
r-> 4J
x o

o >n
rH vJ3








C
0
•H 01
xi e
4-1 OI
Cfl rH
rH >,
cfl XI
B LI
~~- 0)
S P
O 1-1
•H O

4-1 XI
Cfl 0
)-l -rl
Cfl U
ft 4-*

&-S B^S
o m
rH CN



13
•rl
V-i
o
CO rH
4J XI
C 0
01 O
> C
rH 0
o e
CO
M
r4 3
01 UH
13 rH
C 3
•H CO
e B-S
ai m
erf m







0)
13
•H
01 O
C rH
01 XI
rH O
^i CfJ
XI r4
4J 4-1
01 <3J
O 4-*
t-l
0 PI
rH O
XI XI

J-l Cfl
01 O
ft
B-S
B-S in
m •*

Cfl
o
,^
MH
rH
o

o
^
rH
o
ft

&^s
m
vO

M
M
0)
4_»
cfl
»
B^9
m







co
o
•H

60
t-l
o

13
Oi
4-1
cfl
C
01
00
o
,_(
cfl
XI

&^5
o
m
t-l
01
XI
o

}-l
01
13
C
•H
cfl
6
01
^

M
^4
oi en
4J 4-1
CO C
S cu

m o
rH Cfl









01
13
•H
r-J
o
iH
XI
o

pi
01
rH
r*°i
r*.
4-1
0)
e

gsg
o
rH







Cfl
4-J
PI
0)

rH
o
H ft
-a o
>> M
XI ft
o o
t-i M
o o
rH rH
XI XI
0 0
•rl -H
ft r4
01 4J

B*S S-2
O O





Cfl
01
PI
o
4J
cu
*s.

^
en i
rH 1
O 1
XI
o
0
rH
cfl
B-S
O
f~~







CO
4-1 CO
C 0)
CU C
> 0)
rH N
0 C
Cfl OI
XI
'd o
OI t-i
4-> O
Cfl rH
a xi
•H cj
rJ O
O M
rH 4-1
XI -H
0 C

gs$ gvg
o m








J_t
01
4J
CO
3

B~^
LT)
fH

IK
01
ti
01
rH
o
4-1














01
C
01
N
C
01

O

O
rH
XI
Cl

SN!
m

















CO

o
4J
6-3
O
Pi












Cfl
01
C
0)
N
C
01
Xt
o

o
rH
XI
a

B^
0




)_,
ai
4J
CO


•
rH
Cfl
Xi

•V
0)
£
oi cu
C rH
0) >,
co X
o
rJ 6-2
CU O
riZ CN






















PQ CQ
O 0
p-l p-l

B-S B-S
m o
cxj -a-
a
£
T3
•H
3
cr
•H
rJ
T3
•H
3
cr
•H
nJ
T3
•H
er
•H
,-)
T3
•rl
cr
•H
>J
13
•H
cr
•H
nJ
•O
•H
cr
•H
J
T3
•H
3
cr
•H
J
13
•H
3
cr
•H
h4
13
•H
3
cr
•H
,J
13
•H
3
cr
•H
>4
T3
•H
cr
•H
j
13
•H
3
cr
•rl
K-I
-o
•H
3
cr
•H
J
13
•H
3
cr
•H
.-3
13
•H
3
cr
•H
hJ
                   01
                   4J  CU
                   CO  T3
                   cfl  O
                   S  o
CN
        o
               O
                       m
                       o
                               O
                                      O
                                              oo
O
rH
 I
                                                                                                                                 fl
rH      CN
rH      rH
 I       I       I
rj      O     C
<»•
rH
 I
in
i—i

O

-------








































„ .
•D
0)
3
C
c
o
O
q

CD
ai
m















cu
i i
to
cfl
^1

























CO
Z
O
m
cc

8
cc
Q
X
a
LU
r-
^
2 C
S °
O 4J
-J a
I -H
O !H
T °
F W
t CU
§ o
m 1>
LU jj
H*^
00 W

fcs
3
a
™ j
a

^


^
•^o o
cu en o o
B c o o
rH rH in O
o rH m  CO rH rH
M
— /

















cu
TD
•H
rJ X
CU 1 0
43 1 J-i
4-1 1 T3
O >>
r]

B
3
•H
O
CO





rH

•H
IH
CU

si
CO
3
O CO
T3 CD
M C 0)
CO 0) C
N rH 01
CO >, N
pr{ r^ pj
4J CU
01 43
0 0
rl rl
0 0
rH rH
-C 43
O U


o
o
o
o
SJ
CM





















CO
a
•H
rH
o
^»
CJ
o
l-f
o
rH
u













O>
C3
CU
rH
^
H,
4J
CU
O
V^
O
rH
43
CJ


O
O
O
O
CN
st






















|
1
1





















CO
cu
C
cu
3
rH
O
4-1
O
|^
O
iH
43
O


O
o
o
o
CN





















CO
4->
(3
CU

rH
O
CO

4J
e3
01
ex
,
O
^
0
rH
43
O
•H
ex
cu

B-S
%3-
rH


O
o
o
o
o
CN

















cu
3
13
•iH
CO
CU


>-.

IJ
cfl
4J

m
CN










CO
cu
&
a)

a
cu
42
0
^
o
rH
43
U
•H
rO

ijsg
in
i"~-
                                                                                         T)

B

Q
fl-l
'O
-rl
3
cr
•H
*1

T)
-iH
3
cr
•H
J

•n
•H
3
cr
•H
,-j

•o
•H
3
cr
•H
i-J

nd
•H
3
cr
•H
i— 1

'O
•H
3
cr
•rl
,— 1

•rj
•H
3
a-
•H
i-l

T3
•rl
3
cr
•rl
rJ
C
o
•rl
CO
rH
3
£•
W
3
rH
CO
CO
3
O
0)
3
cr

3
cr
•H
rH
M
3
O
O
CO
•H
P*
 O)
4-1  Ol
 CO  TD
 CO  O
3  U
00
T-H


O
cr>
rH

O
o
CM

C5
CN
 I
csi
CN
 I
ro
CM
 I
O
CM
 i
CN
 i
O
                                  i
                                 C)
                                                  64

-------
        ce






rH

O
CU O
rH 4) g O
CO ^J 3 «
2 CO rH r~
C cfl O
3 s >

rH
O
33

B"*£
CM
























CU
c
cfl
43
4J
CU
0

o
rH
43
CJ
Cfl
fa
'4J
CU
4-1

6s?
CM
m







43
rH

vO
O
rH













Cfl
G
O
43

cd
CJ
O
^J
T3
r^>
43

•S
l-i
CU
4J
CO
13
/«s


3
l-i
s»x
43
rH

O
O
o
*
m
m









*
CO
CU
>
o
rH
60 •
CJ
•> 4-1
CO CU
60
Cfl »»
l-l CO
cu
« 60
CO T3
l-l -H
CU M
4-1 4->
rH l-l
•H CO
H-l CJ






rH
ffl
00

o
0
o
«*
v^
CO


CO
4-1
•H
l-l
•H
a
co

rH
Cfl
M
CU
C
•H
e

*.
CO
rH
O
43
O
CJ
rH
Cfl

5s?
m
-
CO
Cfl
rH
ft

*•
C
o

^1
cfl
O





^1
r~i
Cfl
60

O
O
o

o
m









43
4-1
Ju4
CO
CU

CO
3
O
CU
O
Cfl
e
O
4-1
CO
•H
-o

gsg
O
rH





•
Cfl

O
o
o
*•
m
CM







43
4J
£.4
cfl
CU

CO
-J
o
CU
o
cd
a
o
4J
cd
•H
TJ

gs°
O
rH
1
m





•
cfl
60

O
O
O
*
O
s^-







^f
o
00
CM
cfl
$%

jjvg
m

*
tj
•H
Cfl

)^
cu
4J
rH
•rl
4-4

6^5
CO





•
cfl
60

O
O
O
«s
O
CN1



CU
60
T3

rH
CO

»^*
rj
ffl
4J

CU
60
CO

o
4J
CO

0)
(3
•H
rH
o
CO

60





•
60

O
O
o
r>
O
o
0^
rH

CU
60

3
rH
CO

^
c
cfl
4-1

CU
60
cd

0
4-1
CO

cu
C3
•H
rH
O
CD
CO
60





•
cd
60

o
o
o

CN








CO
TJ
•H
rH
O
CO

A
rH
•H
O

r.
^1
CU
4J
CO


&s°
o
CM
1
m





i
r^
cfl
60

O
O
O

O
m











CO
ft
•H
43
a

rH
CO
4-1
CU
a

*
rH
•H
o

&*£
O
rH
        DC
^      z
(M      -
cd      £
oa
<
        DC

        V>
        <£


        U
        a
rH
C CO
O l-l
•H M
4-1 CU
ft 4-*
"iH cfl
W yi co
O CU
CO CO T3
CU 3 -H
Q O M
tJ 0
CU M rH
4-1 Cfl 43
CO N CJ
cfl Cfl
13 PU E*>
e

0
•H
4J
(3
cfl










co
cu
T)
•H
X
O

>•.
e
0
a
•H
4_)
C
cfl
CU

[J
O
ft a
3
CJ -H
•H C
C3 CU
0) rH
CO CD
M CO
CO
a
a ft
ft ft
ft
O
O O
o o
o «
co m
i i
o o
m CM

CU
4J
Cfl
43
ft
CO
o
43
ft

a
3
•H
a

cfl
o

&*s
rH
1
m
•
o











r*1*
M
3
O
M
Ql
a

&*•?
rH
1
in

o







4-1
•H
(3

-••X,
r>»
l-l
3
a
i-i
cu
0

60
e

o
-3"










J-l
o
rH
43
CJ
cfl
4-1
ft
CU


5s?
in

CM

C
0
•H
43
4->
Cfl
rH
cfl
a
•^.
c
o
•H
43
4-1
CO
^i
cfl
ft

6*5
oo
i
m




CO
cu
4J
cfl
o
•H
43
4-1
O

O
43
ft
CO
O
43


B-S
0



T>
CO
CU
rH

rH

43
4-1
CU
cfl

4J
CU
4-1

a
ft
ft

o
o
rH

T3
cd
, CU
43 (3
4-1 01
CU rH
O !>i
r4 43
O 4J
rH CU
43 O
U l-l
•H O
M rH
4-1 J3
O
B--S -H
in i-i
C^ 4J
i
O 6^8
co r^
                                                                                                                                     O
e
£
M
rH
00
CU
60
•O
00
CO
cfl
•a
•H
rH
O
to
                                r^     CU
                                I*      60


                                3     "H
                                                               00
                                                                       00
                                                                               O
                                                                               00
                                                                                       l-l
                                                                                       t-l
                                                                                       cu
                                                                                       4-1
                                                                                       Cfl
                                                   l-l


                                                  rH
                                                  C/)

                                                   l-l
                                                   CU
                                                                                                      ^
                                                                                                      CU
                                       CU
                                       60


                                      "3
                                      rH
                                      W
                                                                                                                      CU
                                                                                                                      60
                                               l-l
                                               l-l
                                               3
                                              rH
                                              cn
                                       3
                                       rH  CO
                                       O *"Q
                                       C/J -H
                                          rH
                                       co  o
                                       3 w
                                       o
                                       CU 43
                                       3 4-1
                                       cr-H
                      CU
                      4J   CU
                      CO  X)
                      cfl   O
                     *  u
 I
a
CM      ro
 I       I
as      a
                                i
m
 i
EC
\o

33
                                                                                      33
co

33
CTi
 I
33
                                                                                                             33
CM
rH
 I
33
                                                                    65

-------
                                                         en
                                                         s
                                                                         tfl
                                                                         B
                                                                                   CO
                                                                                   e

                                                                                   M
                                                                                   13
                                                                                    00



cu
cu Q
n)
60
o
o
o
co 4j a1 «
3 CO rH
C co o
js rs j>
o
o
CN
cO
60
o
o
o
ft
o
o
o
,Q
rH
o
o
0
•V
o
«^J-
CN
cfl
60
o
o
o
*l
o
0
vO
Cfl
60
O
O
O

O
O
rH
in
m
O
o
CN
rs
,— {


CO
60
O
O
O
*
0
CO

rt
60
O
O
0

O

rH
       z

       s

       cc
-      O
•g      *
I      S
J      1
        8
        u
        cc
        co
cd
ui

CO
        I
        CJ
        z
        cc
        O
water on
                                       co
                                      4J
                                       C
                                       cu
 o
 CO  43
     CO
t>S   cfl
O   M
rH  4J
methy
                                                  o

                                                  Cfl
           cu
           e
                                                 o
                                                 CN
                                                         •H
                                                         o
 M



 I
rH
 O
 O-
uene
                           CU
                           4-1
                           CO
                                                                         !J
                                                                         cu
                                                                        4J
                                                                         n)
                                                                         >
 co
4-1
rH
 CO
 CO

 u
•H


 §L
 !-J  rH
 O   O
 C  43
•H   O
     CJ
5s?  i—I
in   co
                                                                                            CO
                                                                                            o
                                                                                           •H
                                                                                           4-1
                                                                                            CO

                                                                                            O
p.
o
•rt
4J
P-
•rl
M
CJ
CO
cu
Q

01
4->
05
CO







rH
CO
•H

01
4J
(rt
s

0)
3
O

M
cfl
N
CO
33
01
T3
1-1

O
rH
43
O
•H
T)

CU
C
01
rH
^i
f*{

CU

B^9
O
rH
•H
}-i
O
rH
43
O
•H
T3

0>
d
cu
rH
^*»
43
4J
01

gsg
o
CN
1
CN


CU
(3
CU
rH
£*•»
f;
4-1
CU
O
]-)
o
rH
4=
CJ
•H
)_l
4J

r>S
O
rH

CU
C
CU
N
C
0)

O
M
O
rH
43
a
o
^4
4J
•H
C

&"•£
o
-*





CO
01
£3
CU
3
rH
O
4-1
o
^
o
rH
f*
CJ

gsg
in
vO


Cfl
00
cfl
^1

c
o

T3
cu

cfl
o
CO

M
o
PJ

gvg
00





CO
01
C
cu
N
C
cu
fl
o
J-J
o
rH
(~?
o

5^S
O
r-~








CO
O
•rt
4J


O
P-I
cfl
0
V-l
0
rH
f{
CJ
                                       CO
                                       CO
                                       l-l
                                      H
           CO

            CO

            §
            cu
            3

           £
                                                         CO
         OJ
         60
        •a
         3
        rH
        CO

         >.
         t-l
         M
         3
        rH
        cn
                                                                                    CO

                                                                                    CO
                                                                                    o
                                                                                    CO
                                                                                            3
                                                                                           rH
                                                                                            CO

                                                                                            o
                                                                                            o
                                                                                            co
                                                              o
                                                             co

                                                             •H
                                                              B
                                                              cu
                                                             CO
                          cu
                          4J   CU
                          co  -a
                          co   o
                          S  u
-*
rH
 I
                                                  m
                                                  rH

                                                  33
 vo     r^«     oo
 rH     rH     rH
  I       I       I
                                               I
                                              P3
                                                      O
                                                      CN4
                                                             CN
                                                              I
                                                                 66

-------
    APPENDIX C




PROCESS ECONOMICS

-------
                                  BACKGROUND

     This appendix  summarizes our estimates of capital and operating costs for the major
components of each process included in Figure 3.1. The common cost factors on which
these estimates are based are summarized in Table 3.3. For the convenience of the reader we
have presented our description in terms of the same eight categories of chemical types used
in Appendix B:

         1.   Concentrated heavy metals
         2.   Dilute heavy metals
         3.   Heavy metals with organics
         4.   Heavy metal sludges
         5.   Concentrated cyanides
         6.   Dilute cyanides with heavy metals
         7.   Liquid waste with chlorinated hydrocarbons
         8.   Organic  wastes requiring rotary kiln.

     For comparative purposes, we have also included summary cost tables of some of the
less attractive  processes, and  the cost for evaporation versus  shipment distance  and cost.
Finally, we have included  the economics of  using a portable unit to destroy insecticide
containers.
                                        69

-------
                         CONCENTRATED HEAVY METALS

     The type of treatment used for heavy metal wastewatcr will depend on the speeies ol
 heavy  metal present, their form (e.g.,  soluble or slurry: sulfide or hydroxide) and  their
 concentration.

     As shown in  Figure C.I. the volume of the free settled, filtered 01 eentrifuged sludge
 (hydroxide  or sulfide) can approach or even exceed the volume of the wastewatcr solution
 in which the soluble metal salt occurs and thus presents a problem in ultimate disposal. II  it
 were necessary to  transport the final sludge any distance for ultimate disposal, the volume
 of  this sludge  in  relation to  the  original  volume  of the  wastcwater  would  have  to he
 considered in the economics.
     CO
     *o
     o
          3   _
          2   -
         %   0
        Ib/gal
  5                10                15

 0.52               1.03              1 64

Concentration of Heavy Metal in Wastewater (Chromic And I
 20

2.20
FIGURE C.1  COMPARISON OF HEAVY METAL SLUDGE VOLUME WITH VOLUME OF WASTEWATLP
                                          70

-------
     For our  first  example  (Figure C.2 and Table C.I),  we  have taken the following
concentrated heavy metal waste:

                       100,000 ppm CrO3 in 20% H2SO4
                         10,000 gal/week (2000 gal/day)
                                      TABLE C.1

               TREATMENT COST OF CONCENTRATED CHROME WASTEWATER

                          Basis: 2000 gal/day     100,000 ppm CrO3

                                                                     $/day
        Chemicals
        Utilities
                      S02
                      Lime
        240 Ib/day
       2000 Ib/day
                      Pumps, Conveyor
                      Agitator
       @
       @ $20/ton
                   20 HP
                    5 HP
                   25HPx8 = 200HPhrs
  24
  20
        Labor
                      2 men x 8 hrs/day x $5.50/man-hr
                      Overhead @ 50% Labor
        Depreciation
        Maintenance
        Insurance & Taxes
20%FCI/yr
 5% FCI/yr
 2% FCI/yr
$34,000/yr
  8,500/yr
  3,400/yr
  88
  44

 142
  35
  14
$369/day

$0.18/gal
        Dewatered Sludge Output 115 ft3/day
     The conventional industrial treatment for a concentrated chrome wastewater is re-
duction by  SO2  and precipitation by lime. (This method was suggested  for an NDS by
TRW.) FeSO4 also may be used as a reducing agent, but it produces a more voluminous
sludge. Proper  disposal of the hydroxide sludge generated is  an  additional cost in these
processes. (Refer to Table C.9.)
                                        71

-------

Storage
Tank

0 r
A *
so,
Storage

Acid
Storage

Treatment
Tank
ob
i h
^ '
i \
_ S02
* vapori

"I
f

*
D L
zer
Lime
Hopper
— EQQH
0 Ro
A *- F,

Fil
20

tary Q Polishing
ter A Filter
1
J
Backflush
« r
ter Cake
% Solids
                                                                                                   Elfluent
                           Waste Storage                        $  6,000
                           Treatment Tank                          6,500
                           S03 Storage  (1-Ton-Tank Rental)
                           S02 Vaporization System                  2,000
                           Acid Storage                               600
                           Lime Hopper and Feed Conveyor            7,000
                           Rotary Vacuum Filter                    25,000
                           Polishing Filter                           5,000
                           Pumps                                 2,500
                           Instruments (Redox, pH) and Recorders      2,500
                                         Purchased Equipment   $
  57,100
     x3
                                         Total Fixed Capital
                                            Investment
                                         Round to
$171,300
$170,000
Basis:  2000 gal/day Chrome Wastewater Batch Treatment
      100,OOOppmCrO3 (85% as Cr+3), SO2  Reduction
      20% H2 SO4  240 days/yr  1 shift/day
            FIGURE C.2   TREATMENT OF CONCENTRATED CHROME WASTEWATER
                                                   72

-------
                              DILUTE HEAVY METALS

     For the second example we have compared treatment  of a dilute chrome wastewater
by ion exchange (Figure C.3 and Table C.2), or by SO2 reduction to Cr+3 and precipitation
by lime as  the hydroxide (Figure C.4 and Table C.3). In the ion exchange process, the rinse
waters flow through the cation exchange, which removes metals other than chrome, 1 ,* and
into  the  anion exchanger, which removes chromate ion and yields demineralized water, 2.
The chromate ion is stripped from the anion exchanger with caustic, which produces sodium
dichromate, 3, and chromic acid is produced, 4, as  the sodium ion  is stripped from the
sodium dichromate in the cation exchanger. Both of these methods are used industrially for
the treatment of dilute chrome wastewater.
                                       TABLE C.2

                             RECOVERY OF CHROMIUM FROM
                        DILUTE WASTEWATER BY ION EXCHANGE
                     Basis:  10,000 gal/day  ISOppmCr"6  200ppmAr3


                                                               $/day
    Chemicals
           NaOH
           H2S04
           CaO
           Exch. Resin
     26 Ib/day
    372 Ib/day
    160 Ib/day
    0.3%/day
 0.04
 0.01
 0.01
 36ft3 x $60/ft3
  .04)
  .72 f
1.04
3
                                                  (Rounded)
                                                   $/day
            13.00
    Utilities

    Labor     4 man-hrs x $5.50/man-hr

    Overhead  @ 50% Labor
6.48 ;
1.00
22.00
11.00

1.00
22.00
11.00
    Depreciation
    Maintenance
    Taxes & Insurance
20% FCI/yr
 5% FCI/yr
 2% FCI/yr
$13,600/yr
  3,400/yr
  1,400/yr
57.00
14.00
 6.00
           57.00
           14.00
            6.00
                           Credits Water (10,000 x
                                                $0.40
                                                1000
                                  Chromic Acid (21 x $0.30)   =
                                                          Net
                                             $124/day

                                               $4/day

                                               $6/day

                                             $114/day

                                             $0.011/gal
    Sludge Output 30ft3/day
    (Mainly Calcium Sulfate from H2SO4 neutral.)
  Numbers refer to process steps shown in Figure C.3.
                                         73

-------
        Chrome Plating Solution


















0 j





Chromic Salts








Sulfunc
Acid














<3


O
A

r
OJ
O)
c
CD
u
X
LLJ



i






/5T-


r
Regenerant &
Sludge Treatment





©














OJ

0 c
£ I
X
LU

)
(



-T)

i











Demineralized
Waier Storage

Caustic
Storage1

	 •» Wate,

                                                       (Existing)
                      C^ation Exchange Unit with Automatic Controls
                      Anion Exchange Unit with Automatic Controls
                      Acid Storage
                      Caustic Storage
                      Pumps, In-Line Mixers, Flowmeters
                      Regenerant/Sludge Treatment System

                                  Purchased Equipment
                                  Fixed Capital Investment
                                  Round to
$27,400
   x2.5 (Exchange Units Complete
           with Controls)
$68,500
$68,000
        Basis: 10,000 gal/day
             130 ppm Crf 6
             200 ppm A2
             240 days/yr Operation
             Continuous Operation
FIGURE C.3   RECOVERY OF CHROMIUM FROM DILUTE WASTEWATER BY ION EXCHANGE
                                                  74

-------
                                                                        Backflush
                                                                                                                       Effluent
                                                                               Sludge Cake
                                                                               20% Solids
                                           Waste Storage                $11,200
                                           Reduction Tank                5,000
                                           S02 Vaporizer & Controls        1,500
                                           Lime Slurry Tank               2,000
                                           Pressure Filter Plate & Frame     5,500
                                           Polishing Filters                 500

                                             Purchased Equipment Cost   $18,300
                                                                           x3

                                              Fixed Capital Investment    $54,900
                                              Round to                 $55,000
Basis:  10,000 gal/day
      1 30 ppm Cr+6
      200 ppm A2+3
Continuous Treatment
      FIGURE C.4   TREATMENT OF DILUTE CHROME WASTEWATER (Reduction & Precipitation)
                                                        75

-------
                                       TABLE C.3

                   TREATMENT COST OF DILUTE CHROME WASTEWATER

                        Basis:  10,000 gal/day     240 days/yr operation
                              130 ppm Cr+6
                              200 ppm Af3
        Chemicals
                  S02
                  Lime

        Utilities    (Power)
22 Ib/day
56 Ib/day
@ 1 Od/l b
®  W/lb
$2.20
 0.56
        Labor     4-man-hrs/day x $5.50/man-hr
        Overhead
        Depreciation
        Maintenance
        Taxes & Insurance
20% FCI/yr
 5% FCI/yr
 2% FCI/yr
$11,000/yr
  2,800/yr
  1,100/yr
 $/day

 3.00

 1.00

22.00
11.00

46.00
11.00
 5.00
                                                                     S99.00/day
                                                                     S0.0099/gal
                                                                     $0.01/gal
        Sludge Output 1ft3/day
A typical waste stream of this type would have the following composition:

                        Flow:  10,000 gallons/day
                               130ppmCr+6
                               200 ppm Al+3

As shown in Figures C.3 and C.4 the net cost of either means of treatment would he nearly
the same.

     We also considered a portable  ion exchange unit. Such a unit could be built much
larger because it would treat waste  from, say, three or four sites one week per month at each
site.  There  would be  a savings because  of the size factor. Quadrupling the size, would
increase the cost only 2.3 times and each site would have to pay for one-fourth of the unit's
time. Other  savings might  be  possible because the unit  might  not  have to be  housed.
However, we assumed that the  cost of modifying  a trailer truck would be equivalent to the
cost  of building housing for the stationary ion exchange unit. Furthermore, in  mild climates
the stationary unit would be outdoors anyway.
                                         76

-------
     Cursory calculations (see Table C.4) show that a portable unit would be marginal. To
calculate the depreciation on the truck and trailer, we assumed that one truck would service
four trailers and that each  trailer would house an  ion exchange unit sufficient to process
200,000 gallons of liquor in one 5-day  week. For our example of 10,000 gallons per day of
wastewater, the trailer would be used one week per month operating on a 200,000 gallon
pond. We have also assumed a 5-year depreciation rate on  the trailer and tractor. The user


                                        TABLE C.4

            ECONOMIC COMPARISONS PORTABLE VS STATIONARY ION EXCHANGE
                                           Portable           Permanent
                                             ($)                ($)


                Capital Investment
                   Pond                    $30,000              -
                   Truck & Trailer           [35,000] *
                   Ion Exchange
                     Equipment            [156,000]*          68,000
                                            $/Year            $/Year

                Operating Costs
                   Chemicals                        Unchanged
                   Labor                            Unchanged
                   Overhead                         Unchanged

                Depreciation prorated including 70% utilization efficiency
                   Equipment                11,200            13,600
                   Truck & Trailer              2,500              -
                   Pond                      3,000              -
                                           $16,700           $13,600

                Depreciation prorated assuming 100% utilization efficiency
                   Equipment                 7,800            13,600
                   Truck & Trailer              1,750
                   Pond                      3,000

                                           $12,550           $13,600
                                 Savings    $ 1,000
                *Trailer and ion exchange equipment occupancy requirements for
                 this project, 25%
                *Tractor occupancy requirement for this project 25% x 25% = 6%.
                                           77

-------
would not have to invest in ion exchange equipment — a  savings of $68,000.  However, lie
would have to have sufficient land to build a retention pond to save his waste  for a month.
Such a pond, to be absolutely safe, should be lined. Thus we calculate its cost at S30.000.

     Table C.4  does  not differentiate ownership  between the portable and  the permanent
system because the charge  for its use would have to be sufficient to cover depreciation of
equipment as well as operating cost. One finds that the depreciation on the pond and trailer
equipment more than offsets the savings on depreciation of the ion  exchange equipment (if
one assumes  that the contracting firm  must charge sufficient fees to allow for only 70'/
utilization  of its portable equipment). Table C.4 also shows that  there will be  a very slight
savings in depreciation  cost if the  equipment can be  utilized at \Q07f  efficiency. Overall.
however, these calculations suggest that a portable  unit  would not attract much venture
capital.

     For  other  heavy  metal salts - arsenic, antimony,  cadmium and mercury - TRW
suggested  long-term storage, precipitation as the sulfide, precipitation as the hydroxide, or
recovery by ion exchange  as several candidate means  to be used by the NDS. When these
metal salts can be recovered economically at the site generating them, by such  means as ion
exchange,  they will  not appear  as waste materials.  Where  the wastewater is  too con-
taminated  with other waste materials or the recovered metal would have too  little value if
recovered,  the heavy metal solution does indeed become a  wastewater. If these  heavy metals
are already in  the insoluble  solid form (e.g., sulfide or hydroxide) the only treatment
necessary would be to encapsulate and landfill (or store).

     One  possible means for removing  any of the soluble heavy metals from wastewater
efficiently  enough to meet present (and probably future) concentration criteria would be to
precipitate them as  the sulfides and encapsulate and landfill or store  the sludge. These
sulfides also exhibit  such a low solubility, that the danger of accidental release of the heavy
metal to the  environment would be very small. Some of these heavy metals also form water
insoluble hydroxides, but the sulfides are generally even less soluble and are more granular
(less gel-like) than the hydroxides. Thus  they are easier  to handle in the filtration step.

     A typical  soluble, heavy-metal waste that could be treated by sulfide precipitation is as
follows:

                                  10,000 gal/week
                                  2-3% sodium arsenite
                                  1 -2% organic arsenites.

The system  proposed for this  sulfide  precipitation is shown in Figure C.5  and  the cost
calculations in Table C.5.
                                         78

-------
Waste Storage
  Effluent
to Incinerator
                                                    Sludge
                               Sludge Cake
                                20% Solids
                                                               Purchased Equipment

                  Waste Storage                                       $  6,000
                  Primary Precipitation & Settling                          15,000
                  Secondary Sulfide Removal                              6,500
                  Sludge Holding                                         8,500
                  Rotary Vacuum Filter                                  20,000
                  Final Filters                                            500
                  Centrifugal Pumps                                      2,700
                  pH and Sulfide Electrodes & Instruments                   2,000
                  Sludge Pumps                                          2,000
                  Coagulant, FeSO4 , Na3 S, Caustic, Acid, Metering Pumps      1,000
                  Na2 S, Ca (OH)2, FeS04  Makeup Tanks and Agitators         3,000
                  Acid Storage                                            600

                                         Purchased Equipment          $ 67,800
                                                                         x3

                                         Fixed Capital Investment       $203,400
                                         Rounded to                  $200,000

       Basis;  2000 gal/day Heavy Metal Waste Solution
             20,000 ppm Heavy Metal Content (Arsenic)
           FIGURE C.5   DISPOSAL OF HAZARDOUS HEAVY METAL WATER
                          SULFIDE PRECIPITATION OF HEAVY METALS
                                                 79

-------
                                TABLE C.5

                   COST OF SULFIDE PRECIPITATION OF
                   HEAVY METALS FROM WASTEWATER

                    Basis:  2000 gal/day  20,000 ppm Arsenic
Chemicals
        Na2S
        H2S04
        FeSO4
        Coagulant
       Units/day

 420 Ib/day x $0.80/lb  = 33.60
1100lb/day x$0.01/lb  = 11.00
 150lb/day x$0.02/lb  =  3.00
 0.8 Ib/day x $0.20/lb  =  0.16
$48.00/day
Utilities
        50HP@ Icf/kwh
Labor
        (Incl. Fringe)     2 men x 8 hrs/day x $5.50/man-hr
Overhead
       @ 50% Labor
                                        4.00
                                       88.00
                                       44.00
Depreciation
Maintenance
Taxes& Insurance
20% FCI/yr
5% FCI/yr
2% FCI/yr
$40,000/yr
10,000/yr
4,000/yr
167.00
42.00
17.00
$410.00/day
$0.20/gal
Sludge Output 32 ft3/day
                                     80

-------
                          HEAVY METALS WITH ORGANICS

     It"  the  waste stream contained organic materials in addition to the heavy metals, the
effluent from the precipitation system would have to be burned or treated by a process such
as carbon adsorption. A system for incineration of the dilute hydrocarbon waste is shown  in
Figure C.6 and  Table C.6 (Carbon  adsorption treatment  of this same waste is shown  in
Figure C.7 and Table C.7.)
Waste
Tank
0
A
i
1

Oil Tank

o
,
±
i

Mixer
A
Oil Storage Tank

Air
&
I 	 1 Stack
Furnace '
~~*" 1800JF *

9
X
$ 500
Waste Storage Tank 3,000
Oil & Waste Pumps 1 ,000
In-Lme Mixer
Furnace
300
25,000
Secondary Blower 1 ,000
Stack
2,000
                                                     $32,800
                                                        x2.5  (Furnace x2.2)
                                     Fixed Capital
                                       Investment
             Basis: 2000 gal/day 2% Hydrocarbon (Non-chlorinated)
                  400 gal/day Oil Rate (50 gal/hr = 7.25 MM Btu/hr)
                   $82,000
                 FIGURE C.6   INCINERATION OF DILUTE HYDROCARBON
                                       TABLE C.6

                   COST OF INCINERATION OF DILUTE HYDROCARBON

                    Basis:  2000 gpd  2% hydrocarbon (non-chlorinated)
            Utilities
                    Oil
                    Power
            Labor
400 gal/day x$0.10/gal
25 HP
                    2 man-hrs/day x $5.50/man-hr
                    Overhead @ 50% Labor
            Depreciation
            Maintenance
            Insurance & Taxes
20% FCI/yr
 5% FCI/yr
 2% FCI/yr
$16,400/yr
  4,100/yr
  1,600/yr
                                           81
                   $40/day
                     2
11
 6

68
17
 7
                                                                     $151/day
                                                                      $0.08/gal

-------
                                     TABLE C.7

                    COST OF DILUTE HYDROCARBON TREATMENT
                              BY ACTIVATED CARBON

                   Basis: 2000 gal/day dilute (2% by weight) hydrocarbon
                         240 days/year 24 hrs/day
                         Fixed Capital Investment $64,000
       Cost Item

     Activated Carbon
     Power
     Labor (Incl. Fringe)
     Overhead (Admin.)

     Depreciation
     Maintenance
     Taxes & Insurance
Units/day
6700 Ib
240 kwh
2 man-hrs
50% Labor
20% FCI/yr
5% FCI/yr
2% FCI/yr

$/Unit
0.10*
5.50
$12,800/yr
3,200/yr
1,300/yr

$/day
670.0
2.4
11,0
5.5
62.7
15.7
6.4
$773.7/day
$0.39/gal
      Regenerated On-site.  Regeneration by Activated Carbon Supplier would cost
      about $0.30 per Ib.


                   COST OF ACTIVATED CARBON REGENERATION

           Basis: Carbon Regeneration System Capital Investment $300,000 (1972)
                 6,700 Ibs/day activated carbon, 804 tons/yr ($200,000 in 1968)
     Cost Item

Makeup Carbon at 6% Loss
Labor 24-man-hrs/day
Fuel
Power
Overhead (Admin)

Depreciation at 20% FCI/yr
Maintenance
Taxes &  Insurance 2% FCI/yr
$/unit
S/year
$/day
600/ton
5.50/man-hr
28,800
32,000
3,500
1.400
16,000
60,000
6,000
6,000
$153,700

$640/day
$0.10/lb Carbon
  Lake Tahoe Unit
                                         82

-------
       Wastewater
                                              200 ppm COD
20,000 ppm COD
Exhausted
Act. Carbon
1
1




Carbon


2
t

Carbon
1
3




Carbon
Carbon Storage

	 h_
                            2000 ppm COD
                    20 ppm COD
                       Waste Storage Tank
                       Adsorption Towers
                       Carbon Conveyors
                       New Carbon Storage
                       Pumps
                       Valves
                       Controls
                       Spent Carbon Storage
                        2,000
                        6,200
                        4,400
                        1,000
                        2,200
                        2,000
                        2,500
                        1,000
   Purchased Equipment    21,300
                      	x3
Fixed Capital Investment   $63,900
        Rounded to     $64,000
       Basis: 2000 gal/day Wastewater containing 2% hydrocarbon
            240 days/yr at 24 hrs/day
            COD = chemical oxygen demand
FIGURE C.7   DILUTE HYDROCARBON REMOVAL FROM WASTEWATER BY ACTIVATED CARBON
                                              83

-------
     If the dilute hydrocarbon contains chlorine or nitrate, it would be necessary to scrub
the flue gas. This system (shown in Figure C.8 arid Table C.8) also could be used with minor
modification for incineration of explosive wastes after the explosive is slurried in water.
                                       TABLE C.8

        COST OF INCINERATION OF DILUTE HYDROCARBON CONTAINING HALOGEN


               Basis:   2,000 gal/day 2% hydrocarbon (chlorinated)
               Chemicals
                 CasusticSoda      300 Ib/day    @   M Ib        $12.00/day

               Utilities
                 Cooling Water      100 M gal/day @   5«i/M gal       5.00
                 Fuel              400 gal/day   @  10d/gal        40.00
                 Power                                          1.00

               Labor (Incl. Fringe)    12 man-hrs/day x $5.50/man-hr  66.00
               Overhead  (at 50% Labor)                           33.00

               Depreciation      20% FCI/yr     $34,000/yr      142.00
               Maintenance       5% FCI/yr       8,500         35.00
               Taxes & Insurance   2% FCI/yr       3,400         14.00

                                                             $348/day
                                                              0.17/gal
                                            84

-------



Waste
Tank
	 	 1



Oil
Storage



9 *,
A *




0 .
A ""
Water
1 *"!
i i
Water |
Mixer 1 o>
1 I D
I 1 3
^r Furnace | Spray fb
*" ^ i,'"*1 18001- 1 Chamber
' — i 	
0 .ir 1
X A '
CaCI,
Q Caustic
A Storage




0
A
ID Fan








^_





	 1


CJ






                              Oil Storage Tank
                              Waste Storage (or Mixing) Tank
                              Oil & Waste Pumps
                              In-Line Mixer
                              Furnace
                              Spray Chamber
                              Scrubber (Venturi)
                              Scrubber I. D. Fan
                              Caustic Soda Storage Tank
                              Stack
                              Pumps
                                 Fixed Capital Investment
                                 Round to
$    500
   3,000
   1,000
     300
  25,000
  10,000
  18,000
   5,000
   2,000
   3,000
   1,500

$ 69,300
    x2.5

$173,250
$170,000
Basis: 2000 gal/day 2% Hydrocarbon (Chlorinated)
     400 gal/day Fuel Oil Rate
  FIGURE  C.8    INCINERATION OF DILUTE HYDROCARBONS CONTAINING HALOGEN
                                                  85

-------
                      DISPOSAL OF HEAVY METAL SLUDGES

     The sludges produced by the precipitation of the heavy metals in general  will not he
economically  recoverable on  a continuing basis.  Their disposal  wiM  consist of on-site
encapsulation  in asphalt, waste  resin, or polymer. Volatile sulfides that would have too high
a vapor pressure  at the temperature of the molten tar or resin, would be encapsulated in
concrete.

     For the  tar or polymer encapsulation, we visualize using still bottoms or other tar
residues, some at zero cost, but  on  the  average at lyf/pound. Also, we understand that
off-standard polymers are available at  1^/pound. This waste would he cast into fiber or used
(waste) steel 55-gallon drums (assumed to be available at about $2 each).

     For encapsulation in cement, we visualize using dilute metal sulfide or hydroxide as the
water to form  the concrete. A portable cement mixer, of the type used at small construction
sites, would be used to mix the cement and the water containing the  insolubilizcd metal.
and the mixture would then  be cast into fiber drums or used (waste) steel drums.

     Table C.9 summarizes the  costs for several methods of encapsulating sludge cakes ol a
typical  concentration, 2Q7f. These costs represent  the  operating experience  of two  com-
panies and ADL's estimates for a volatile and non-volatile sludge.
                                        TABLE C.9

                      DISPOSAL OF FILTERED HEAVY METAL SLUDGES

                              Basis:  Sludge Cake 20% Solids by Weight

                                                           Disposal Cost
               Process                                   (4 Per Gallon Wet Sludge)

          Company A                                            8-10
          Company B                                            3-12
          Polymer Encapsulation & Landfill (Fig. C.9)                    25
          Cement Encapsulation & Burial Onsite*                        10
          * Volatile sludges only.

     Figure C.9 shows the capital costs and operating costs associated with  the asphalt
encapsulation as estimated by ADL. The cement encapsulation process costs arc based on
the cost of an outside contractor pouring cement at $23/cubic yard (5-yd  minimum)  into
used steel  drums or fiber drums, and burying it. Unfortunately, the dilute slurry of metal
sulfides would increase in volume (1:65) in  making the concrete, so the cost of excavation
and backfill (at $3/cubic yard and S2/cubic yard, respectively) would represent one-third of
the total cost of 25
-------
                   Cr (OH)2
                        Steam
                                                db
Asphalt or Polyethylene Scrap
                                                                         Fixed Capital  $21,000
                                                        55 Gal Drums
                      Encapsulation Cost

                            Raw Materials, Asphalt 1000 Ib @ 1rf / Ib
                            Utilities, Steam 10,000 Ibs
                            Labor 4 man-hours/day x 5.50
                            Overhead
                            Depreciation, Maintenance, Taxes & Insurance
                            Drums@2ea., 3/day
                      Burial Cost
                            Excavation. 2 yds x $5/yd
                            Back Fill
      $10/day
       10
       22
       11
       15
        6

      $74/day

   $0.65/ft3 Sludge
      $10/day
        5
                                       Total for Encapsulation & Landfill
                Basis:  115ft3/day Chrome Sludge (1720 Ib/day Cr (OH)2)
      $15/day

      $89/day

   $0.77/ft3 Sludge
   $0.103/gal Sludge
FIGURE  C.9  ASPHALT ENCAPSULATION OF CHROME WASTE SLUDGE & BURIAL (20% Solids)
                                                    87

-------
                        CONCENTRATED CYANIDE WASTES

     The treatments applicable to concentrated cyanide waste include  acid decomposition
of the  cyanide  and subsequent  incineration  of  the  HCN, Du Pout's Kastone hydrogen
peroxide method,* and the Schindewolf thermal decomposition process.**

     For our examples  we have compared the destruction of the cyanide radical by  the
conventional caustic-chlorine oxidation (Figure C.10 and Table C.10) with a 2-step process
that  involves  acidification,  incineration  of  the  HCN gas, heavy metal treatment, and
secondary cyanide treatment by  alkaline chlorination  fFigure C. 11 and Table  C.I I). The
2-step process requires less chemicals, but more labor and  investment and on the whole is a
more expensive  process. It would have the advantage of producing less secondary effluent
(NaCl). If a suitable kiln or furnace were available at  the site for safely burning the HCN, the
capital investment could be reduced  by  15%, but  this process  would  be more expensive
because of the labor required for two stages rather than one stage of treatment.
                                     TABLE C.10

      COST OF TREATMENT OF CONCENTRATED CYANIDE WASTE  BY CHLORINATION
              Basis:   5,000 gal/week   1,000 gal/day    (1 batch/day)
                     7,000 ppm copper cyanide  1,000 ppm sodium cyanide
                     Fixed Capital Investment $100,000
                                   Units/day
                 $/Unit
              $/day
              Chemicals
                Caustic
                Chlorine
 95
227
 0.03
 0.07
 2.8
15.9
              Utilities
                Power
                Cooling Water
                   (Mgal)

              Labor  4 man-hrs/day
              Overhead  50% of labor

              Depreciation
              Maintenance
              Taxes & Insurance
150 Kwh

  1.5
20% FCI/yr
 5% FCI/yr
 2% FCI/yr
   Chemical Week, December 16, 1970, p. 54.
   Chemical Week, December 20, 1972, p. 32.
 0.01

 0.05
S20,000/yr
$ 5,000/yr
$ 2,000/yr
 1.5

 0.8

22.0
11.0

83.3
20.8
 8.3
                                                                  $166.4/day
                                                                  S  0.17/gal

-------
                                                               I                    I
                                                             ^,      Heavy Metal    i
                                                             *"J      (Treatment)    f
                                                               (Not included in cyanide
                                                               treatment investment)
-^•Effluent
                            Waste Storage (5,000 gal. Carbon Steel)           2,500
                            Chlorine Storage (Included in Cl, Cost)            -
                            Caustic Storage (500 gal. Carbon Steel)            500
                            Chlorine and Caustic Metering Systems           3,000
                            Waste Transfer Pump                           700
                            pH and Redox Control Systems                 1.500
                            Alkaline Chlorination Reactor with            22,000
                               Cooling Coils (1,500 gal)
                                                     Purchased
                                                     Equipment      28,400
                                                                       x3.5
                                             Fixed Capital Investment   99,400
                                                   Rounded to       $100,000
Basis:  5000 gal/week, 5 Batches of 1000 gal/week, 48 weeks/year
      7000 ppm copper cyanide  1000 ppm sodium cyanide
      FIGURE C.10    CONCENTRATED CYANIDE WASTE TREATMENT BY CHLORINATION
                                                 89

-------
                            HCN
                                                       Flue Gas
                                                                  NlaOH Storage
                                             Heavy Metal
                                             Treatment or
                                              Recovery
Cl, Storage
Dilute Waste
Storage


Alkaline
Chlormation
                   Effluent
                               Cone. Waste Storage                      $  2,500
                               Dilute Waste Storage                         2,500
                               Sulfunc Acid Storage                          300
                               Chlorine Storage (Included in Chlorine Cost)
                               Caustic Storage                               300
                               Acid & Chlorm. Reactor                     21,000
                               Vacuum Pump                             1,500
                               Gas Incineration System                      6,500
                               Incineration Low Temp. HCN Shutoff          1,000
                               Acid Metering Pump                           700
                               Caustic and Chlorine Metering Systems          2,500
                               pH Control System                          1,000

                                          Purchased Equipment Cost       42,500
                                                                         x3.5

                                          Fixed Capital Investment       $148,750
                                          Round to                   $150,000
Basis:  5000 gal/week (1000 gal/day) Batch Treatment
      7000 ppm Copper Cyanide, 1000 ppm Sodium Cyanide
                FIGURE  C.11   CONCENTRATED CYANIDE WASTE TREATMENT BY
                                 ACIDIFICATION AND CHLORINATION
                                                  90

-------
                            TABLE C.11

COST OF CONCENTRATED CYANIDE WASTE TREATMENT - 2 STAGES
                    (acidification & chlorination)
  Basis:   5,000 gal /week, 1,000 gal/day
          7,000 ppm Copper Cyanide, 1,000 ppm Sodium Cyanide
          Batch Treatment, Capital Investment $150,000
                       Units/day       S/Unit            $/day
  Chemicals
     Sulfuric Acid          58 Ib          0.02
     Caustic Soda           2.6          0.03       0.08 }>     1.7
     Chlorine               6.1          0.07

  Utilities
     Power               300 Kwh        0.01                3.0
     Steam                 0.3MMBtu    1.00                0.3
     Gas                   4.2MMBtu    0.32                1.3
  Labor                8 man-hrs/day     5.50               44.0
  Overhead                50% labor                         22.0

  Depreciation          20% FCI/yr      30,000/yr            125.0
  Maintenance           5% FCI/yr       7,500/yr             31.0
  Taxes & Insurance      2% FCI/yr       3,000/yr             12.5

                                                         $241/day
                                                         $0.24/gal
                                91

-------
                             DILUTE CYANIDE WASTES

     Much of the cyanide wastes occurs as  effluents from the plating  or  metal  recovery
industries. These wastes would have to be treated for both the cyanide and heavy metals.

     The concentration of the cyanide and heavy metal and the value of these compounds
would influence the selection of the waste treatment system. If the cyanide and heavy metal
are not economically  recoverable  (e.g., by  ion exchange), the cyanide radical would  be
destroyed and the heavy metal precipitated and disposed of as sludge.

     In treating a dilute cyanide waste, one can use hypochlorite, or caustic and chlorine, to
oxidize the cyanide to cyanate or to nitrogen and carbonate. This oxidation  may be done in
either a batch or a continuous system with sufficient residence time. Relatively small
volumes probably would be treated in a batch process. In  Figure C.12 and  Table C.12, we
have  depicted a batch  process for the  total oxidation of a dilute cyanide by caustic and
chlorine followed by heavy-metal removal.
                                     TABLE C.12

                     COST OF DILUTE CYANIDE WASTE TREATMENT

            Basis:   5000 gal/week     2 Batches/week 48 weeks/year
                   100 ppm Cu (CN)2   100 ppm NaCN Capital Investment $95,000
   Chemicals
          Caustic
          Chlorine

   Utilities
          Power

   Labor
   Overhead

   Depreciation
   Maintenance
   Taxes & Insurance
                             Units/Batch
    6.4
    15.3
    200 Kwh

4 man-hrs/batch
50% Labor
                  S/unit
0.02
0.10
0.01
      20%FCI    $19,000/yr
       5% FCI      5,000
       2% FCI      2,000/yr
             S/batch
 0.13
 1.53
 2.00

22.00
11.00
                                                                            $/week
   5.0


   4.0

  44.0
  22.0

 396.0
 104.0
  40.0

$615/week

$0.12/gal.
                                          92

-------
                                                                       Heavy Metal
                                                                       Treatment
Effluent
                                                                I	|
                                                                  (Not included m cyanide
                                                                  treatment investment)
                            Waste Storage (5000 gal. carbon steel)           2,500
                            Chlorine Storage                              —
                            Caustic Storage (200 gal. carbon steel)             500
                            Chlorine and Caustic Metering Systems          2,500
                            Waste Transfer Pump                           700
                            pH and Redox Control Systems                1,200
                            Alkaline Chlonnation Reactor (3000 gal.)       20,000

                                                 Purchased Equipment   27,200
                                                                     .._,.,. x.3.5
                                              Fixed Capital Investment  $95,270
                                                     Rounded to       $95,000
Basis: 5,000 gal/week, 2 Batches of 2,500 gal/week, 48 weeks/year
      100 ppm Copper Cyanide  100 ppm Sodium Cyanide
                      FIGURE C.12   DILUTE CYANIDE WASTE TREATMENT
                                                 93

-------
                        CHLORINATED HYDROCARBON WASTES

       This category of chlorinated hydrocarbons includes many types of materials, including
  insecticides, chlorinated  solvents, and  power-transformer heat-transfer oil  (PCB's). These
  solvents may contain oil, metal cuttings or other solid materials. Waste chlorinated  hydro-
  carbons that contain no solid  materials could be incinerated directly in  a furnace and the
  flue gas scrubbed (Figure C.13 and Table C.13).
                                         TABLE C.13

                   INCINERATION OF CHLORINATED HYDROCARBON LIQUID
Basis:      3,000 gal/day chlorinated hydrocarbon
          Operation 24 hrs/day, 5 days per week (240 days/yr)
          Fixed Capital Inv. $900,000
         Cost Item
 Units/hr.
Units/day
Units/yr.
                                                                         Unit
                                                                         Cost
$/day
Lime Hydrate
Cooling Water
Fuel
Power

Labor (Incl. Fringe)
Overhead

Depreciation      (20% FCI/yr)
Maintenance      ( 5% FCI/yr)
Insurance & Taxes  ( 2% FCI/yr)
 2,110lb       50,640 Ib
70,000 gal    1,680,000 gal
   180 gal        4,320 gal
   300 Kwh      7,200 Kwh

            16 hrs/day
            50% labor
                            0.012
                            0.05
                            0.10
                            0.01

                           $5.50
                           $208,000/yr
                           $ 52,000/yr
                           $ 21,000//r
                            608
                             84
                            432
                             72
                                            44

                                           867
                                           217
                                            87
                                                                              Total
                                                                            Savings
                                                      $2,499/day
                                                      $2,500/day
                                                       $0.83/gal
                                             94

-------
       r	1
Waste!   Filter
Lime °°
Slurry
O
A
We
*V
                                                                                                       Scrubber
                                                                                                        System
                                  I. Liquid Chlorinated Hydrocarbons

                                       Fuel Storage                               $  6,000
                                       Waste Storage                                28,000
                                       Fuel Metering Pump                             500
                                       Waste Metering Pump (Alloy)                      700
                                       In-Lme Mixer                                   400
                                       Air Compressor                              10,000
                                       FD Fan (Included in Furnace)
                                       Furnace & Afterburner (to 2800F)              85,000
                                       Spray Cooling Chamber                        20,000
                                       Scrubber                                   100,000
                                       Scrubber |,D. Fan                            10,000
                                       Lime Storage & Slurry System                  10,000
                                       Slurry Pump & Flowmeter                        600
                                       Stack                                        8,000

                                                Total Purchased Equipment          $279,200
                                                                                    x3.5

                                                Fixed Capital (Excl. Cool Tower)     $977,000
                                       Cooling Tower (Installed)                      60,000

                                                Total Fixed Capital Investment      $1,037,000
                                                Round to                        $1,040,000
           Basis: 3000 gal/day, 24 hrs/day
                 240 days/year
                                 FIGURE  C.13   INCINERATION COST OF CHLORINATED
                                                  HYDROCARBON LIQUIDS - CAPITAL COSTS
                                                                95

-------
                        ORGANIC WASTE REQUIRING A KILN

     Liquid chlorinated hydrocarbons that  contain solid matter would have to be filtered
and the sludge and clarified liquid fed separately to a kiln (Figure C.I4 and Table C.I4). The
tine  gas from the furnace  or kiln would be  cooled in a spray chamber then scrubbed with
dilute  alkali  in a two-stage scrubbing system (venturi + packed  column). Solid chlorinated
hydrocarbons would be fed directly to the kiln.

     For  our example we used  polychlorinated  biphcnyls with and without  a  solid con-
taminant.


                                      TABLE C.14

                INCINERATION OF  CHLORINATED HYDROCARBON SLURRY

                   Basis: 3,000 gal/day chlorinated hydrocarbon and solids
                        Operation  24 hrs/day, 5 days per week (240 days/yr)
                        Fixed Capital Investment $1,400,000
     Cost Item

  Lime Hydrate
  Cooling Water
  Fuel
  Power

  Labor (Incl. fringe)
  Overhead

  Depreciation
  Maintenance
  Insurance & Taxes
 Units/hr

 2,110 Ib
70,000 gal
   180 gal
   350 kw
 20% FCI/yr
  5% FCI/yr
  2% FCI/yr
 Units/day

  50,640
1,680,000
   4,320
   8,400

 32 hrs/day
Unit Cost

 0.012
 0.05
 0.01
 0.01

 5.50
    $252,000/yr
      63,000/yr
      25,000/yr
 $/day

  608
   84
  432
   84

  176
   88

 1,050
  262
  104

$2,888/day

$0.96/gal
                                          96

-------
                                                                               Lime
Waste

Waste


Oil


-ftl


_£.
J








9
i

., Q



i











— *i






° Mr
A '

Water












q,-.




\
















X '





f

Scrubber
System

1
T









L^-


                                     II. Chlorinated Hydrocarbon Slurries

                                           Fuel Storage
                                           Waste Storage & Settling Tank
                                           Sludge Conveyor
                                           2 Filter Pumps
                                           Shell Type Filter (Stainless Screens)
                                           Filtered Waste Storage
                                           Fuel Metering Pump
                                           Waste Metering Pumps
                                           In-Line Mixer
                                           Air Compressor
                                           Air Blower (Included with Kiln)
                                           Rotary Kiln (Including Feed Mechanisms)
                                                 and Afterburner
                                           Spray Cooling Chamber
                                           Scrubber System
                                           Scrubber I.D. Fan
                                           Lime Storage and Slurry System
                                           Lime Slurry Pump and  Flowmeter
                                           Stack
Purchased Equipment

     $  6,000
       20,000
        2,000
        2,000
        4,500
       28,000
          300
        1,700
          400
       10,000
      120,000
       20,000
      100,000
       10,000
       10,000
          600
        8,000
                                                            Total Purchased Equipment
     $343,500
         x3.5
                                                            Fixed Capital Investment
                                                               (Excl. Cool. Tower)
                                           Cooling Tower Installed
   $1,202,000

       60,000
                                                            Total Fixed Capital Investment   $1,262,000
                                                            Round to                     $1,260,000
                 Basis: 3000 gal/day Chlorinated Hydrocarbon Slurry
                       Operation 24 hrs/day, 5 days per week (240 days/yr)
             FIGURE  C.14    INCINERATION OF CHLORINATED HYDROCARBON SLURRIES - CAPITAL COSTS
                                                                   97

-------
   DISINTEGRATION AND INCINERATION OF INSECTICIDE DRUMS AND PAILS

     We  have  considered  the economics of  a portable disintegrator for insecticide con-
tainers. We have based it, in part, on our understanding of such a unit as conceptualized by
the Chemagro  Company. In its letter to the President's Cabinet Committee on the Environ-
ment,*  Chemagro proposed a portable insecticide-can disintegrator made up of:  (l)a
hammer  mill,  (2) an exhaust fan  to prevent  the dust from  leaving the hammer mill via a
negative  pressure, (3) a high-temperature incinerator for  the dust laden exhaust air and
(4) appropriate scrubbing system, so  one could disintegrate cans  and  at  the  same time
incinerate the  pesticide residues contained in  the cans. The company suggested that such a
portable  unit  would cost  on the  order of $300,000, and that  it could go to the various
insecticide producing companies and distributors, who are accumulating 30- and 50-gallon
drums and 1-  and 5-gallon pails at the rate of 250,000 and 40 million, respectively, each
year.

     We  have not seen Chemagro's specific plans for such a unit but understand that it has
demonstrated  its feasibility in a stationary hammer mill and stationary incinerator scrubbing
system.

     We  have  made some very cursory economic calculations based on the following as-
sumptions:

     1.    The  hammer mill is operated in such fashion that it requires  an air flow-
          through rate of 60 volumes/minute for incineration (it turns out that this
          assumption is  not a critical one), and that the air is heated to 2100F before
          being discharged to a scrubber and to the atmosphere;

     2.    The  unit costs $300,000;

     3.    It takes two men to operate  the unit — one to feed the cans to the hammer
          mill, and one with a forklift  truck collecting the cans on  the storage lot and
          bringing them to the unit; and

     4.    The  feed rate is equivalent to one 50-gallon can per  minute, or 14.4 tons/day
          of metal.

     Our calculations (Table C.I 5) indicate that fuel is the minor part of the operating cost
and that the fixed charges dominate all other costs. Furthermore, the  economics of the
entire system  are completely dictated  by the net value of the  scrap that is collected as a
result of this operation. Chemagro's letter to  the Government indicated that the scrap was
 ' Letter to the President's Cabinet Committee on the Environment, Subcommittee on Pesticides, Federal
  Working Group on Pesticides Management, by Dr. Robert C. Scott, Vice President of Manufacturing,
  Chemagro Division of Baychem Corporation, February 9, 1972.
                                         98

-------
                                       TABLE C.15

               COST OF WASTE WATER CONCENTRATION BY EVAPORATION
        Basis:   Evaporation of 1,000— 10,000 gallons water/day
                8 hrs/day operation, 260 days per year
                Submerged Combustion Evaporation
                                                          Gallons per Day
                                                 1,000         5,000          10,000
         Fixed Capital Investment (FCI)              375,000     $120,000       $150,000

         Operating Cost      ($/1,000 gal.)
           Utilities
              Gas          (at 704/1,000 ft.3)          6.73         6.73           673
              Electricity    (at  1cf/Kwh)              0.89         0 89           0.89
              Cooling Water (at  54/1,000 gal.)          1.67         1.67           167

           Labor                                  44.00         8 80           4.40
           Overhead (Admin.)                        22.00         440           2.20

           Depreciation     (at 20% FCI  per year)       57.69         18.46          11.54
           Maintenance     (at 5% FCI per year)       14.42         4.62           288
           Insurance        (at 2% FCI per year)        5.77         1 35           1  15
              Total Operating Cost ($ per 1,000 gal.)   $153.17       $47.42         $3146
evaluated by several steel companies as being number I grade. This may well be the ease for
these disintegrated  50-gallon  drums;  however, we have  conservatively assumed that  the
5-galIon and 1-gallon pails, being of much thinner steel, would be evaluated  as the equivalent
of an automotive grade scrap  (very thin). This scrap currently sells for $40/ton delivered at
the  steel  mills. However, the market fluctuates  violently between  S10 and  S40
-------
     If  the portable unit  could be  built  for  $150,000 instead of  $300,000 and  the
economics were evaluated on the basis of one man/shift operating the  unit (presumably  a
second  man being provided by the company disposing the pails), the estimated operating
cost is  only $252/day, with a  $72/day credit  to the scrap, and a net disposal cost of
37^/pail. Stated another way, this less expensive operation could break even at scrap values
of $27.50/ton (or a net  of $17.50/ton to the portable unit operator). (See Table C.I 6.)

                                      TABLE C.16

                        PORTABLE INSECTICIDE CAN DESTROYER
                  (Assumed capacity 3600 Ib/metal hour, 1 shift/day operation)
        Fuel, 4.4 MM Btu/hr @ 15«(/gal                     $   6
        Labor, 2 men/shift @ $3.50/hr                        88
        Overhead                                         44
        Depreciation, $300,000 investment @ 5 years           240
        Maintenance @ 5% or $15,000/yr                      60
                                                     $ 438/day or $0.91/drum
        Credit for 14.4 tons/day steel
          @$15/ton delivered*                            -72
                                                     $ 366 or net cost $0.76/drum
        *Assumes $10/ton delivery cost to steel mill.

     Obviously, these economics are not accurate enough to draw any general conclusions
other than to say that the economics of a portable  insecticide  can  destroyer  are grossly
determined by:  (a) the capital cost of the equipment and (b) the net scrap value for the cans
destroyed.
                                          100

-------
 APPENDIX D




RISK ANALYSIS
     101

-------
                             GENERAL METHODOLOGY

     To arrive at the total risk of a hazardous waste disposal scheme one  must divide tin
scheme into operational steps  for which  individual  risks can  be calculated  and finalh
slimmed. For example, a disposal  scheme  may consist  of the following steps,  wastes are
stored  at the source, then transferred to tank cars, transported by  rail to a local disposal site.
transferred to holding storage tanks at  the disposal site and finally processed. The degree ui
risk to which society is exposed from such an operation is a function of the  probability that
an accident will occur during any one of these steps, the probability of waste release given
an accident, and the probability of creating one or more hazards to society given a release

     In arriving at  the probability  of an  accident,  one  employs  previous statistics  on
accidents in similar operations. The next step is to determine the probability of release given
an accident and finally  the  probability of fatality or injury or  permanent environmental
damage given the  release  of waste. This type of information i.an be  derived only from
technical considerations, and depends on such factors as:

     •   The physical, chemical and biological properties of the waste,

     •   l:\pected quantity and rate of release;

     •   Population density along route  of travel and  near generating and disposal
         sites;

     •   Protective measures taken  to prevent the accidental release of waste (i.e .
         method of packaging, transfer procedures, etc.);

     •   Ease of neutralization and/or  containment of the waste;

     •   Contingency planning.

     Our discussion in  Part  2 showed  that  for the purposes of this study, transportation
accidents appear  to be the decisive factor in this  risk analysis.  The methodology derived
here is, therefore, essentially  for transport accidents.
                                         103

-------
                                RISK TO HUMAN LIFE

                              Definition of Acceptable Risk

     There  is  evidence to  suggest  that society  will accept  a technological risk  if it is
comparable to or lower than the risk to which the population is exposed in its everyday life.
Starr1'2  lias shown that, for the U.S. population, the statistical risk of death from disease
and accident (10~6  fatality/person-hr exposure) appears  to be a psychological yardstick for
establishing the  level  of acceptability of other risks.* He also showed that the public is
willing to accept "voluntary" risks (e.g., hunting, skiing, smoking, etc.I roughly 1000 times
greater  than "involuntary"  risks  (e.g.,  living  near a flammable  liquid storage tank or a
nuclear reactor). Other workers3-4'5 have  also used  similar units (e.g.,  fatality/person-hr
exposure) for estimating risk.

     We have collected or calculated the magnitudes of risks to which the U.S. population is
generally exposed in its everyday life. These are given in Table D.l  and  compared with some
values for the United Kingdom.
                                       TABLE D.1

                               TYPICAL VALUES OF RISK
                               (fatality/person-hr exposure)

                Risk of Death From          United States         United Kingdom

              disease and accident               1CT6 1/2
              fires at home                0.4x1(Ts           0.1x10"*  7
              accidents at home            2.1 x 10'*             3 x 1
-------
       risk.  As shown  in  Table D.2,  a  risk of  10 I0  fatality  per person-hour of  exposure is
       practically insignificant, costing, at most, 1  to 3 days in a life of 60-80 years A risk of 10 "
       fatality per person-hour of exposure  is not insignificant, but the times involved are small
       enough so individuals are generally willing to accept it. However, a risk of 10~x fatality per
       person-hour  may  be marginally acceptable and   10~7  fatality  per  person-hour  is clearly
       unacceptable  unless  there  are  considerable justifications  or benefits for the individual
       involved.

            From Table D.2,  it can be  inferred  that many, perhaps  most, people who are in-
       voluntarily exposed to a hazard  would accept a risk level of 10"v  fatality per person-hour ol
       exposure or less as "very small" and would  consider 10"7  fatality or more per person-horn
       as not "very  small," if these risks were shown  in terms of reduction of lifetime. Thus the
       risk  analysis  task  became one of determining whether a particular disposal scheme would
       entail a risk of less than or more than 10~9 fatality per person-hour of exposure.
                                              TABLE D.2

                 EXPECTED REDUCTION IN LIFETIME FROM A CONTINUOUS, LIFELONG,
                                       THREAT OF FATALITY
Probability of Fatality
per Hour of Exposure
Expected Recurrence
     Interval
      (Years)
(40)*
                                                                   Expected Reduction in Lifetime
(60)
(80)
(TOO)
       10'1 '
       10'9
       10~
     1,140,771

      114,077

        11,408

         1,141

          114

         11.4
12hrs
5.1 days
1.7 mos.
1.4 yrs.
10.4 yrs.
31.1 yrs
1 2da/s
1 1 2 days
3.8 mos.
3.0 yrs.
20.7 yrs.
50.4 yrs
2.1 days
20.5 days
6.7 mos.
5.2 yrs.
33.0 yrs.
70 0 yrs.
3 2
-------
                       Calculating Risk from Fires or Explosions

     In calculating risks from accidents resulting in fire, explosion, radioactivity or toxic gas
release, a parameter essential for the risk calculation is the "kill radius" which determines
the "kill area" of the particular hazard. The "kill area" is that within which humans will die
(or assume  they will  die) as a result of  the  accident and  the  subsequent release of the
ha/ardous waste. It should be pointed out that quite often, in making its decision to accept
or reject a particular risk, society assumes  death for all who are exposed even though deatli
is not likely  to occur.
        L Radius Jor Fires.  If a combustible waste should accidentally spill and ignite, the
lethal thermal radiation flux (Btu/hr-ft2) from the resulting fire will define the kill radius.
We selected a thermal radiation flux  of 10,000 Btu/hr-ft2 as the  lethal  threshold. At this
level, clothing, frame homes and vegetation would ignite and endanger the life of anyone
present.  Although lower levels  of thermal  radiation can cause severe  burns  and result  in
death upon long exposure, we  assume that  people exposed to lower levels of radiation will
generally  take  shelter and  shield themselves  from thermal  radiation by simply  standing
behind a wall, a tree or a vehicle.

     A method of calculating radiation flux for any separation distance, fire  size,  and fuel
has been developed.8 If a massive vehicle rupture that spills all the fuel instantaneously (the
worst case) is assumed, the farthest distance at which the lethal radiation flux will be felt
can be calculated.

     To  analyze the worst case, we assumed that  the volume spilled covers the area
necessary to give a spill depth of 0.5 inch. On this basis, we calculated the thermal radiation
flux at  different distances for a given set  of  fire conditions  to determine the distance  at
which the flux is 10,000 Btu/hr-ft2 .

     Kill Radius for Explosions.  As  discussed in Part  2,  the  kill radius  of explosion
resulting from the rupture of flammable liquid containers was within the fire kill radius. The
Army Material Command  has published9 safe separation distances  for various types and
quantities  of explosives. In our analysis we used as the  kill radius the separation  distance
defined by the Army. We also discounted the fact that any explosion is likely  to be damped
by the container and concerned ourselves with unconfined explosions since these represent
the worst case. For the small quantities of explosive wastes that are expected to be  shipped,
the AMC Manual recommends an exclusion distance of 500 feet. This was used as the "kill"
radius for explosive accidents.

     Kill Radius for Radioactive Wastes.  The "kill" radius for radioactive chemical spills is
not  as easily defined as that for explosion or fire. The effect of exposure to radioactive
materials varies with the type of radioisotope released,  the duration of exposure and the
dosage.  Furthermore, death  from  radioactivity is not  immediate. However,  the  public-
perceives a radioactive  spill  as fatal to those  exposed regardless  of  the  dosage or the
exposure duration.

                                          106

-------
     Adams and Stone10 indicate  that  for  releases  up lo  1000 Ci  of  '^'I,  very  fe\v
casualties would be  expected beyond one mile. We have employed a "kill" radius of two
miles in  our analysis, which is quite conservative considering the small amounts of radio-
active wastes expected to be shipped and the  low  radiation  levels that would be released in
an accident. These levels are  expected to be much less than the 1000 Ci of  ' 3 ' I that wouk!
be typically released  in a major nuclear reactor failure.

     "Kill"  Radius  for  Toxic Gases. The toxic  gaseous wastes  identified in this study
included CW agents.  Unlike the dispersion of gases in air, the dispersion of CW aerosols in an
is difficult to predict theoretically since the aerosol persists for many days.

     The results of military tests on dispersion  of CW agents are classified. Published  data '  '
indicate  that "under favorable  meteorological conditions, the detonation or vaporization
cloud  may  spread   up  to 30 kilometers  from  the point of origin.  Beyond  that range,
concentrations may still be present which lead  to combat incapacity."

     it appears  that a conservative estimate  of the size of a vapor cloud  from  a  CW gas
release would  be 40 miles (64 km) long and 5 miles (8 km) wide, giving a "kill" area of 200
square miles.

     Estimating the  Probable Risk. Once the  kill radius, R, is known, one  can estimate the
probable risk incurred from transporting a flammable or explosive radioactive material along
some route  of length L and population density p. As long as the route length is much larger
than the kill radius  (which  it almost always is), the total number of people who could be
exposed  to  the  fire* hazard is 2RLp. At any given moment, however, only those people
within a distance R of the truck transporting  the hazard will be exposed to risk. This lattei
number of people is equal to

                                      ?rR2pP(p)

where:

            TrR2  =   circle  whose  center point  is the  truck  transporting the  haz-
                     ardous waste and whose radius is equal to the kill radius.

               p =   population density along route.

            P(p) =   probability  of a given person's being present when the accident
                     occurs.

     By definition ?rR2pP(p) people will become fatalities should an accident occur.
 * This applies equally to explosives and radioactive release.
                                         107

-------
     The probabilistic expected value of fires per year is given by:

                        fires
                             =  P(a) • L • n • P(f/a)
                        year
where:
     P(a)    =    probability of an accident per vehicle mile (derived from statistical
                 data).

       L    =    route length (miles).

       n    =    number of trips per year.

    P(f/a)   =    probability of a fire, given an accident.

     Each person within  the  area exposed to  the  hazard  of possible fire,  explosion, or
radioactive release is present in that area for some fraction (hours) of a year given by 8760 P(p).
From the  point of view of each individual present, whenever he is within the exposed area
he is exposed to  the risk of a vehicle passing by and having an accident. Thus, the possible
number of exposure-hours is equal to the number of hours  in a year times the population
density along the route times the probabilistic  value of some segment of the population
being within the risk area when the accident occurs, or

                        Exposure-hours/year = 8760 (2RLp)P(p)

     We can now  calculate fatalities per exposure-hour as follows:

                          Fires, Explosions or             Fatalities per Fire,  Ex-
       _     .             Radioactive Releases     X      plosion  or Radioactive
       Fatalities  per                                             „ ,
                 :"      _  	per year	Retease	     _
       Exposure-hour                                      -    •-
                                     Exposure-hours per year

Or:
       Fatalities per    _
       Exposure-hour            8760 • (2RLp) • P(p)
Which reduces to:
                          P(a) x P(f/a) x nLF       ...
                          	= tatalities/exposure-hour
                                  HT
                                         108

-------
where :

     P(a)    = probability of an accident per vehicle mile per year.
     P(f/a)  = probability of a fire (explosion) given an accident.
     n      = number of trips per year.
     L      = length of trip (miles).
     F      = fatalities per fire (explosion or radioactive release) = (;rR2p)P(p).
     H      = humans exposed per year = (2RLp).
     T      = exposure hours per person per year = 8760 P(p).
     R      = kill radius.
     P      = population density per unit area.
     P(p)    = probability of person being within kill radius during accident.

     The same equation can be used for estimating the risk of toxic gas release except that a
"kill area" is used. The expression for F becomes (XYp) P(p) where X and Y are the width
and length, respectively, of the toxic  vapor cloud. The expression for H becomes (2YLp).
                                        109

-------
                   CALCULATION OF WATER POLLUTION RISK

                                    Transport Risk

     One unit that may be used for assessing water pollution risk is the probabilistic amount
of water that can be polluted given a spill of a hazardous waste. To arrive at this number,
the probabilistic quantity of the waste that can be spilled  in a year during transportation,
Qst, and the acceptable critical concentration level of the waste, Cc, should be found.

     The ratio QS^/CC would then represent  the volume of water that would be necessary to
dilute the spilled waste to a harmless level of concentration.

     A system for ranking hazardous materials was developed by Dawsori, et. al.,12 in which
the minimum  concentration required to produce a detrimental effect (kill fish, make people
sick, upset ecological balance, etc.) was given for a large  number of hazardous materials.
These minimum concentrations were defined in terms of human toxicity, aquatic toxicity,
aesthetic effect, and plant toxicity. The lowest of the toxic critical concentrations was used
for Cc (mg/liter) in our analysis.

     Qsj. is the quantity of the hazardous chemical that may be accidentally spilled every
year (mg/yr). The value of Qs^ is derived from the quantity of material shipped per year, the
concentration of the hazardous waste as shipped, the probability of an accident in which the
material is spilled, and the  probability of a spill's reaching a body of water. It can be found
from the equation

                                    Qst = «0 (pst)

where:

         q  = the quantity of hazardous material in each shipment
       PS*  = the probability of a spill occurring during transport
            = (	™	)  (total miles trans, along route/yr)
              Vehicle-miles/

     The value  of  PS* will depend  on the safety record  of the mode of transport  used
(derived from previous statistics) as well as on the distance travelled.

     The results for a hypothetical case are shown in Table D.3. These data are based on one
plant in the Northeast that produces one million gallons of a 2-3%  solution or organic and
inorganic arsenites  and arsenates every  three months.  The waste may  be shipped to two
alternative  sites where it is treated by evaporation, encapsulation in pitch, and burial in a
land fill. Although the same disposal method is used, the waste may be shipped 1,00 miles in
30,000-gallon  railroad tank cars to site I or  trucked 10 miles in 9,000-gallon tank trucks to
site II. The  results  show that from a transportation standpoint,  site II presents society a
lower risk of pollution than site I.

                                        110

-------
                                      TABLE D.3

            TRANSPORT AND TRANSFER SPILL RISK: HYPOTHETICAL EXAMPLE

                                                Site I             Sited
            Mode of transport
            Distance of travel (miles/trip)
            Trips/yr
            Load/trip (gal)
            Spills/mile*
            Qst/Cc (liters/yr)
            Qsp/Cc (Irters/yr)
            Total (liters/yr)
Railroad car
100
133
30,000
1.9 x 10~8
16 x 106
Tank Truck
10
445
9,000
3.6 x 10~*
3.2x 106
15x 106
31 x 10"
  51 x 106
54.2 x 106
              Statistics from National Tank Truck Carriers Conference, Association of
              American Railroads and Federal Railroad Administration.
                                     Transfer Risk

     In our analysis  of risk we excluded data based  on spills during transfer operations in
part because prudent operation will  reduce this risk and in part because transfer risk can be
analyzed  meaningfully only in  terms of a specific site. However, we  have described the
method, based on the same hypothetical example used to describe transport risk, since  it
may later be useful  to define levels of risk  during  transfer when specific sites are being
considered.

     There is a risk of spillage during the transfer of material into and out of the vehicle at
the source and at the disposal site. The quantity spilled at each transfer point per year will
depend on the number of transfer operations performed per year, the flow rate of the waste
during filling and unloading, the probability of spill per operation, and  the time that a spill
is allowed to continue before it is stopped. This probabilistic spilled quantity can then be
used in a "critical concentration  analysis" similar to the one  desciibed  for the transport
process, provided  that certain assumptions are made  regarding  the probability of a spill
reaching water.

     The  probabilistic  quantity  spilled, Qsp (mg of hazardous  waste), can be expressed as
           (Psp)(m)(t)
                                          111

-------
where:

      N  =  the number of transfer operations performed annually.

     P t  = the probability of a spill oecurring during a transfer,

      in  = the flow rate of water-free hazardous waste (in mg/sec).

       t  = the average time between  occurrence of the spills and stoppage of the
            spill (sec).

     This QSD can be divided by  the critical concentration C , (mg/liter) to give the volume
of water required for dilution annually, assuming again that all liquid spilled finds its way
into water.

     As a first approximation, we assumed in our hypothetical example that once in every
1000 transfers, the contents of a  20-ft  length of 6" ID filling pipe will spill. That is, we took
I>   to be 10~3 and the  product  (m) (t) to be the chemical waste content of 25 gallons of
waste solution.

     The results for the  hypothetical problem cited  here are also shown in Table  D.3. The
total environmental damage from transportation and transfer spills is also given. It appears
for this example that, on the whole, site 1 is safer than site II.

     The analysis can be refined  if the probable spill location is taken  into account. Spills
occurring along a waterway will cause immediate pollution, while those occurring inland will
not. Inland spills can be broken down  into those occurring in highly  populated areas, where
the sewer  system  will funnel a spill into water very quickly, and those occurring in rural
areas,  where  the  spill  reaches water through  a  relatively slow leaching process. As a first
approximation one  can include  the effect of  these factors by  assuming that sewer line
density is directly proportional to population density and that the time that a spill takes to
get to water is inversely proportional to the sewer density.
                                          112

-------
                          ACCEPTABLE POLLUTION RISK

     As mentioned in Part 2, no yardstick was found in the literature that eould he used to
gauge  the  level of  pollution that society is  willing to  aceept.  We considered several
possibilities such as converting pollution risk level to a potential human fatality/person-hour
exposure and comparing this number with 10~9  fatality/person-hour exposure as suggested
by Starr1 >2 or estimating the percentage of the total water shed along the route of transport
that  could  potentially be polluted and comparing that value with some acceptable level such
as 0.1% per year, or estimating the cost  of recovering or cleaning the polluted water and
comparing  this cost  with the total cost of disposal or the cost that society pays for clean
water.  Such schemes suffered from either a lack of data or the difficulty in arriving at or
estimating certain parameters. The most promising approach appeared to be that which we
described in Part 2 in which the quantity  of the waste  that society  normally voids into its
waters from manufactured consumer products is used as an acceptability yardstick. The data
needed to arrive at this yardstick will be available shortly.13  For the present, however,  the
absolute volume of water that could potentially be polluted every year due to accidents will
have to be used only  to compare two or more disposal sites away from the source or to
compare different modes of transportation.
                                         113

-------
                     REFERENCES TO APPENDIX D

 1.  Starr, C.,  "Social Benefits  Versus Technological  Risk,"  Science,  165.
    \ 232-37 (19 September 1969).

 2.  Starr, C., "Benefit-Cost Studies in Socio-Technical Systems,1 Proceedings of
    the Conference on Hazard Evaluation and Risk Analysis, Houston, Texas
    (August,  1971)  sponsored  by  the Committee on  Hazardous Materials,
    National Academy of Sciences, Washington, D.C.

 3.  Kletz, T. A., "Hazard Analysis-A  Quantitative  Approach to Safety," Pro-
    ceedings of the Symposium on Loss Prevention in the Chemical Industry,
    Institution of Chemical Engineers, London  (1971).

 4.  Sinclair,  C., "Technological  Change  and Risk," University  of  Sussex,
    Brighton, U.K.

 5.  Baldwin,  R., "Some Notes on the Mathematical Analysis of Safety," Fire
    Research Note No. 909, Fire Research Station, Borehaniwood, U.K. (1972).

 6.  "Injury  Rates by  Industry,  1970," BLS  Report No. 406, U.S. Dept.  of
    Labor, Bureau of Labor Statistics, G.P.O. (1971).

 7.  Fry, J. F.,  "An Estimate  of the Risk of Death When Staying in a Hotel,"
    Institute of Fire Engineers Quarterly, 30, 77 (1970).

 8.  Atallah, S. and Allan, D., "Safe  Separation Distances from Liquid Fuel
    Fires," Fire Technology, 7 (1971).

 9.  U.S. Army Material Command, "AMC Safety Manual" (1970).

10.  Adams,  C. A., and Stone,  C. N.   "Safety and Siting of  Nuclear Power
    Stations in  the United Kingdom," Reprint from  "Containment and  Siting of
    Nuclear  Power  Plants,"  International Atomic Energy  Agency,  Vienna
    (1967).

11.  TRW, "Profile Reports on Organophosphorus Nerve  Agents, CB(287) and
    VX(288),"  Fifth  Monthly  Progress Report  to Environmental  Protection
    Agency, Contract 21485-6005-TO-OO (1972).

12.  Dawson, G. H., et. al., "Control Spillage of Hazardous Substances," Report
    No.  15090 FOZ 10/70, Government Printing Office (1970).

13.  Berkowitz, J., "Catalog of Manufactured  Products Having Water Pollution
    Potential," Final Report to EPA, Contract 68-01-0102 (1973).
                                  114

-------
            APPENDIX E




ANALYSIS OF FEDERAL AND STATE LAWS

-------
                     FEDERAL LEGISLATION AND STATUTES

     We analyzed the structures of Federal legislation and  statutes relating to hazardous
wastes as of September 1972  (Table E.I). We have also indicated those offices within the
Executive Branch (Figure E.I and Table E.2) and within the Congress (Table E.3) that
might have an interest in or control over hazardous wastes.

     The Federal statutes that  we identified as being of interest to this case are as follows:

      1.  Federal Water Pollution Control Act
      2.  Rivers and Harbors Act of 1899
      3.  The Solid  Waste Disposal Act
      4.  Air Pollution Prevention and Control Act
      5.  National Environmental Policy Act
      6.  Carriage of Explosives or  Dangerous Substances
      7.  Federal Insecticide, Fungicide, and Rodenticide Act
      8.  Food, Drug, and Cosmetic Act
      9.  Hazardous Substances Act
     10.  Department of Transportation Act
     11.  Community Facilities and Advance Land Acquisitions
     12.  Public Works and Economic Development
     13.  Explosives and Other Dangerous Articles
     14.  National Wilderness Preservation System
     15.  Marine Resources and Engineering Development
     16.  Atomic Energy Act
     17.  Proposed Toxic Substances Control Act of 1972.

     Of these 17, the first 10 seek  to cope directly with problems in the environment or to
people and thus are of particular interest.

     The categories of information which we included in Table E.I  are described below. The
table is not meant to be a lawyer's analysis, but merely a convenient device for presenting to
a variety of users those characteristics of Federal statutes important to this research effort.
However, the table maps the topography of Federal legislation and paves the way for more
detailed examination of legal language and regulation as the need arises.

     For each  statute the  following information is included:  (1) the formal title, (2) the
common name (or Short Title), and (3) the reference information for locating the statute in
the U.S.  Code Annotated. In many instances each amendment to a statute has  a common
name; this name is also included for reference.

     For emphasis,  statements  considered to be particularly relevant  are underlined  or
boxed within each of the categories. Some subjective comments gleaned from various  books
and papers are referenced in parentheses.
                                       117

-------
LAW:

Listed here are the one or several means of identifying a statute, beginning with
the most general and descriptive title. For example, "Pollution Control of Navi-
gable Waters" is the title of that chapter on the U.S. Code Annotated, the number
of which is cited,  which includes a series of Federal laws described by the  title
specified in legislation.

PURPOSE:

We summarize what is usually set  forth in the "Declaration of Purpose" clause
beginning each statute, but in some cases include our own interpretation of the
major thrust of the statute.

EXECUTIVE AGENCY RESPONSIBLE/NATURE OF POWERS:

Listed here is the  executive agency responsible  now. In many cases this differs
from the agency designated by Congress originally, because  offices formerly in,
for example, the Department of the Interior were reassigned to the Environmental
Protection Agency when it was created.

This entry also shows various types of administrative and legal powers assigned to
the agency by the statute. We have used four categories:

•   Adjudicatory: having quasi-judicial powers,  including  the right to hold hear-
    ings;

•   Promotional:  having  the power to promote  the purposes of the statute,
    typically by means of financial aid and Federal administrative support;

•   Rule-making:  having  power to set standards and rules within guidelines set
    by Congress; and

•   Advisory: having authority only to suggest  and recommend actions,  and to
    carry out research and development activities which may or may not lead to
    action by other Federal agencies or state and local government bodies.

TYPES OF HAZARDOUS SUBSTANCES:

Here we summarize the categories of substances covered by the statute. Clearly,
many "substances" of concern to  legislatures in  the past  are riot "hazardous
wastes" within the meaning of this research effort. Presently, some "wastes" are
components of "substances." One legislative task resulting from this search  may
be  to amend  present  statutes,  to make them  apply  more  specifically to
"hazardous wastes."

                                   118

-------
BASIC CONTROL STRATEGY:

This column  lists our summary of how the authors of each statute sought to
control  the refuse or hazardous substance. The spectrum ranges from none to
stringent: from mere research efforts to setting of standards (more or less restric-
tive), to firm  central control, as in the case of radioactive wastes. The strategy of
control  reflects Congress's theory  at the time of enactment about (1) what the
problem is, and (2) what the federal government can and should do about the
problem.

TECHNIQUES:

This column  lists the specific means  by which the control  strategy is to  be
effected, such as  making matching  grants,  requiring permits, and  establishing
standards.

ENFORCEMENT  POWERS:

This column  outlines  the provisions for assuring compliance with the statute.
Statutory standards  may  be enforced either through administrative action or by
bringing an action in a court of law or equity. Among the variety of enforcement
techniques that an agency might employ are the following:

•   Seek an injunction in court to halt the prohibited acts.
•   Assess fines for violation (hopefully acts as deterrent).
•   Impose criminal sanctions for violation.
•   Issue cease and desist orders.
•   Deny or  withhold permits.

STRENGTHS AND WEAKNESSES:

These two  columns  list  assessments by various analysts,  including ourselves,
summarizing experience to date.

AMENDMENTS PENDING:

In a few cases, bills now pending before Congress could, if enacted, significantly
modify  the statutes now on the books, and  are therefore  important to our
thinking. For example, one section of the "Water Quality Improvement Act of
1970," which is now Section 1162 of the U.S. Code, requires the President, using
the EPA, to draw up and publish a list of "hazardous substances" and how to
control  them; he  has, accordingly, proposed the "Toxic  Substances Control Act
of 1972," now pending as a bill before the House of Representatives.
                                  119

-------
EFFECTIVENESS TO DATE:

In this column we report such summary judgment as we have obtained as to how
the statutes have been applied in practice.

APPLICATIONS TO STATE AND LOCAL GOVERNMENTS:

Information in this column  has  great administrative and legal importance, con-
cerning both the Federal structure  of American  government  and the questions
before this case.  The  extent to  which Congress  will reserve  1o  the  Federal
government powers to enforce  decisions in all  legal jurisdiction will critically
influence how effectively wastes can be disposed.
                                  120

-------
                TABLE E.I




FEDERAL LAWS RELATING TO HAZARDOUS WASTES
                    121





                                               Arthur D Little, Inc

-------
                                                       TABLE E.I (Continued)
      Purpose

To enhance the quality
and value of our water
resources and to establish
a national policy for the
prevention, control and
abatement of water
pollution.
                 Federal Laws Relating to Hazardous Wastes

        1 .a. Pollution Control of Navigable Waters: 33 USC 1151-1175*
   Exec. Agency Resp.
   Nature of Powers      Types of Hazardous Subs.     Basic Control Strategy
EPA

  Ajudicatory
(e.g., quasi-judicial
powers, including the
right to hold hearings).

  Promotional
(e.g., power to promote
purpose through finan-
cial aid).

  Rule Making
(in certain circum-
stances)

  Advisory
(e.g., carry out research
& development activi-
ties).

ATTORNEY GENERAL
                              When referred by EPA
                              for court action.
Sewage discharges into
any waters.

Pollution in interstate
waters and parts thereof.
1. Federal government
  stimulates & funds
  Planning, Investiga-
  tion, and Research.

2. Relies on States to
  establish & enforce
  standards. Federal
  EPA to set standards
  only after states fail
  to do so, except in
  interstate cases.
         Techniques

Make joint investigations
with any Federal agencies,
with State water pollution
control agencies & interstate
agencies and the Municipalities
& industries of the condition
of any waters in any State or
States, and of the discharges
of any sewage, industrial
wastes, or substance which
may adversely affect such
waters.

Make grants not to exceed 50%
of administrative expenses
of a planning agency for a
period not to exceed 3 years
to develop an effective,
comprehensive water quality
control & abatement plan for a
basin.

Carry out research, investigations,
experiment demonstrations, &
studies alone & in  cooperation
with public authorities,
agencies & institutions and
private agencies & individuals.

Make grants for research and
development not to exceed 75%
of costs.

Require states to establish
standards for all interstate
& coastal waters.
      *Common mane(s):   "Federal Water Pollution Control Act"
                          "Water Quality Act of 1965"
                          "Water Quality Improvement Act of 1970"
                          "Clear Water Restoration Act of 1966"

     Amendments:  Amendments of 1956 - Amendments of 1961   Note: The Amendments of 1972, a major revision of these statutes
                                                                      are analyzed in Table E.l.b.
     Ref. to U.S. Code:  (incorporates 33 USC 466 et seq)
                                                                   122

-------
                                                             TABLE E.I (Continued)
 Enforcement Powers
                               Strengths
                                                          Weaknesses
                                                        Amendment Pending
                                                           Effectiveness
                                                              to Date
                                                 Applications to
                                                  State & Local
Three step process:

1. Convening conference
to secure action through
negotiation.

2. Public hearing to
receive testimony.

3. Federal court action
for non-compliance.

If standards violated:
  1. 180 days notice
    to comply.
 2. Federal court
    action.
Fast action in case
of violation of
water quality stan-
dards. (Toxic Subs)

Demonstrates Federal
concern about pollu-
tion.

Initiate enforcement
action when States
fail to act in cases
of interstate pollu-
tion.
May be used only after pollution
has occurred and then, diffi-
cult to relate change in water
quality to a specific discharge.
          (GAO)

Federal authority limited at
conference since (a) no direct
Federal relation with polluters
and (b) no subpoena authority.
          (Lewin)

Depends on state initiative.
          (Lewin)

Underfunded.  (Degler)

No authority to enforce specific
effluent restrictions which
would permit the  setting of
treatment requirements for
plants, before pollution became
a problem. (GAO)

Conference & hearing formalities
very slow.
          (GAO, Toxic Subs &
          Lewin)
                                                 Federal Government precluded from
                                                 playing a fully effective role
                                                 because of the requirement that
                                                 the Federal enforcement assist-
                                                 ance must be requested by the
                                                 state if only that state is
                                                 affected. (Lewin)

                                                 Vested interests generally
                                                 stronger at state than Federal
                                                 level. Probably unopposed at
                                                 most local levels. States weaker
                                                 in money & competence than
                                                 Federal government. (RT)
Administrator urging
legislation to provide
him with less time
consuming procedures
by eliminating public
hearing step.
        (Lewin)
Since 1970 Federal
enforcement actions
have become more
frequent & stronger.
     (GAO)

Only 51 Federal
actions taken in a
period of 14 years.
     (Degler)

States taken advan-
tage of:
                                                                                                        In many cases when
                                                                                                        conf. recommend-
                                                                                                        ations were not
                                                                                                        followed, confer-
                                                                                                        ences were recon-
                                                                                                        vened & dates for
                                                                                                        compliance extended.
                                                                                                             (GAO)
 Recognizes, preserves
 rights of states in
•preventing & control-
 ring water pollution.

 Depends on state
 initiative to apply
 for federal money.

 Agencies receiving
 grants are required
 to draw up & submit
 plans for EPA
 approval.

 State guidelines for
 setting standards
 included an order that
 standards would not
 be acceptable unless
 they provided for
 reduction of all
 existing municipal &
 industrial pollution
 within five years.
 (Degler)
                                                                       123

-------
                                        TABLE E.I  (Continued)
                     t.b.  Federal Water Pollution Control Act Amendments of  1972
                  Agency &
                  Powers
            Types  of Hazardous
                Substances
Basic Control
  Strategy
Techniques
Enforcement
   Powers
To achieve
wherever possible
by July 1, 1983
water clean
enough for
swimming and
other recreation-
al uses and clean
enough for pro-
tection and
propagation of
fish, shell-fish
and wildlife
                   EPA
                              Pollutants
Rule-making
States retain
primary responsi-
bility to prevent,
reduce and
eliminate water
pollution, but
within a national
program framework
Set specific dates
for industrial &
municipal discharges
to be treated & set
level of treatment

New grant program
with stringent
                               of specific actions   regulations

                                                  Expand water
                                                  quality standards
                                                  program

                                                  Require intrastate
                                                  standards to be
                                                  set by states by
                                                  April 1973

                                                  Require states to
                                                  hold public hearings
                                                  every 3 years to
                                                  review standards
                                                  and up-date

                                                  New system of
                                                  permits replacing
                                                  1899 Refuse Act
                                                                        Court injunc-
                                                                        tion when
                                                                        imminent
                                                                        danger
Take action
when states
do not or
cannot

Federal Aid

Permits

Inspection

Fine

Imprisonment
                              Hazardous
                              Substances-
                              defined  as
                              substances
                              presenting an
                              imminent and
                              substantial
                              danger to public
                              health or welfare,
                              including fish,
                              shell-fish, wild-
                              life,  shorelines
                              and beaches
                                                  Extends oil
                                                  pollution control,
                                                  liability & enforce-
                                                  ment provisions to
                                                  hazardous substances
                                                  (maybe 33 use 116x)
                                                  124

-------
                        TABLE E.I (Continued)
Strengths
                    Weaknesses
                                  Amend
                                            Effective
                                                       Application to
                                                       State and Local
Extends control     Except for
to all U.S. waters, permits and
not just interstate grants for
                    municipal
Strengths control
over toxic pollu-
tants

Allows for
citizens or groups
to sue to enforce
non-discretionary
actions of adminis-
trator, effluent
standards or orders
of administrator -
limited to persons
having an "interest"

Urges international
effluent standard
agreements

Small Business
Admin. loans
provided for
               May be
               amended
               to not
               exclude
waste treat-   EPA from
ment construe- NEPA
tion, exempts
EPA from NEPA
under this
bill
N/A      State issued permits
         subject to Federal
         veto

         States may adopt
         more stringent
         regulations

         In order to apply
         for permit, must
         obtain State
         certification

         If certification by
         one state results in
         a discharge not in
         compliance with
         standards in another,
         permit not granted
                                    125

-------
                                                 TABLE E.I (Continued)

                                                     2. Rivers & Harbors Act of 1899*
        Purpose

Prevent the creation of
any obstruction to the
navigable capacity of any
U.S. waters.
   Exec. Agency Resp.
   Nature of Powers

RPA
   Rule Making

Army Corps of Engineers
   Rule Making
  Types of Hazardous
      Substances
Any refuse matter, other
than that flowing from
streets and sewers, in
navigable waters.
  Basic Control Strategy

Monitor & limit amounts
discharged into waterways.
       Techniques

All waste dischargers re-
quired to apply for permits;
permits issued by Corps of
Engineers after review &
Approval by EPA.
"Common name(s): The Refuse Act of 1899.

Ref. to U.S. Code: 33USC 403 et seq.
                                                              126

-------
                                                              TABLE E.I (Continued)
   Enforcement Powers

Violation results in fine
of $500-2500 and/or 30
days-1 year imprisonment.

Prosecution of offenders
by U.S. attorneys when
requested by Secretary
of Army or any designated
officials.
       Strength

Violations can be
referred to the
Department of Justice
for court action
without delay.
      (GAO)~

Because of broad
judicial interpreta-
tion, provides valu-
able enforcement
tool by extending
Federal authority
to intermittent
discharges of waste
into navigable
waters.
      (Lewin)

Provides for immed-
iate court action.
   (Toxic Subs)

Through coordination
with Federal Water
Pollution Control
Act can extend auth-
ority to intrastate
waters where no
Federal Water Quality
Standards apply, as
well as to inter-
state waters.
      (Lewin)

Violators can be
convicted even if
pollution complies
with water quality
standards.
      (Lewin)

Application for
permits must include
data on composition
and volume of wastes,
precludes hiding
information on the
grounds of "indus-
trial secrets."
                                                            Weaknesses
                                Amendments
                                   Pending
Does not cover municipal liquid
sewage and therefore does not
cover industrial wastes going
into municipal sewers. (GAO)
Enforcement authority split
between EPA and Corps.
      (Toxic Subs)

Policy changed by memo from
Department of Justice (6/70)
directing U.S. Attorneys to
use in charges of non-contin-
uous nature
   1. emergencies,
   2. if so requested by Corps.
Continuous polluters fall under
jurisdiction of FWQ Administra-
tion. If liberal in defining
"emergencies" this may not limit
Act. (Lewin)
Effectiveness to Date

Few permits issued
prior to April 1971.
Registration requi-
red for 41,000 indus-
trial sources of
pollutants by mid
1971.
                                                                                                                              Applications to
                                                                                                                              State & Local
To obtain a permit
company must obtain
state certification
that it will be in
compliance with stand-
ards.

Enforcement powers
tend to subjugate role
of states.
      (Toxic Subs)
                                                                   127

-------
                                                      J3
                                                   4-1  5

CO
s
(X
•d
U-l
0
m
3
C
fe
5
cd
£
01
s
without

|
3
O
i
CO
CO U
£ f2
M
i
G
cS
0
1 1
t>
s
1
I
10/26/7

.c
Vt
o
C
to
"ft.
4J
o
Q.
S
•g
s
iJ
o
creatio
S
ffl
p.
C
o
.C
10 .
4J 4J
4J 5

M (8 •
s£ s

S 2-g
III
0) '
•o
U
C O

C U (U
oi oo td o
>H M M 0
o a o >>
-a
•-I C-4 r*» O
C
•H C
•H 01 11
§ "2 en M

UH *a TJ cu o G '
WO C -H 4J C O
'So S'^'s^u'S

IS "22^-S-esl
o o) "H "S M ° *
T3
 U
 3
 O
U
pa
<
H
                         8S"0 ° a
                         W ,
                         3  js i


                         ^H  O (
                                0   >.
                                iH   U
                                4J   0
                                  O     i-t a) C

                            33&IS   II2S   1
                              3 ° S S
                              COQjOiS   H >
                                                                  o   of.
   
-------
•a
 a>
 O
U
w
w
_)
03
•<
H
          g

          1
                  4 C bO
                  3 CO rj)
                    o in o
                    M O M
                    O. O D.
                                                                                               0) 4-> I
                                                                                               -o m i
»&
53
&1
i-t O1
0)
Si!
Federal
do
ra o
A 0)
rH Q>
0 -H
< «


I-t
Vl
0
15 3
*H
t*
T3 T-I
§0
s-
ul B
St >
C! i
O
X -t
4J 1-
w ^
w
^H
3 £
.0 n
I 0
4J
i u
5 n
*u
Q>
tH
bl
^

i
o
HI
r-l
u
0


i
4-1
3
o
-H
>
§
4~l
i
i
w







0)
u
B
0
4-»
4J
ej
i
a
td
additive
*H •
3 C
m o
s>3
§£
en o,

n)
-O
O
d)
4J
tU
H
i *
o  4-1

sub a tan-
to health
4 " h
1 a) a
, CO C
5 §^
>4 V ci
n«










                                                   129

-------
                                                                             w    S -O
                                                                                          •" CO 'O -H   V

                                                                                          ^ C C e OJ C
                                                                                          


 §

O
,-1
«

                                                      0) C 4
                                                         130

-------

                                                      QJ 4)
                                                      > ODj3    MMOUCJIX,
J -H 4-J  l-l
1 ffi O  O
                                                                                                                                                 T)    ai  in en  en
                                                                                                                                                 -H  ai-auww-a
                                                                                                                                                 O-a-riCGCH
                                                                                                                                                         QJ OJffl O
tu
w
j
CO
<
H
                           •H ffl  >

                            § »s
                            r-t C  U)

                            ffl 00 J2
                            OJ u  
-------
                            00   j: 4-»
                         a)  e  M  (0  w 4
                         D -H  a) xi  fl) >
                         (0  B Tf  O
                         in -H  vi  V)  c c
                                                                                C  CO '
                                                                                « JJ -
                                                                                    ! CU 00 00

                                                                                     C -H  O
T3
 (D

 c
V-*

 o
u
w
a
*§  > u N  -H  .
tO -H C fJ  ^3  I
    co a) iJ  rt  ;
o  O u -^  S  i

x  h "ft a  I  !
O  O l-l Of  rH  !
                                                                             8  I  •
                                                                                       S
                                                                                                                                     -  o
                                                                                                                                     I  U  tfi
                                                       13  
                                                                                                                                      (0
                                                                                                                                      a  cl
                                                                                                                                     £3
                                                                                                                                      O H

                                                                                                                                      O "4-1
                                                                                    132

-------
 CD

 G
'-*->

 O
U
PJ
J
CQ
<
H
0 W
•O 01
£ S
m fl
o
o to
S-H
M
rH 0.
"3
0 JJ

C E*.
••-<
b. tH
tn
$
0)
•&'
A

i-i
r-l <
M a

erf
O
g
4J
cd
•-I
•H



£
1


-------

cu
01 flj



J -H
" 8 CO*
W ,0 01
0 xwH
SO H
„ rH
5 g-g
S 5<2
to cu

§ n
T O
S
w
H
S
f->
W
J
§.
-0
1 s
8 H
0 -3
M U
3 §
« c
&.
8

E-i
M
W

D •
0 03
Q oi
/-*\ 2 3
i-rt *s 2
^ M w
 o
CO -H H CJ
OB CU CO
00 -H cS J3
o rt <+H 3
w 4-1 -H M CO
S2 ui ^ n) -H »w -r*
2 4J CO P. CO 4-1
S c o> co cd i£ -H
g M -H J3 rH
ST l-l 13 CU CO -H
^ 00 O U H d) O
43 ti 0 iH Cd
<0 co m -u y-i
^ 0 C -H
CO -H -H CO H M *•>
J3 CJ O 3 «
o 3 o a> to 01 o^
H O. AJ -»-i 1-1 co ^
CN
o
(*>
u
T3 C "
1 5 5
•r -H "
3 0)
U- -0
o o
'31 < U
•"J
lj' C «
J E3
T 0) O
t u u
D C
g tO
e > "w
33 5
-'
co
^•0

T j: rH 4.J 00
I- O fl) OJ h
"r 3 Tt Z) CO •

CU Ql CJ CO
- 4-) i:l CO S
tJ CO Cfl -H M
t cu E -o o
o cu j: QJ cO
2 w ^ a
J-J CO 1-1 O
u cd ,-< n-t o
S3 -H OJ -H
3 ^ rH
O >i .0
0 C ID T3 3
CO 



H
cO
§
0
h
fx<
<•
s

CJ
cd
^
01
&
•rH
•O
0>
cO •
3 co
0)
Is i
0 -H ^
vO
rn
M
U
O
'a "*
1 i

•S^ ^
0 § =
s M. o

•H rH
rH 01 *
•§ S S
Ck Q K
rsi


o>
j;
jj

d
O
•d
cu

j^
ations 1

s
I






a
o
•H
U
S
a
£

u
»









(U
>
•H

O
Cx,
X
1
en
C
Cfl
VI
r-l
<4H
O
S
s
h

s

o
U-I
c
o
•H
CO
a
O)
cu
cO
l-t
Formu



k
a
Q
-C
o
13
c
td
S

O
a.
a
o

o
4J
OJ T3 jj •
CU ^ C O C
I-H co nj a) o
,0 01 i— t W-l iH
(0 "W 4-1
O 00 .C 0) CB
-H C U rH
4-1 -H O CU 3
(J Vl ,Q ^ §
cd 3 cd C
hOC *J 0
CO 03
c -J d -i
3 VJ --I o cu
O O ffl -rl >->
C *W fl 4J UH
^ fO • cd co
CO M U. H
4J C J-l CU 3 CO
en ifl 4J OJ3 >,
cu cu £ co cu cd
,n e -H 3 K 13
















(i) 1 -
M- ^ « 3 ^
H r-H S ctj 3 "13
cd iw | K o- iX .
CD MorHbOrH*01
rH CU(OlHC!D?i
U W J -H 01 Hg
*J S O) W 'H -H rf ^J
k 00-T3T3rotfi^
* .. S! « 3 U 2 ,, I
COM •Hoa'OVicit^
3 C 4J ^| ,H 0 01 W
O^H CJQOrH -OO).,.
v- 13 to o co at S
0(3 Or-fQ)T3 «»-|Q
KCJ "a-H^OrHrHEiS
toes flj-ujaofdc;:
CT-H frjQ>em-H(-M



00 >,
C t-i
-H O
^ 4J
co td
•e o
C -H
O cu T3
•H H 3
4J 3 i-l
ra 03 -<

o
p.
-i 3
p. o
13 M M
(0 00
M-I a
01 o «
4-» 13
4J M H
10 O CU
H & J=
QJ M 4-J
s i °
^ !i*g .
«4H a rt co
CO 00 CO  -H
41 H -H 4J
J3 O CO to
4J m o co






CO
a*


a>

134

-------
                                 . 3 V
                                   O. i-(
                               i o .r: -H .c i
 0)
 3

'-»->
 C
 O
O
W
                       H Ji

                       ^-t
                       3 u
                                                                     S a
                                                                     •H 4J
                                                                        a
                                                                     4-1 4J
                                                                     O (C
                                                                     §5
                                                                      u jj a  
-------
 n!
•^3

 o
U
Cd
                  4-1 -O

                  OT d>


                  K *
                   3S.f
                   «  a o
01 o d
T3 -H 0)
  •M -H
O CO O
^ 55 m
                                           « c
                                                              d t-4
                                                              o cu
                                                              u d
3?
01 O
> -W
01 O
T)
  01

£ S
                                                                           «•§
                                                                           c ca
                                                                      3  gi^s
                                                                    5"f
                                                                 I  3.
C  S
      •H 3 O

        -§ 
-------
•o
 H >, 01
                                  c •-< o-
                                 •H 0) O
                                  O "O  CO
                                 .c a>  en
                                 •M u  o>
                                                                     Sin
                                                                               o  w

                                                                               oo  a
                                                                    I-H o -H TJ a.
                                                                     3 a   ^ S 4
                                                                     o g m to 3
                                                                    o -H -H oo*a
                                                                                              >     & i-l .£ O

                                                                                              4  X  >" >-< 4J

                                                                                                *-» jQ «f  — *J
                                                                                              i  (0  M :
                                                                                              i  t-t  , 'a  t-i to
it  V  tJ &

£3  S 3
                                                             137

-------
P-3
U
CO
^
H
                       -

a
                       en  c

                    h  o
                       O  <
                       O  C
                                   ° E: a)
                                   oo co -o
                                                        £ W
T3
 <9
 O
U
                    I  O U-l

                    dl    O

                    -O O
                    C oo ra

                    4J O (0
                             u t  ,H

                             S g "
                             T) -3 kl
                                                              a I
                                                              u n

                                                              w <*-i
                                                              4-1

                                                                203  •
                                                                ^1
                                            138

-------
                       O 0)
                       4J y
                     1   CJ
                       u cq
                       ft -W
                       
-------



Assistant Sec for
Health & Sci.
Affairs
-
Food & Drug
Administration

L^IJ



Is
il
II
a





















5 |
(J>^
II
s o
o> U

-------
                             TABLE E.2


          ORGANIZATIONAL UNITS IN FEDERAL EXECUTIVE BRANCH

                 WITH INTEREST IN HAZARDOUS WASTES


EXECUTIVE OFFICE OF THE PRESIDENT

          Domestic Council

          Formulates and coordinates domestic policy recommendations.
          Involved in policy decisions relevant to hazardous wastes.

          Office of Management and Budget

          Assist President in formulation of fiscal program of the
          government.  Assist President hv clearing and coordinating
          departmental.  Advise on proposed legislation, recommending
          Presidential action on legislative enactments.  Assist
          President in the consideration and clearance of executive
          orders.
          Involved in allocating budget and recommendations involving
          legislation for hazardous waste programs.

          Council of Economic Advisors

          Analyzes national economy and advises on economic developments,
          Involved in economic policy decisions that would indirectly
          relate to hazardous waste programs.

          Office of Science and Technology
          Evaluates major policies, plans and programs of science
          and technology of various agencies of Federal government.
          Potentially involved in the scientific assessment of the
          selection of national disposal sites for hazardous wastes.

          Council on Environmental Quality
          Established by NEPA to formulate national policies to
          promote the improvement of the quality of the environment.
          Potentially involved in the evaluation of the national
          disposal sites' impact on the environment.
DEPARTMENT OF DEFENSE

          Department of the Navy

               Office of the Judge Advocate General

               Provides advice and information on legal aspects of
               international relations, including ... law of the sea
               and of the sea beds, including marine pollution.
               Would be involved in any legal ramifications of
               ocean dumping of hazardous wastes.
                               141

-------
                           TABLE E.2  (continued)


          Department of the Army

               Corps of Engineers

               Administers laws for the protection of navigable
               waterways.
               Potentially involved in the administration of procedures
               involving transportation, treatment and disposal of
               hazardous wastes.
DEPARTMENT OF JUSTICE
          Land and Natural Resources Division

          The Assistant Attorney General in charge of this division
          supervises all suits and matters of a civil nature in the
          courts  relating to real property, including lands, water,
          other related natural resources, the Outer Continental Shelf,
          marine resources, the protection of the environment.  Among
          other functions of the division are the review of legislative
          proposals affecting matters within the scope of its litigation
          responsibilities.
          Would be involved in all legal aspects of the disposal of
          hazardous wastes, and the review of any proposed legislation
          covering hazardous wastes.
DEPARTMENT OF THE INTERIOR
          Assistant Secretary for Fish,  Wildlife & Parks

               National Park Service

          Assistant Secretary for Public Land Management

               Bureau of Land Management
          Both offices are involved in the administration of the
          Wilderness Preservation Act.
          Would be potentially involved in the decision of where
          to locate the national disposal sites.
                                  142

-------
                           TABLE  E.2  (Continued)


DEPARTMENT OF TRANSPORTATION

          Coast Guard

          Cooperates with other agencies in their law enforcement
          responsibilities, enforces conservation laws, is overseer of
          safety in shipping on inland and coastal waterways.  Involved
          in the safe transport of hazardous wastes by water.

          Federal Highway Administration

          Concerned with the total operation and environment of the
          highway systems, with particular emphasis on improvement of
          highway oriented aspects of safety.
          Directly involved in the safe transport of hazardous wastes
          on highways.

          Federal Railroad Administration

          Support rail transportation, research and development to
          improve rail and ground transportation.
          Directly involved in the safe transport of hazardous wastes
          by rail.

          Federal Aviation Administration

          Regulates air commerce to promote its safety and development.
          Directly involved in the safe transport of hazardous wastes
          by air.

          Assistant Secretary for Safety and Conservation Affairs

               Office of Hazardous Materials

               Develops and coordinates programs for the regulation of
               hazardous material.

          Assistant Secretary for Environmental and Urban Systems
               Office of Environmental and Urban Research

               Responsible for environmental and overall urban
               transportation needs, goals and policies; and innovative
               approaches to urban transportation and environmental
               enhancement programs.
               Involved in transportation aspects of hazardous wastes
               in urban areas.
                                 143

-------
                          TABLE E.2 (Continued)


DEPARTMENT OF AGRICULTURE

          Director for Science and Education

               Agricultural Research Service

               Improve crop and livestock yield and strains.
               Potentially involved in anything detrimental to that end.

          Assistant Secretary for Rural Development and Conservation

               Forest Service

               Administer national forests.
               Potentially involved in disposal site selection.

               Soil Conservation Service

               Directed to effectively utilize the productive capacity
               of soil and water resources with concern for problems of
               pollution and preservation of these resources.
               Potentially involved in disposal of hazardous  wastes with
               regard to soil pollution.


DEPARTMENT OF COMMERCE

          Assistant Secretary for Economic Affairs

               National Industrial Pollution Control Council  (NIPCC)

               Defines and reports potential control problem areas
               within industry.
               Would be concerned with hazardous wastes pollution from
               industry.

          National Oceanic and Atmospheric Administration

          Explore, map and chart the global  oceans and assess the seas'
          potential yield to the nation.  To manage, use and conserve
          these animal and mineral resources; to warn against impending
          environmental hazard.
          Involved in the handling of hazardous wastes so as  to protect
          the oceans.


DEPARTMENT OF HEALTH, EDUCATION AND WELFARE



               Food and Drue Administration

               Protects the public health of the nation by insuring that
               foods, drugs and cosmetics are safe, pure and properly
               labelled.
               Would be concerned with chemical substances being classified
               as hazardous.  May also be consulted on provisions for
               model law.

                                  144

-------
                          TABLE  E.2  (Continued)


INDEPENDENT AGENCIES

          Atomic Energy Commission

          To provide that the development, use and control of atomic
          energy will be directed to make the maximum contribution to
          the general welfare.
          Because of the peculiar nature of atomic energy, i.e.,  extremely
          hazardous, this agency has been delegated total power with
          regard to the various  aspects of dealing with atomic energy.
          It may therefore serve as a model agency for one to deal with
          hazardous substances in general.

          Environmental Protection Agency

          Created to permit coordinated and effective governmental action
          to assure the protection of the environment by abating and
          controlling pollution on a systematic basis.
          Would have overall responsibility for the administration of
          any program dealing with the disposal of hazardous wastes.
                                 -  145

-------
ro

W
w
          CO
          0)
          C/J
          cfl
 CO
 3
 o
•o

 CO
 N
 Cfl
ft


.5
          co
          0)

          0>
          4-1
          C
43
4-1
•H
          to
          CO
          0)
         C
         o
         CJ
         •H

         CD
         4-1
         •H


         5
 cfl
 S-i

44
 O
 3
 t-i
44
c/:
             CO
             w
             w
             H
             H
             O


             H

             H
             O









































W
H
Ed
CO



CO
t-i
•H
cfl
<-H
^4H
<]^

^
Cfl
i-H
3
CO
C
H

•o
C
cfl
j_,
O
'C
0)
4-1
G
H

0)
43
4-1
G
o
0)
0)
4J
•H
O
CJ






C
0
•H
4-1
Cfl
0)
S-i
o
01
PH

-O
C
cfl

to
^
t-i
cfl
PH
G
O
01
01
4-1
4-1
•H
E
g
O
a
•§
CO




















to
TO
G
cfl
rJ

O
•H
rH
43
3
P-i
C
0
01
01
4-1
4J
•H
e

O
U
•§
CO










rces
3
O
to
o>
04

V-i
Q)
^
O
fn

•a
G
cfl

S-i
0)
4-1
Cfl
S
C
o
0)
0)
4-1
4-1
•H

p
0
a
3
CO










                       S-l
                       0)
                       G
                      w

                       o
                      •H
                       C
                       O

                       01
                       01
                       44
                                o
                               CJ
                               •H
                                O
                                fi
                                o
                               •H
 CO
•H
 60
 01
C
o

OI
0)
44
                               o
                               o


                              CO




^
44
CO
0)
r-*
0


*"U
c
CO

0)
3
4J
rH
3
O
•H
t-l
60


G
O
01
O)
44
44
•H
e
e
o
u
d
o
•H
IJ
CO
0)
to
G
O
U

rH
•H
0
c/>

G
0
0)
0)
4J
44
•H
g
^
Q
O
i-Q
3
CO
























^
J-4
44
M
0)
r4
0
ftj

*"O
C
cO







44
a
0)
o
p*
•a
0)
43
to
S-l
0)
44
CO
^E

G
O
0)
a)
44
44
•rl
F3
v3
O
CJ
43
3
CO







                                                   to


                                                   o


                                                   o
                                                                                          ,0
                                                                                           c
                                                                                           o

                                                                                           0)
                                                                                           0)
                                                                                           o
                                                                                          CJ
                                                                                                   0)
                                                                                                   4-1
                                                                                                   cfl
                                                                                          0)
                                                                                          01
                                                                                          4->
                                                                                          •U   C
                                                                                          •H   O
                                                                                          e  -H
                                                                                          0  «
                                                                                          O   3
                                                                                          a  H
                                                                                          43  -H
                                                                                          3   O
                                                                                          CO  (Xi



to
C
o
•H
4-1
CO
•H
5-4
p.
0
S-i
CX
a
<[J

G
O
0)
a)
J_J
4-1
•H
d Related
cfl
/I I
Agriculture
c
0

o>
O>
4-1
44
•H to
g 0)
B -H
O U
0 C
43 O>
3 bQ
CO <1




Interior
14-1
o
Department
G
o

0)
Q)
4J
44
•H
a
£3
O
O
o
3
CO







CO
Q)
•H
O
G
CD
60
*C

TJ
OJ
4-1
rt
r-H
(1)
P*

'O
G
Cfl




A
O
3
14H
O
Department
c
o

CU
0)
4-1
4-1
•iH
^
g
O
o
43
3
CO




Related
T3
G
CO
on, Welfare
•H
4-1
cO
a
3
*T3
W
CD
» Oi

4-1 CJ
rH R
cfl O.i
0) 60
EC <






to
Public Work
c
o

0)
0)
4-1
4-1
•H

H
0
O

3
CO





G
O
4J
Transporta
c
o

QJ
01
4-1
4J
•H
e
e
o
o
43
3
CO


















0)
o
J-(
01
a
a
o
CJ

rj
O
0)
0)
44
44
•H
0
CJ
Natura

«
?->
60
rJ
O)
G
W

G
0

OJ
01
44
44
•H
Q
|3
O
O
43
3
CO





nment
0
S-i
•H
>
c
w

Q)
43
44

T3
G
cfl

CO
OJ
o
S-I
3
0
to
0)






44
§
43
CJ
S-i
01
a

01
43
44

G
O

01
0)
44
44
•H
g
E 0)
O G
O -iH
43 SJ
3 CO
W S







Q}
O
CO
MH
S-l
3
CO

G
O

0)
01
44
44
•H
a

o
o
43
3
CO
















C
o
•H
44
CO
44
S-l
O
o.
CO
G
cO
S-l
H





                                                                                                                                                 CJ
                                                                                                                                                 G
                                                                                                                                                 OI
                                                                                                                                                 t-i
                                                                                                                                                 t-l
                                                                                                                                                 3
                                                                                                                                                CJ
                                                                                                                                                 c«

                                                                                                                                                 ao
                                                                                                                                                 C
                                                                                                                                                 C
                                                                                                                                                 CO
                                                                                                                                                PQ

                                                                                                                                                 C
                                                                                                                                                 O

                                                                                                                                                 O)
                                                                                                                                                 01'
                                                                                                                                                •H



                                                                                                                                                 O
                                                                                    146

-------
 01
4-1
G
O
O
CO

w

w


H
00
W
H
<:
H
IS
w
CO
               td
               W
               CO
               o
               PS
                            13
                            G
                            cO

                            C
                            O
                                            tfl

                                            !-i
                                            a;
                                            tn
                                            C
                                            O
                                           c_>   to
                                                0)
                                            C   a
                                            O   VJ
                                                3
                                            QJ   O
                                            0)   CO
                                           J-J   0)
                                            O   M
                                            O   3
                                           £>  4J
                                            3   CO
                                           co  2;
                                                               •H
                                                                tfl
                                                3
                                                CO
                                                G
                                               id
                                                G
                                                cfl
                                                O
                                                •H

                                                01
                                                4-1
                                                G
                                                                C
                                                                O
                                                                Ol
                                                                Ol
                                                               4-J
                                                               •H
                                                               O
                                                               O
















CO

0
Dt
CJ
•H
"§
P-i
C
O
4J
•H
s
0
o
u


CO
f-l
0
'S
cfl
EC!

Tt
G
cfl
CO
0)
•H
Pi
C
o
0)
01
1 1
4-J
•H
O
0
"3
CO





G
0)
e
Q^
0
0)
^
01
Q

id
01
CO
OJ
1 1
cfl

C
O
0)
01
j 1
4-1
•H
O
O
3
CO





 60
 G
•H
 G
                                                                       13

                                                                        §

                                                                        co
                                                                        01
                                                                        C
                                                                        G
                                                                        O

                                                                        a;
                                                                        01















CO
G
O
•H
cfl
•H
f-l





OJ
^
3
4-J
rH
3
CJ
•H
^-i
60
^

G
O
01

-------
  NEW JERSEY LAWS AND REGULATIONS RELATING TO HAZARDOUS WASTES

                              Existing Laws (Table E.4)

     New Jersey Department  of Environmental Protection Act of  1970. The New Jersey
Department of Environmental Protection was established pursuant to reorganization legisla-
tion  (Chapter 33, P.L. 1970) enacted in 1970. The law amends existing statutes to transfer
various pollution control responsibilities from the State Department  of Health and other
agencies to a new Department of Environmental Protection.

     The  1970  law did not repeal or change any  provisions of existing air and  water
pollution  statutes  except  insofar as  the names of state  agencies were changed. The act
authorizes  the new department to undertake a  fairly broad  range  of administrative tech-
niques to control pollution and  to engage in various promotional  and planning activities
relating to environmental control.

     New Jersey Water Quality Improvement Act of 1971. The New Jersey Water Quality
Improvement Act of  1971 (Chapter  173,  P.L.  1971)  confers upon the Department of
Environmental Protection the power to deal with damage  caused by the unlawful discharge
of "petroleum products, debris and hazardous substances" into the waters of New Jersey.
Section 3 defines petroleum products, debris and hazardous substances very broadly.

     Section 4 prohibits the discharge of the defined substances in a manner which "allows
flow or run-off  into or upon the waters" of New Jersey arid the banks or shores of  said
waters.

     Section  5  empowers the Department  to undertake the clean-up  of the prohibited
discharges and hold the violator liable  for the cost.

     Section 6 provides fines and penalties for failure to notify the  Department immediately
of prohibited discharges. If the violation continues, each day during which it continues shall
constitute an additional, separate and distinct offense.

     Section  7 limits the total amount in fines for any one violator to $14 million except
where willful negligence or misconduct is present.

     Section  8  authorizes the Department  to bring a civil action  for injunctive relief to
prevent violations.

     Section  9 states that  the provisions of the Act shall not supersede any more stringent
local provisions or other state statutes.
                                        148

-------
     New Jersey Ocean Act (Chapter 177, P.L. 1971). The Clean Ocean Act provides for the
control of the dumping of  waste  materials in waters adjacent to  New Jersey. The Act
empowers the Department of Environmental Protection to promulgate regulations governing
the loading and handling of any vessel carrying sewage sludge, industrial wastes and the like
for disposal  in the ocean, and enables the state to require dumping farther from shore than
the 12-mile limit.

     Section 5 of the Act specifically provides for the issuance of permits and the charging
of fees by the Department.

     Section 6 provides for court actions for injunctive relief to prevent or stop violations
and fines to  be levied against violators.

     Pesticide Control Act  of 1971  (Chapter 177, P.L. 1971). This Act empowers the
Department of Environmental Protection to regulate the sale, labeling, and use of pesticides.
Under the provisions of the Act, the Department is authorized  to ban or restrict the use of
pesticides which are, or tend to be, dangerous to humans, wildlife, or the environment.

     The Act also establishes a nine-member pesticide control council as an advisory body
to the Department.

     Wetlands Act of 1970 (Chapter 272, P.L. 1970). The Wetlands Act provides for the
designation  by the  Commissioner of Environmental Protection  of certain coastal wetlands
after public  hearing. Any dredging,  removing, filling or other activity that alters or pollutes
such designated coastal wetland areas requires the issuance  of a permit by the Department.

     Section la  of  the law states the policy underlying the wetlands legislation. The need
for protecting and  preserving the ecological balance of these  areas is stated. Section  Ib
mandates that the Commissioner, within two years of the effective date of the act, make an
inventory and maps of all tidal wetlands within the State.

     Section 2 empowers the Commissioner  to  adopt,  amend, modify or repeal orders
regulating, restricting of prohibiting  dredging, filling, removing or  otherwise altering,  or
polluting, coastal wetlands.

     Section 3 requires that  with respect to any proposed order pursuant to Section 2 a
public hearing be held in  the county in  which the coastal wetlands to be affected are
located.

     Section 4  enumerates  so-called  "regulated activities";  states that  no  "regulated
activity" is  to be conducted upon a wetland without  a  permit;  sets out generally  the
procedures for securing a permit; and provides a statutory standard to be followed by the
Commissioner in granting or denying permits.
                                       149

-------
     Sections 5 and  6 state generally the jurisdiction of the courts and judicial remedies
available in actions under the Wetlands Act.

     Section 9 provides penalties for the violation of the Act or the Commissioner's orders
pursuant to the Act.

     Industrial Waste Treatment Act of 1972 (Chap. 42, P.L.  1972). This Act empowers the
Department of Environmental Protection to establish standards for the pretreatment of
industrial wastes.  The Department can insist on industrial pretreatment not only because of
the composition and quantity of the chemical wastes, but if the particular municipal plant's
treatment facilities are deemed inadequate to handle the untreated wastes.

     Fines  of up to $5,000 per day of violation may be  assessed  by the Department.
Furthermore, under the statute municipalities are empowered to seal off sewer connections
to violators.

     Other Related  Statutes.  A  number of other  New  Jersey  statutes are not aimed
specifically at waste disposal or pollution but impact on the problem.

     The Sewerage Authorities Law of 1946 and the  Municipal Utilites Authorities Law of
1957 both provide for the establishment of local authorities or special districts to undertake
waste treatment activities. Such authorities or special districts are independent and autono-
mous from municipal and  county agencies. The sewerage and waste treatment activities of
sucli authorities are regulated by the Department of Environmental Protection.

     •   Food and  Drug Laws providing for inspection programs which look for, among
         other things, the presence of waste materials  in or near food.

     •   Air Pollution laws under which the Department of Environmental Protection's
         Bureau  of Air Pollution monitors and regulates the incineration of refuse material
         by public and private disposal facilities.

     •   Legislation  providing monetary incentive for better waste disposal techniques.
         This includes provisions for research and  development grants. Another statute
         (Chapter 127, P.L.  1966) provides for the exemption, upon application of waste
         treatment facility operators, from payment of local property taxes. Such opera-
         tors must  have  been properly certified  by  the Department of Environmental
         Protection.

                  Administrative Implementation and Political Realities

     In April  1970, New Jersey established the New Jersey Department of Environmental
Protection by merging into a single department all  New Jersey agencies which relate to the
human  environment,  and installing the  department's  commissioner as  a member of the
                                        150

-------
Governor's cabinet. The department was  organized by  grouping from the former Depart-
ment of Conservation and Economic Development those divisions responsible for parks and
forests, fish and game lands, navigation and water control and supply witli the Department
of Health's Division of Clean  Air  and  Water which  had responsibility for water and air
pollution,  solid waste  management,  radiation protection,  shellfish control and  potable
water.

    With an annual budget of over $40  million  and over 1300 full-time employees,  New
Jersey's Department of Environmental Protection is  responsible for the administration  of
373,000  acres of publicly-owned land,  enforcement of state statutes on the environment
and general oversight of New Jersey's ecology. Under  the overall direction of a commis-
sioner, the Department has five  operating divisions:  Water  Resources;  Environmental
Quality; Marine Services; Fish, Game and Shellfisheries; Parks; and Forestry.

    The divisions are further divided into bureaus. For  our purposes the operating units of
prime interest are the Bureau of Water Pollution Control in the Division of Water Resources
and the Bureau of Air Pollution Control and Solid Waste Management  in  the  Division  of
Environmental Quality.

    The Bureau of Solid Waste Management regulates sanitary landfills and monitors and
regulates the activities of operators, collectors and haulers  of solid waste. Collectors and
operators of solid waste disposal facilities must  register with the Bureau. The Bureau is
charged with giving due consideration to  the comprehensive solid waste management  plan
before approving new  facilities. An important function of  the  Bureau is to monitor the
operation of disposal sites through inspection programs to assure  conformance with applica-
ble regulations and health codes.  The  Bureau of Solid Waste  has the  power  to  force
governmental and  private entities which engage in solid waste related activities to comply
with the statewide comprehensive management plan.  A  court injunction may be sought in
the name of the Commissioner of Environmental Protection.

    Another important New Jersey administrative body is the Public Utilities Commission
(PUC), which is empowered to regulate the activities of collectors and haulers of solid waste
as well as those of operators of disposal facilities. The PUC  uses all the traditional tools of
state utility regulatory bodies such  as the issuance of certificates of public convenience and
necessity after hearings, inspection of financial records to  assure fitness  to operate, rate
regulation, and route regulations of haulers.

    The Bureau of Water Pollution Control undertakes the following activities to assure
that hazardous wastes do not find their way into New Jersey waterways:

    •    Reviews basin plans for  sewerage system construction;
    •   Investigates oil spills and initiates legal action where appropriate;
    •   Enforces water pollution statutes and regulations;
                                        151

-------
     •   Monitors industrial waste treatment; and
     •   Monitors and surveys water quality.

     Within the Division of Environmental Quality there is a Bureau of Radiation Protection
which  is charged with  regulating radiation sources and licensees who handle radioactive
materials.

     In addition various citizen  advisory councils play a statutory  role in environmental
policy  formulation. The Clean Air Council,  the Solid Waste Advisory  Council and the
Pesticide Control Council each made recommendations to the Director of the Division of
Environmental Quality on pertinent issues in their respective areas of interests. The Depart-
ment of Environmental Protection is not  obligated to accept this advice but  such advice
would  have to carry significant weight if only because of the politically explosive nature of
most environmental issues. Similarly, the  Clean  Water Council and the Water Policy and
Supply Council had advisory functions with respect to the Division of Water Resources.

     New Jersey's Department of Environmental Protection seems to have made ample use
of the  technique of  cross-divisional task  forces and interdepartmental  committees. For
example, a new interdepartmental  committee charged with evaluating the total environ-
mental impact  of  any  solid  and liquid wastes  put into any of the state's 350 landfill
operations  was established to work with the Bureau of Solid Waste Management. The
committee  consists of representatives from the bureaus of Potable Water, Water Pollution
Control, Geology, and units involved in  land-use  planning and stream encroachment  in the
Division of Water Resources  as well as  navigation and riparian units from the Division of
Marine Services.

     As required by  the State Sanitary  Code, engineering design plans are submitted for
each landfill. The interdepartmental commitlee  serves as a screening unit for  these  plans,
with each committee  member evaluating the engineering report from his particular point of
expertise and the effects of the landfill operation upon the environment.

     The Department requires that daily logs be kept on type and source of waste being
dumped in the  larger landfills in the state known  to be receiving large quantities of chemical
wastes.

     Pursuant to the  statutory  mandate  of  the Clean Oceans Act,  the Department of
Environmental  Protection promulgated  regulations banning the dumping  of  most  toxic
wastes and requiring  that most other waste materials be barged to the 2000-meter depth
line. Handling and loading for ocean-disposal of radioactive materials, mercury compounds,
by-products from pesticide manufacture and petroleum refining are prohibited.

     The regulations require  that one year from the  effective date  the disposal of sewage
sludge, chemical  wastes and wastes dredged from nine major industrial waterways be
dumped seaward of the 2000-meter depth line. Dumping is controlled by an annual permit
system.

                                        152

-------
     The  techniques  used  by the Department of  Environmental Protection to enforce
various waste disposal and collection activities begin with the rules and regulations promul-
gated by  the  applicable  bureaus. Pursuant to  these rules with their statutory  base, the
department can accomplish its ends in the first  instance through its permit system and
standard setting as well as by vigorous prosecution of violators.

     Our discussions with officials in New  Jersey suggest that  existing  state legislation is
probably  adequate to  accomplish the task of regulating  hazardous waste disposal and
treatment activities. Any problems that exist at  the  state level are at the level of administra-
tive implementation.

     Perhaps the single  greatest  obstacle to totally effective regulation is the limitation
imposed on staff size and activity imposed by monetary considerations. At the same time it
should be  noted  that the Environmental Protection Department lias over  1300 full-time
employees  and  the task of coordinating their activities is a problem in itself.

     There was some dissatisfaction with the administrative performance of the Bureau of
Water Pollution Control.  This  dissatisfaction resulted in a sweeping reorganization of the
Bureau, effective September 1972, that changed the unit from a geographical division  to an
organization along functional lines with its own enforcement staff.

     Enforcement activity  in  the Bureaus  of Solid Waste  and Water  Pollution appears
vigorous. In addition to their own respective enforcement staffs, each bureau tends to  work
with a specialized group of environmental law experts within the Attorney General's Office.

     Because of common waterways and other commonalities, New Jersey has had to seek
strong interstate cooperations  with New York and  Connecticut. Interstate compacts have
been enacted but this area remains a problem.

     New  Jersey is  blessed or cursed, depending on one's bias, with over 130 citizen
advisory groups that must be  consulted on various environmental issues. Although  these
citizen groups are advisory, they can be a substantial political force.

                     Pending Legislation and Recent Developments

     Some 30  pieces of  legislation  relating to  waste disposal  and treatment directly or
indirectly are pending in the New Jersey legislature.  After discussion with the Director of
Legislative  Services at  the State  House, we concluded that only five important bills had
some practical chance of passage:

     •   An Act providing for and authorizing  funding for experimental and demon-
         stration projects for new techniques in  solid waste collection and disposal.
                                         153

-------
     •   An Act empowering the Department of Environmental Protection to estab-
         lish pretreatment standards for sewage that may be discharged into public
         sewage treatment plants.

     •   An Act strengthening the Clean Water Council and giving it certain investi-
         gatory and subpoena powers.

     •   An Act authorizing the Commissioner of Environmental Protection to condi-
         tion the award of sewage treatment grants on the adoption by the  grantee of
         an equitable  schedule and classification of rents,  rates,  fees in connection
         with the use of sewerage treatment facilities.

     •   An Act authorizing the development of comprehensive land use controls for
         development projects within the state.

     The new Federal  Water Pollution  Control Act  of 1972 and  the Marine, Protection,
Research and Sanctuaries  Act seem to  have largely pre-empted New Jersey's Clean Ocean
Act of 1971. The full effect of these laws, however, remains to be seen.

     This fall, New Jersey's Department of  Environmental Protection issued a series of
administrative orders to Shell Oil, DuPont, Monsanto,  Mobil, Texaco  and Olin, requiring
each  to start individual on-site wastewater treatment facilities between 1973 and 1975.
These orders followed  abandonment of plans  by the Delaware River Basin  Commission to
build a multi-million dollar regional treatment plant designed to handle 71.5 million gallons
of wastewater daily and serve all major  petrochemical companies lining the  Delaware River
in Gloucester and Salem  Counties. Shell was  given  the option of joining  the Gloucester
County Sewerage Authority system.

                                  Probable Needs
     Adoption of any of the proposed alternative approaches for treatment of hazardous
wastes would probably require  some amendment of New Jersey statutes and regulations.
However,  no approach suggested appears infeasible  because of existing or pending New
Jersey legislation.

     Operational Options. The  on-site processing approach to treatment pursuant to Fed-
eral law would not offer any major conflict with the existing New Jersey requirement that
processed  wastes not result in the discharge  of hazardous materials  into  New Jersey
waterways, but  does  not dictate to plants  the manner  by which they prevent this.  No
specific effluent  standards must be met so long as hazardous material is not discharged into
New  Jersey waterways. Final  treatment of wastes on-site via  mobile facility  would be
possible as long as the necessary  permit was secured and air pollution standards were met.
                                        154

-------
     Off-site processing and disposal does raise the question of finding a site that would be
acceptable  to New Jersey authorities and does not violate New Jersey law prohibiting such
processing in the wetlands or adjacent to waterways. A further complication would develop
if New Jersey enacts legislation requiring a state-wide land use plan.

     Pretreatment on-site  and  final treatment  off-site  raises questions  both about the
adequacy of pretreatment facilities and processes and the location of the off-site facilities.
With  respect to  both activities some  coordination with the New Jersey Department of
Environmental  Protection  would  be needed  and conceivably amendment of New Jersey
statutes to accommodate location of off-site treatment  facilities.

     Technical _Options. Since  New Jersey does not  specify any  particular  technique or
process, there would  seem to be  broad latitude as to technical options just  as long as no
hazardous effluent material is discharged.
                  ^         There  would be no New Jersey statutes or regulations requir-
ing specific types or effluent concentrations or process types. However, monetary incentives
are available under New Jersey law and  care  would  be taken to avail oneself of these
incentives. New Jersey incentives are in the nature of tax relief and grants or subsidies. Price
incentives are not present under New Jersey statute.

     Any of the  organizational  alternatives would  be possible, although public ownership
and  operation  would  be most  difficult to achieve because of the political implications.
Whether an existing public agency or a new authority owns and operates the facilities, there
would be jurisdictional  questions to be resolved and political jealousies to  be aware of.
These jealousies could be quite  acute in the case of a new public authority which is given
powers  of eminent domain and  cross-jurisdictional  authority.  Enabling legislation in  New
Jersey provides for the creation of such authorities, but a new statute may be in order if the
activity  of the authority is to  be limited specifically  to hazardous waste treatment and
disposal.
                                        155

-------
                                            TABLE E.4

                         NEW JERSEY LAWS AND REGULATIONS RELATING TO
                                HAZARDOUS WASTES - EXISTING LAWS
     NEW JERSEY
               Law

N.J. Dept of Envir.Protection
Act of 1970
   Consolidate all  environ-
   mental functions.
   Chapter  33

   P.L.  1970
Nature of Powers

  Advisory
  Promotional
  Rule-making
  Adjudicatory
                                                       Types ,of Hazardous
                                                          Substances
    Basic Control
      Strategy

Formulate comprehensive
policies for the conser-
vation of natural re-
sources.
Coordinate regional &
local efforts in accor-
dance with a unified
plan including prescri-
bing minimum qualifica-
tions for people in-
volved .
Initiate program for
industrial planning.
Supervise sanitary
engineering facilities.
Enforce state laws per-
taining to the environ-
ment.
                                             156

-------
  Techniques           Enforcement         Strengths

Research program

Statewide educa-
tion
Require registra-
tion & reports of
programs that may
result in pollu-
tion of any kind.

Hold hearings on
complaints

Make rules and
regulations
Weaknesses
                                     157

-------
  NEW  JERSEY
              Law

N.J. Water Qual. Improvement
Act of 1971
                                  Nature of Powers
                        Types of Hazardous
                           Substances
                            Basic Control
                               Strategy
   Concerning the prevention
   and abatement of pollution
   of the waters of N.J. re-
   sulting from the discharge
   of petroleum products,
   debris and hazardous
   substances.

   Inserted as part of
   Title 58.

   Chapter 173

   P.L. 1971
  Enforcement
Petroleum products
debris - "all forms
of solid waste and
liquid waste of any
composition whatso-
ever"

Hazardous substances -
compounds presenting
serious danger to
public health or wel-
fare including damage
to environment, fish,
shellfish, wildlife,
vegetation, shorelines,
stream banks & beaches
                                                Fast  action after
                                                accident

                                                Stringent  punish-
                                                ment  as deterrent
                                                to  accidents
   Water & Water Supply
   Title 58

   Art. 1,2,3,4,5,& 6
   Prohibits pollution
   of potable water and
   fresh water

   Sets up rules and regu-
   lations re water supply
   and sewer systems
Rule-making
Domestic and indus-
trial wastes, pol-
luting substances
Supervise purity
of water supplies
by penalties for
violations

Prohibit discharge
of unacceptable
effluent

Regulate discharge
from trains and
boats within desig-
nated watersheds

Require permits for
locating factories,
workshops on water-
shed areas.

Regulate discharge of
"sludge acid"
New Jersey Clean Ocean
Act of 1971
   To control and prevent
   the threat to the quali-
   ty of the State waters
   caused by dumping of
   waste into adjacent
   waters.

   Inserted as part of
   Title 58

   Chapter 177   P.L.   1971
  Rule-making
Wastes
                          Regulate the practice
                          of ocean dumping.
                          Adoption of rules and
                          regulations concerning
                          the loading and hand-
                          ling of materials within
                          State to be disposed at
                          sea.
                                                 158

-------
                        Enforcement
     Techniques            Powers           Strengths               Weaknesses
 Require prompt con-  Undertake removal   AH encompassiig          jjo reai methods
tainment and removal  when responsible    definitions               of preventing
of substances         person fails to do  Fast> strong              pollution
Prompt notification   S°                  enforcement
of sPiU              party to remove     P°WerS
                      discharge at respon-
                      sible person's ex-
                      pense
                      Fine
                      Civil suits
Assign penalties      Fines               Specifically
for vtiation          c  ...               assigns lia-
                      DUJ.CS              t j i .      f
T.J  i    • j                              bility to fac-
Final opinion on
quality of efflu-
ent

Permits

Approve plans for
water purification
plants
   Issue permits for   Withaold per-     Fast action
   handling materials  mits              through in-
                       Suits             junction
                       T .    ._.          Permit issu-
                       Inlunctions
                                         ance attempts
                                         to control
                                         before the
                                         fact.
                                        159

-------
NEW JERSEY
                                                  Types of Hazardous
        Law                   Nature of  Powers         Substances      Basic Control Strategy
Pesticide Control             Rule-making         Pesticides          Adapt regulations
Act of 1971                                                           concerning the sale,
                                                                      use and application
                              Adjudicatory                            of all pesticides
Chapter 177                                                           Create the Pesticide
Laws of 1971                                                          Control Council
New Jersey Wetlands           Adjudicatory         Anything            Preserve  the  ecological
Act of 1970detrimental         balance by  regulating,
                                                   to wetlands         dredging, filling,
Protection of natural         Rule-making                              removing, altering  or
resources in coastal                                                   polluting
wetlands

 Chapter  272

 P.L.  1970
                                              160

-------
Techniques
                            Enforcement Powers
                                                          Strengths
                                                     Weaknesses
Make rules and
regulations
  Injunction


  Fine
                            Embargo
Require labelling
conforming to Federal
regulations
Fublic hearings
Study and
investigate
Commissioner
designate
wetlands
Court restraining
action
Exempt* State
Mosquito Control
Commission
Rules and
Regulations

Permits for regulated
activities
Restoration Costs
Fine
                                            161

-------
  NEW JERSEY

         Law
Nature of Powers
Types of Hazardous
    Substances
Basic Control Strategy
 Solid Waste
 Management Act
 of 1970
 Chapter 39
 Laws of 1970
Rules and
Regulations


Advisory


Adjudicatory
Solid Waste
Supervise solid waste
collection and disposal
facilities and
operations
                    Develop statewide
                    regional, county and
                    intercounty plans for
                    solid waste management
Refuse Disposal Regulations
       1958
                                                                       Create Advisory Council
                                                                       on Solid Waste Management
  Applicable to
  Hazardous Wastes
                   Hazardous and
                   Chemical Wastes
                   (Excluding
                   Radioactive)
                  Shipper is responsible
                  for proper labelling and
                  handling of hazardous
                  wastes to insure safe
                  disposal

                  Hauler responsible for
                  operating within existing
                  laws for transport of
                  dangerous articles
                  (Chapter 128, P.L. 1950)

                  Receiver responsible for
                  operating within existing
                  laws

                  No chemical wastes (liquid
                  or solid) shall be deposited
                  in direct or indirect contact
                  with surface or ground waters
                                              162

-------
Techniques
                              Enforcement Powers
                              Strengths
                                                                                 Weaknesses
Require registration
of new and existing
facilities
Promulgate rules and
regulations for solid
waste management
Research and
Development


Acquire Land
Study and Advise
Hold Public Hearings
Injunction


Fine
Recognizes
existence of a
solid waste crisis
and the need for
forward management
                                             163

-------
NEW JERSEY
          Law
      Title 40
  Sewerage Authorities  Law

           1946

  Enabling Act

  To reduce and abate

  pollution of waters

  menacing public health.
                     Types of Hazardous
Nature of Powers         Substances
 Enabling

 Rule-making
                        Sewage
                                            Basle Control Strategies
                       Authorize counties
                       and municipalities
                       to form sewerage
                       agencies

                       Construct and
                       maintain sewage faci-
                       lities to protect
                       watars from pollution
                       May discharge
                       nothing that will
                       cause pollution of
                       waters
  Municipal  Utilities
  Authorities  Law

       1957

  Foster  the provision
  and distribution  of
  adequate supplies of
  water and  abate
  pollution
 Enabling
 Rule-making
Polluted water
Counties and/or
municipalities
singly or together
managing waterworks
and works for col-
lection, treatment,
purification, or
disposal of sewage
and other wastes
Authorize sewerage
agencies to become
authorities
      Title  32:  18

  Interstate Sanitation
  Commission
         1935
  Cooperation of New York,
  New Jersey, and
  Connecticut for the
  control of future pol-
  lution  and abatement of
  existing pollution
 Rule-making

 Adjudicatory
Pollution
Classify waters in
order to deal realis-
tically with use of
waters

All sewage discharge
restricted and treat-
ment required
                                                164

-------
                Enforcement
Techniques         Powers         Strengths               Weaknesses
Build systems      Suits

Inspections
Make rules and
regulations

Charges for
correction

Providing
financing for
projects
Sue and be sued

Acquire property
Issue bonds
Create Authorities  Sue

Provide for
financing

Acquire property

Make rules and
regulations
Hearings for ac-
cused polluters

Rules and        Each state
regulations      to enact

May not cause to f"1.169*8'
exist any source lati°n £or
of pollution with-
in the district
after 4/1/35 with-
out Commission    Injunction

approval
                                165

-------
     NEW JERSEY

        Law
Nature of Powers
Types of Hazardous
    Substances
Basic Control Strategy
Delaware River Basin
Compact Pollution Control
Chapter IIP Article 5
Advisory
Adjudicatory
Sewage industrial
and other wastes
Pollution by sewage or
industrial or other
waste shall not injure
the waters of the basin
Control future pollution
and abate existing pollution
in the basin
 Transportation of
 Dangerous articles
 Chapter 128
 Laws of 1950
 Rules and       Dangerous articles:
 Regulations      -flammable liquids
                  -flammable solids
                  -oxidizing materials
                  -corrosive liquids
                  -compressed gases
                  -poisonous substances
                  -radioactive materials
                   (each of them are also
                    defined)
                    Control conditions
                    under which dangerous
                    substances can be
                    transported within
                    the state
  NOTE:  Does not apply to:
              -explosives
              -flammable liquids transported in tank trucks,  trailers  or semi-trailers approved
               by Division of Motor  Vehicles.
                                              166

-------
 Techniques
Enforcement Powers
Strengths
Weaknesses
 Investigate

 Build facilities  to
 control existing  or
 potential pollution

 Hold public hearings

 Establish standards
 of treatment of
 sewage and wastes
Insure orders to
cease polluting and
implement treatment
Very strong
protection for one
body of water
Regulations

Placarding
                         Fine
                         Imprisonment
                                           167

-------
NEW JERSEY
                                                     Types of Hazardous
      Law                    Nature of Powers        	Substances	      Basle Control Strategies
Air Pollution
Control Laws
Air Pollution                   Advisory            Air Pollutants          Create Clean Air
Control Act of 1954           »,. ,.  .                                      Council
                              Ad^udicatory
Control and                  _ ,    . .                                       Promulgate rules
            ..                Rule-making                                            ,
suspension of                                                               and regulations
air pollution                 Promotional                                   prohibiting air
                                                                            pollution

                                                                            Promulgate motor
                                                                            vehicle emission
                                                                            standards

                                                                            Require registration
                                                                            of those engaged in
                                                                            operations which
                                                                            may result iri air
                                                                            pollution

                                                                            Clean air scholar-
                                                                            ship intern program
 Air Pollution
 Emergency  Control            Rule-making            Air Pollutants          Report in writing to
 Act of  1967                                                                 governor who then
                                                                            proclaims emergency
 Provides emergency
 powers  when air                                                             Declaration of
 pollution  seriously                                                         emergency should
 affects the health                                                          be publicized
 of the  public                                                               Promulgate stand-by
                                                                            orders for emer-
                                                                            gency state
                                              168

-------
 Techniques
Enforcement
   Powers
Strengths
                                                                     Weaknesses
Study codes
and
regulations
and make
recommendations

Study state
of art

Hold public
hearings
yearly

State-wide
education

Inspection
 Registration
 Injunction
If emission
detected and
no regulation
exists about
that specific
emission, may
call hearing
and direct
polluter to
cease
Financial aid
for under-
graduate and
graduate
engineering
degree
Prohibit motor
vehicles

Prohibit or
restrict com-
mercial or
industrial
activity

Prohibit
inciner ators
Prohibit
Consumption
of  fuel

Prohibit
burning &
other activity
contributing
to pollution
emergency
 Motor vehicle
 inspection.
 Entry and
 search  (ex-
 cept single
 and double
 family homes
 - need search
 warrant)
 Traffic
 rerouting
 Fine

 Imprisonment
Excellent
emergency
powers
                                      169

-------
 NEW JERSEY


 Pending Legislation

S200

Providing for experimenta-
   tion with and demonstra-
   tion of new techniques
   in solid waste collec-
   tion and disposal.
Nature of Powers
Advisory

Promotional
   Types of Hazardous
      Substances
Solid Waste
    Basic Control
      Strategy
R&D program to deter-
mine best method
S-234
   Requiring pre-treatment
   standards for sewage
Rule-making
Sewage
Make rules and regula-
tions establishing pre-
treatment standards be-
fore it can be discharged
into public collection
system.
S-266
   To amend the Act allow-
   ing the granting of finan-
   cial aid to counties and
   municipalities.

   Establish the Clean Water
   Council
Adjudicatory
Pollutants
To grant aid up to 30%,
25? for those projects
qualifying for federal
funding under FWDCA
A-702

   An act  regulating  the
   phosphate content  of
   soap, soap powders
   and detergents
Rule-making
Phosphates in soaps
and detergents
Unlawful to manufacture
use, sell, distribute,
or dispose of any soap,
soap powder, or deter-
gent containing more
than 5% phosphates by
weight..
                                                 170

-------
                       Enforcement
   Techniques              Powers            Strengths
Study and report
  Rules and regula-    Injunction        Fast, strong
  tions                                 action
  Require applica-    Seal     ^^  Beforehand
  tion to connect      .                control via
  to public system      °n              application

  Inspection
  Grant money         Subpeona          Subpeona
                     witnesses
   TO be set by      Fine               Fast
   Department of     injunction         through
   Environmental                        injunctive
   Protection                           ralief
   through rules
   and regulations

   Labelling
                                       171

-------
                    PENNSYLVANIA LAWS AND REGULATIONS
                       RELATING TO HAZARDOUS WASTES

                                     Background

     As both a large and an old industrial state, Pennsylvania has faced for some years the
problem  of coping with industrial wastes. Unfortunately, an important part of its natural
resource  base for  manufacturing -  Appalachia's coal fields - is also a major source of
difficulty in disposing of hazardous wastes safely.

     Today, much of the (industrial) blight endures in the anthracite fields  of north-
     eastern Pennsylvania, where fires and cave-ins of the earth go on for decades after
     abandonment of mine sites and  monstrous smoking culm dumps mar the country-
     side; the soft-coal fields of the west, with thousands of acres churned up by
     reckless strip mining; . . .*

     These man-made  fissures  in the  earth's crust cause continuing problems, as rainfall
collects in abandoned mines, picks up iron oxides and mineral salts from coal dust and old
explosives, and then overflows into surface streams, which supply about 80% of the water
consumed in Pennsylvania. In addition, the natural processes which created the coal deposits
also  created porous soils and miles of underground interconnected drainage  systems. When
combined with Appalachia's heavy rainfall  pattern of 45-50 inches per year, these condi-
tions make geologists leary of disposal of any kind. Department of Environmental Resources
(DER) officials report that only 17% of Pennsylvania is geologically suitable for receiving
ordinary municipal wastes and their leachate; and this percentage includes land already used
for other purposes, hence  not available  for disposal. The Commonwealth has therefore
turned down a number of outside requests to consider providing waste disposal sites.

     In 1973, Pennsylvania enacted  its Clean Streams Law. However, it was not oriented
toward the prevention of water pollution; it authorized official abatement action to begin
only after the fact. Moreover, many  small industrial plants took advantage of a loophole in
the law and avoided control by  the Sanitary Water Board  by constructing earthen lagoons;
but these lagoons, in most cases, merely postponed the day of ultimate disposal of hundreds
of millions of gallons of oil, chemical, and sewage wastes. During the late 1960's, a series of
major  spills and pollution incidents caused severe damage to streams and  focused public
attention on the law's weaknesses.* *
  'Pierce, Neal R., The Megastates of America., N.Y.: Norton, 1972, p. 231.
  "Lazarchik, Donald A., Pennsylvania's Pollution Incident Control Program," Paper presented at 25th
  Annual Purdue Industrial Waste Conference, May 1970.
                                        172

-------
     This series of incidents contributed to the awakening to environmental dangers which
has produced, in many states, stronger laws as well as more vigorous agencies to implement
them. In 1971, Pennsylvania set up  DER to assume the duties  of 14 existing, but often
competing and ill-coordinated, agencies. Governor Shafer created an extraordinary  strike
force, continued by Governor Schapp, of six young attorneys authorized to invoke injunc-
tions rather than the longer and less certain procedures of criminal prosecutions and fines.*
In  1972, the  General  Assembly completed action to amend Article  1  of Pennsylvania's
Constitution by adding an  "environmental bill of rights":

     The people have a right to clean air, pure water, and to the preservation of the
     natural,  scenic,  historic and esthetic values of the environment.  Pennsylvania's
     public natural resources are the common property of all the people, including
     generations yet to come. As trustee of these resources, the Commonwealth shall
     conserve and maintain them for the benefit of all the people. (Section 27)

     Practice  of these preachings does not come without effort. Officials complain that
they lack the  funds  needed  for  enforcement. However, the nation's  third most
populous state seems,  because of its early water and air pollution abatement efforts, to
have a relatively strong organization for directing and monitoring  municipal control
programs required by law.

                             Existing Laws

     Table E.5 summarizes Pennsylvania's laws relating to hazardous wastes. Below,  we
note those provisions relevant to hazardous wastes. Table E.6 contains the text of new
rules regulating  hazardous solid waste.  Note that the information and interpretive
comments in  this report are based upon examination of documents and interviews with
key officials in Harrisburg. No observations were made of monitoring and enforcement
actions in the field.

     Pennsylvania Department of Environmental Resources (Act No. 275, 1970; Effec-
tive  January^  19, J_971_).  The  law  recognizes environmental functions under a new
Secretary  of  Environmental Resources, both  by abolishing some departments and
commissions and transferring their functions to  DER, and by retaining other agencies
but placing them with  DER. Units within DER important to hazardous wastes are:

     •    Bureau of Water Quality Management (Water Supply and Sewerage,  Indus-
          trial Wastes);
"Pierce, Op. cit, p. 259.
                                        (73

-------
     •   Bureau of Air Quality and Noise;
     •   Office of Radiological Health;
     •   Bureau of Mine and Occupational Health and Safety (Quarries and Explo-
         sives);
     •   Bureau of Land Protection and Reclamation (Solid Waste Management, Oil
         and Gas); and
     •   State Board of Certification of Sewage Treatment Plant  and Waterworks
         Operators.

     The law  empowers  DER to act in many areas, generally by issuing permits  and
certificates, and to assist municipal governments in planning.

     The Act created, in addition  to DER, three more agencies:

     •   Einvironrriental  Quality Board_, to develop a master environmental plan for
         the Commonwealth and to review and regulate DER's work:
                              ^' to hear appeals concerning permits and deci-
         sions issued by DER, and to issue adjudications;

     •   Citizens_Advisory^ Council, to review all environmental laws of Pennsylvania,
         review and advise  DER, and report annually to the Governor  and  General
         Assembly.

     These  bodies  have broad review powers which, if exercised vigorously by appointees,
can significantly influence environmental policy and DER's implementation of it.

     Clean  Streams Law (Act No. 394, 1937; as amended through 1971). The Law creates
broad powers, including the regulation of "industrial wastes," which (Article 1 , Section 1 )
"shall be construed to mean any liquid, gaseous, radioactive, solid or other substance,  not
sewage, resulting from any manufacturing or industry . . ." Section 4 declares that Pennsyl-
vania's policy  is both to prevent further pollution and to reclaim every presently polluted
stream, using permits to exercise comprehensive watershed management and control.

     Among  Rules and Regulations issued  under the Clean Streams Law, Chapter  97,
"Industrial  Wastes," adopted September 2, 1971, sets forth detailed standards for a number
of wastes resulting, for example, from milk processing and paperboard manufacturing.
Sections 97.51-58  specify sumps,  domes, and other requirements to handle wastes from oil
and  natural gas wells. Sections 91.71-75, "Underground  Disposal," prohibit discharge into
abandoned  wells and specify strict conditions for disposal into mines, underground horizons,
and new wells.
                                       174

-------
     Chapter 101, also adopted September 2, 1971, issued "Special Water Pollution Regula-
tions"  that apply to accidents which release toxic substances into  streams. Section  101.2
requires the responsible person or municipality to notify the nearest of seven DER Regional
Offices, to prevent injury  to downstream users, and to remove residues within 15 days.

     Chapter 91, governing water resources, is notable for its emphasis upon comprehensive
and basin-wide water quality management and pollution control. Section 91.31 provides
that DER shall not approve a project unless it conforms to a comprehensive plan based upon
information available from federal, state, and  local  agencies as well as the applicant.

     Air Pollution Control Law  (January 8,  [970, P.L. 2119; amend_ed_through_ 1972).
Pennsylvania  provided  an early and dramatic example of air pollution when, in October
1948,  a  temperature inversion over the steel-mill town of Donora, south of  Pittsburgh,
locked in a dense mixture of fog, exhaust, and smoke, which caused 22 deaths. The Law
provides not only for control and abatement, but also for prevention of pollution, including
that  caused by toxic or radioactive substances, by smokes, dust, fumes, gases, odors, vapors,
and similar causes. It controls burning of coal refuse  and open burning of municipal refuse.
It requires approval of plans to construct certain classes of air contamination sources, as well
as reporting of sources. If further requires control of pollution by local governments.

     In October, 1972, the General Assembly substantially amended this Law, by Act No.
245, to strengthen the powers of DER,  create  a permit system for stationary sources, add
heavy  penalties and remedies,  and establish the  Clean  Air Fund. Section 3 (7) defined
"source" to include  both stationary and mobile equipment. Act No. 20, of February 14,
1972, provided for interstate agreements.

     Pennsylvania Solid  Waste  Management Act  (Act No. 241, August,  1968; amended
through__Jj)72)-  This Act provides for the  planning and  regulation of  storage,  college,
transportation,  processing, and disposal systems;  requires municipalities to submit plans;
requires permits for operating systems; and authorizes rules, remedies, and penalties.

     Of special interest are the  1972 amendments to Rules and Regulations, Chapter 75,
"Solid  Waste  Management," pertaining to hazardous waste,  defined by Section 75.1(13) to
include, but not be  limited  to, chemicals, explosives, pathological waste,  and radioactive
materials. Subchapter G, Sections  75.211  through  75.235, quoted  in full in  Table E.6
provides for regulation of consignment, processing, transportation, storage, and listing. The
law  does not specify  standards, but authorizes  DER to  promulgate  them as scientific
knowledge makes them feasible.

     Interstate Compacts. Various Acts authorize the Commonwealth to join with neighbor-
ing  states in planning and pollution control  programs  of river basins (Ohio,  Potomac,
Susquehanna, and Delaware Rivers) as well as air sheds.
                                       175

-------
     Municipality Au^orities Act_of_1945_ (_P.L. 382; amended through 1972). This bioad
enabling statute permits municipalities, townships, and counties to establish "bodies corpo-
rate  and  politic,"  or  public  agencies organized on  business  management principles, to
provide, often on a user-fee basis, such public services as airports, tunnels, incinerators, and
water works. Section 4, "Purposes and Powers," does not specify "hazardous  wastes," but
does  include  "sewage treatment  works, including works  for treating  and  disposing of
industrial waste."

     Industrial Development Authorities  Act (August 23, 1967, P.L. 251; amended through
1972). Pennsylvania, a leading proponent of attracting industry by means of the industrial
development authority device, passed this law to provide for "the incorporation  as public
instrumentalities of the Commonwealth  and as  bodies corporate and politic  of industrial
development authorities for municipalities, counties, and townships." This type of authority
is a specific application of the general concept of the "special district" form of government,
usually created in  Pennsylvania under the Municipality Authorities Act. However, whereas
special districts - for example, a turnpike authority or a sanitary district  - both build and
continue  to  operate  facilities  needed by  the public, industrial  development authorities
generally  seek merely to attract private firms  into  a region  by helping to provide the
required  infrastructure, such  as land and utilities. In  some cases, an authority  owns an
industrial  park and buildings, parts of which it leases  to firms. A major function is often to
raise capital by issuing municipal bonds which, being free of taxes,  provide essential  facilities
to industry at costs lower than are available in commercial capital markets.

     By Act  No. 171  of December 29, 1971, the General Assembly amended  the  enabling
law to define the "pollution control facilities" which development  authorities may promote.

                  Administrative Implementation and PoliticaI_ReaMtjes

     Having indicated the framework of  laws and regulations available to control hazardous
wastes, we now turn to the practicalities of making these  laws  and  regulations effective.
Extensive examination of  Pennsylvania's administrative capacities was not possible witliin
the scope of this assignment, but the officials interviewed did  make a number of observa-
tions worth reporting.

     Joint Legislative Committee. Within the legislative branch, Pennsylvania  seems some-
what unusual among  the  states in having a Joint  Legislative Committee concerned with
pollution  control and  conservation. Each of the General Assembly's chambers has its own
committees.  But the  device of the joint committee, also used sparingly  in the Congress,
provides  the potential  for a single focus, visible to the public as well as to executive agencies
and  to members of the Assembly itself. This device offers a means, therefore, of coping with
the problem characteristic of legislatures - fractionated interest dispersed between houses
and  among committees. Moreover, the charge of this joint committee includes both air and
water matters, a further step toward considering different aspects of a related problem.
                                         176

-------
     The Joint Committee's Executive Secretary feels that Pennsylvania's laws are adequate
to allow the several alternative methods of disposing of hazardous wastes. The state's needs,
in his opinion, are now two: first, to  codify existing laws and regulations in environmental
matters generally; second,  to provide sufficient funds to administrators to carry  out  the
policies already declared by law.

     Department of Environmental Resources. This department, as its name  suggests in-
cludes the administrative units most directly concerned with controlling hazardous wastes.
DER officials feel that present laws are generally adequate to allow the proposed  alterna-
tives.

     The mere  placement  within  a  single  department of several  previously independent
agencies does not guarantee, of course, perfect coordination among related programs. DER,
therefore, requires, as a matter of internal department  routine, the coordination of reviews
of applications  for  permits in  any  one field by  all concerned  units.  DER's  internal
instruction, see Table E.I, cites an example:

     An air  pollution permit will not be issued until all appropriate requirements for
     water pollution control, solid waste management,  and other DER programs have
     been satisfied.

DER's eventual goal is to be able  to issue only one permit for a given request or project.

     DER appears to enjoy both strong central management, in Harrisburg, and an effective
network of eight offices sited in regions of the  Commonwealth,  with a total staff of about
250  persons. These offices  not only process permit applications  and enforce laws, but also
provide technical assistance to municipalities, counties, and townships in developing their
required plans for water quality  management and solid waste management. State officials*
made clear that,  although DER describes its role as assisting local governments, in reality it
is directing their planning programs. It does so  for a  number of  obvious reasons, including
state  legal requirements, funding  by Federal agencies and DER,  availability of qualified
professional  personnel in DER,  reluctance of some  local governments to  carry out such
programs on their own initiative, and the  importance in many  cases of coordinating  the
planning of several governments joined by a common watershed, airshed, or "wasteshed."

     Environmental Quality Board. Although  DER  conducts the work of detailed  daily
administration, this Board plays  the important role of reviewing  DER's work. By virtue of
both  its  legal powers  and the vigorous use of them by its members, the board has a
significant impact on policy. Moreover, five  of its members, with full voting powers,  are also
*Those interviewed are listed in Table E.8.
                                        177

-------
members of the 1 8-person Citizens Advisory Council. Thus, the Board is one of the devices,
if not  the main device, for channeling political concerns about environmental policy and
programs. Furthermore, it has administrative links witli the  Environmental Hearing Board.
Therefore,  its Administrator points out, these four bodies combine, for  most practical
purposes, the legislative, executive, and judicial roles in environmental matters.

     Comments and Trends. An important factor influencing the effective performance of
these bodies is  reported to be the  energetic role of Pennsylvania's citizens' groups. Citizens'
task  forces  emerge in response to issues. They attract significant amounts  of time and
professional expertise from lawyers, scientists, doctors, university  professors, and similar
kinds of persons. They prepare themselves thoroughly, present detailed technical arguments
during  hearings, and otherwise make their views and judgments known  through the Citizens
Advisory Council.  They take up  the  time of  DER officials but, as these  officials admit
readily, with good results.

     The desire common to local governments, DER  officials report, is, not surprisingly, to
locate  waste disposal  facilities  "anywhere but  here." A current controversy  focuses on a
proposal to  dispose of Philadelphia's solid wastes in abandoned mines in Northeast Pennsyl-
vania.  Although the local governments concerned oppose the idea now, its economic logic
and attractions  may in time overcome objections.

     Some  officials prefer the strategy of encouraging private enterprises rather than public
agencies to develop and operate disposal services, with the Commonwealth's role limited to
certification and  regulation.  They argue that the  state could supervise private firms more
effectively  than it  could an  agency of its own creation. This strategy, of course, implies
important roles for the  Industrial Development Authority and Public Utilities  Commission,
or similar agencies devoted to waste disposal.

          Probable Legislative Needs for Hazardous Waste Disposal Alternatives

     Pennsylvania  officials, as  noted  above,  believe that  their laws  and regulations are
already developed  enough to enable  processing and  disposal of hazardous wastes by the
alternative  methods proposed.  Minor changes or perfecting amendments, however, would
likely be required to remove possible obstacles and ensure proper authorizations.

     Officials indicate a number of specific though minor needs, listed below. Most relate to
the  solid  waste management program, which  has  regulations governing ''hazardous solid
waste." Neither  we nor Pennsylvania  officials can  suggest now  the specific wording or
statutory provisions required. This task of technical draftsmanship would require further
detailed consultation and advice from legislative counsel  to the General Assembly.
                                         178

-------
     Single Permit.  Present laws require  different  permits for different types of pollution
control. Although DER tries by internal procedure to coordinate permit reviews, it feels
that a single permit covering all would be preferable, both for DER and for applicants.

     Mor:etjiry_Jr|centive_s.  To  develop hazardous  waste  facilities will  probably  require
incentives in  the  form of Federal  grants or of state bond issues.  The latter would require
legislative authority.

     Permit Industrial Development Authority  to  Promote Facilities. A clause may be
needed in the present enabling act to  specify that the Authority may include hazardous
waste facilities within "pollution control facilities."

     Require  All Localities to Develop  Solid Waste Management Plans. Present law requires
planning  by only those local governments having a population of more than 300 persons.
This releases  a number of localities from an important  obligation. The law  should be
amended to require  all localities to plan. Moreover, the law, which  now allows voluntary
participation, and thus implies the option of nonparticipation or withdrawal, should be
amended to require compulsory participation.

     Require  Local Governments to Implement  as Well as Plan Solid Waste Management.
Present law requires only planning, which  is well and good, but  it should be amended to
require localities to  put approved  plans  into practice. In most cases, however, this means
that  state funds must also be authorized to assist construction of treatment and disposal
facilities as well as to pay for other implementation expenses.

     Permit DER to Approve  of Solid Waste Disposal Sites. One present law reserves to
County Commissioners the approval of dumping sites, for example, abandoned strip mines
within the county,  for solid wastes. This provision is relevant to the current proposal for
disposing of Philadelphia waste in an upstate county. This provision should be rescinded.
Similarly,  another present law  bans importation of wastes from outside the Commonwealth
to be disposed of  within  Pennsylvania.  This law should  be amended  to allow DER to
approve such disposal according to appropriate criteria. Clearly, "anywhere but here" laws,
although attractive locally, are not a long-term solution for every government.

     Concept of  the "Solid Waste  Shed".  Present  law  is based upon the  concept of
paramountcy of local political boundaries, unlike the Clean Streams Law  which recognizes
the need  for basin-wide management. The analogous concept of wastesheds  should be
written explicitly into Pennsylvania's solid waste management law.
                                        179

-------
                                                  •« — i





^.
i
^

fc
§
PH
O
r2



CrO

X


CO


Ot
S
B






4J
G
f g
4-1
d
M



Techniques

s &
4J a
O 4-1

fj 4J
•H W
CO
BS





03
3
o
•a
M
N aJ
cO U
w d
cd

»!
a"
f-<

(0
OJ
&
0
(X(

Q
OI
h
3
4-1
s
TJ 4J 3
0) OH
N CUf-l
•H >* O
rH 4J CO P.
(d -H M
t-i > Ot r-f
4-t -H > «
S « OW - 1
CJ CO cu w

a a co
§1 CO 1 CO O
J3 4-1 Ori(dSO--H-nC
a S c eu-ri3H-HB3BD.OlE4l-fC/3MOO
4> tt U
Pi D. P. CU
tO TJ 1 4J
01 1 g ™ S
j- a. o a. . 3 a
4J3iHcra ntooo
Md toHcjocu 3 4-1 a) *-> vj
ti O O tOCjOiHiHrH (n T-j (4 BO
O itUB 4-lQ]
•HU3B S ooaJciigto i-i S oo '-M a to me
tn-HriO & C X • B 4J O C iH 0)c3
•H S 4-J -H tU -rHUCOO^ CDD.-H T)tUCO >)-irH'
3&C04J 4J (-1 hUIU (H M OJ40) 04JfXVJ
o-to^ao cnoJ cao *-> Sain) 0OrH oo d
UatOOJ4-)CU>>CO bOCO) >3 -HhcUCl!
cd t-l iH 4->j^ J3 4J 3 CUO>.d -, 4) (-1 . 4->O>S
CUhU CQCUlH t3 4-1 fH 1J O CUM CO d Lj-l O 4J
T330J(0 O3Q-aCUrH4J O.T3 3 n)(- ^ ^o]
BC04JB 0,COSrH -HCBiHCO -C.ar-1 CQ-O^O rHQO.CU
3 to CO O CUtDCUO HiH4->0> B3O cOBcdiH O -^ a M
MSU t3Mapa & > & H cdcoffi i-HcdS4-i p,oddM-iMi-iooiHeio
rlCUErJ COCUJ3x!3CU-H-r4BJJtU
iHiHB-H •H003a)2:i-Hau3UiH3r(
5>4Jl-i> •OttSHt8jSrH?,CUCT.tlt|jrH
cu>>cu ttt cuaii-(>1ctp.a 4j*j{d4Jat4J«wdM
NCJtdrH >4-(COE>4-COa.ClOOJ(3a>rH
•Hctjcu a oi Jo^ri-HcdC ODM Otd-dCOtd4Ji~H>1 4J4.JOJS4J4J
a) at m 0) cu OJ ai M,cc3cd4JcrjT-< — o .a tu *
S 3 w eu . ^ m oo
eu Ticuaicocuto^
4JH BB4J(tt>CUS
cdtd-H Qcd4Jtu,
ESOfJ *&«-O^SB
CU 4J CJ»«'OciJ4JCUcOr>,
oo en 13 <-3 a] CiOtqcQiHoocOr-i
rt Q) i-( 3 dJJ33iHg4J
acj^Hr-iis si-(T3CT'Fai34-i5co
S-HO-riC CUOdi-tcOCOUD
WSWOrH C03rHrHtj(OElW'O


>> >,
00 W M 00
do OB
-H 4-1 4J *H
A! >, fl CO A! Fs
ffl U CJ U CO H

r S « 5 " m
CU iH 3 3 CU -rl
r-l > 1-1 1-1 ,-H >
3 -t) -rj ^ 3 TJ
as <5 
d
cu

o
1
4-1

•H


"-. 00
er, M
< s
rH Cd


l

CU
•rl

iH

5


to



cd
4J




U
4J
cd
4J
CO

!
•H
M
ctt
>

S



M
CO








•o
g
PQ


D) CO
01 M
•H rH
y js
g 2
00 CO
rt w


•a ^
n)
0 C



a •
3-

O3

.C
CO 0



cd
u
CO U
W Ed


                                                              I  fd CO etJ
                                                            
-------
                                                                                                               T* H a

                                                                                                                  £ £
                   u rt >   w

                   S3S SI
                   >w no a. « i-i
                   u at O.H ai
                   rt n rt a. o.
                      « o
                      M U
 3



VM


 O
IT)
w
H-l
M
                          .33,
                                             •si
                                                       H  a

                                                       •35
                                                       4J  00
                                                       & 4-»


                                                       SH
I8.|
j  o  S

j -u  n
A c  o
                                                               g-H «  H
                                                                «   3


                                                             £ -8*0  S
                              £r   I
•H w


0- M
                                                                                                      I P. 4J tO "

                                                                                                      )     CO '

                                                                                                      ) rH 






o

o
1
2
8.
O

TJ
m
a
<0
> 01
"d
g
-rt
S
•H
S
(d
4J
g
O
l-i 4-l O
o to
                                                                                                         o 2
                                                                                                         M   tn iw
                                                              181

-------
_c

 o
B
l/->
w
w





 n
•sasl
•a o P« a
a 1-4 BJ -H

|2 2 o


•o
,



•d
a







r
«
d -H h

   Ch
0) S i
S-d !
                                                1 ui o tn
                                                ^ -H B T3
                                                 4-> w td 
-------
                           frS
                           as
                           m »
 S
•3
 §
w
                             .JOB -H
                            I O 41 r-| ,H
                             U >M M a   4J g
                                           0} 4J J3 4J >4-t ^ 4-1
                     O a[
                     si
                                 SS|
                                " 5«  M
                                " « 3  S
                                o •* 3  3
                                >w M *J
                                        183

-------
                                   Table E.6

              Excerpts from Pennsylvania Rules and Regulations,

                   Department of Environmental Resources*


                     CHAPTER 75.  SOLID WASTE MANAGEMENT

                      Subchapter A.   GENERAL PROVISIONS

                                MISCELLANEOUS
75.1  Definitions

          The following words and terns, when used in this Chapter, shall
have the following meanings, unless the context clearly indicates otherwise:

          (13)  Hazardous waste — [Solid waste with certain inherent
dangers.]  Any waste which by virtue of its quantity or content presents a
hazard to the individuals handling it, a hazard to public health, or
potential pollution to the air or waters of the Commonwealth or makes land
unfit or undesirable for normal use.   This category shall include but is not
limited to chemicals, explosives, pathological waste and radioactive materials.
                      Subchapter F.  STANDARDS FOR SOLID WASTE
                                      INCINERATOR FACILITIES
75.193.  Hazardous waste.

          Hazardous wastes may be incinerated provided that special provisions
are made in the design and operation of the facility and only with Departmental
approval.


                      Subchapter G.  HAZARDOUS SOLID WASTE

                                   GENERAL
                                              /
75.211.  General requirement.

          Whenever hazardous waste is produced and alternate reclamation
or reuse is not possible, the collection, transportation, processing and
disposal shall be accomplished in accordance with the provisions of this
Subchapter.
*  Issued under authority of Act. No.  241 of July 31, 1968, and adopted
   1972.
                                     184

-------
                            Table E.6 continued

75.212  Consignment of waste.

          (a)  No consignment of solid waste shall be made to another
without the disclosure of its hazardous nature.

          (b)  No consignment of solid waste should be made to another
without the assurance that subsequent handling and disposal shall be
accomplished in a satisfactory manner and in accordance with the laws
and regulations of this Commonwealth.
                      PROCESSING AND DISPOSAL OF WASTE

75.221.  Authorized sites and methods.

          No receiver of hazardous solid waste shall use any other than
sites or methods permitted pursuant to the act for hazardous waste
processing or disposal.

75.222.  Transportation of waste.

          The transportation of hazardous solid wastes shall not be done
in a manner which will present a rsik to the transporter or the general
public or which may result in pollution of the environment.

75.223.  Processing of waste.

          The processing of hazardous solid waste to render it non-hazardous
shall not be done in a manner or way which, in itself, creates additional
hazards or environmental pollution.

75.224.  Handling methods for waste.

          No disposal site shall accept hazardous solid waste for disposal
without having established a handling method which precludes or minimizes
the occurrence of hazardous incidents.

75.225.  Storage for processing or disposal.

          No storage of hazardous solid waste materials prepartory to
further processing of disposal shall be in such locations or quantities
or under such conditions as may be deemed unsafe by the Department.
                                     185

-------
                             Table E.6 continued


                              LISTING OF WASTE

75.231.   Department to maintain list.

          (a)  The Department shall maintain a multiple list of hazardous
or potentially hazardous materials as determined by experience, investi-
gation and literature.

          (b)  The lists shall be so divided as to provide an element of
delineation.

          (c)  Any material or substance proven to be hazardous by actual
contamination or injury shall be placed on the list with the proper informa-
tion to guide subsequent handling.

75.232.   Effect of listing or non-listing.

          (a)  The naming or omission of any material or substance should
not be construed to be the ultimate determination of classification.

          (b)  No substance should be considered wholly free of suspicion
as a hazardous agent solely based on its absence from the Department's
listing.

75.233.   Listing by toxicity.

          (a)  Each item or class of item shall be listed by common name,
chemical name,trade name or otherwise identified.

          (b)  The lower limits of toxicity shall be indicated in the
listing.

          (c)  Recommended handling and disposal methods when known shall
be added to  the listing to assist in upgrading management practices.  Known
unsatisfactory handling practices shall be specifically delineated.

75.234.   Listing by flammability and explosiveness.

          (a)  Each item or class of item shall be listed by common name,
chemical name, trade name or otherwise identified.

          (b)  The conditions or limits of flammability or explosiveness
shall be indicated in the listing.  The listing shall include a lower
limit of the quantity considered hazardous even though respectfully handled.
                                      186

-------
                            Table E.6 continued

          (c)  The recommended handling and disposal methods shall bo
added to the listing when known.  Unsatisfactory handling practices shall
be specifically delineated.
75.235.  Listing by pathogenicity.

          (a)  Each item or class of item shall be listed by common name,
chemical name, trade name or otherwise identified.

          (b)  Quantity limitations which contribute to the hazardous
quality of the waste shall be provided.

          (c)  Both desirable and undesirable disposal methods shall be
included in the listing.

75.236.  Listing by radioactivity.

          (a)  Wastes shall be described by specific common name and
chemical name.

          (b)  The hazardous materials listing shall not be considered
all inclusive and shall be updated and expanded as new information becomes
available.

          (c)  References concerning the hazardous nature of materials
placed on the listing shall be maintained.

          (d)  Federal and State standards for handling and disposal
shall be followed.
                                  187

-------
                                 Table E.7


          Copy  of Department of Environmental Resources Internal
Instructions Concerning Issuance of Department of  Environmental Resources Permits

Regional Air Pollution Control Engineers
Regional Sanitary Engineers
Regional Sanitarians


Wesley E. Oilbertson - Deputy Secretary
     for Environmental Protection
As many of you know, we are now developing procedures to better coordinate
the issuance of permits in the Department in accordance with policy estab-
lished sometime ago.  It  is intended that these procedures will provide
for the following:

1.  Notification  (in a clear and concise manner) to any applicant of
    all permit requirements with respect to all rules and regulations
    of DER.

2.  Coordinated review of permit applications by DER staff.

3. -The issuance  of all required DER permits, for  a specific facility,
    at one  time.  That is, for example, an air pollution permit will
    not be  issued until all appropriate requirements for water pollution
    control, solid waste  management, and other DER programs have been
    satisfied.

While  the procedures to accomplish the above are being developed, you  are
asked  to make every effort  to achieve  these objectives during your  routine
permit processing operations.  Each.of you is hereby made responsible  for
ascertaining whether another Bureau is to be involved.  Coordinated permit
processing  procedures have been covered previously in directives from  the
environmental protection  bureaus.   Some of these directives called  for
merely notifying  the appropriate bureau when a permit was received  that may
fall under  their  regulations.  More positive action is now required.

It is  planned to  involve  the Regional  Environmental Protection Coordinators
In the development of  these procedures.  It also appears that some  permit
applications may  have  to  be modified  in order  to prevent redundancy and
simplify both  the applicant's  task and the DER review.

You will soon be  receiving  additional  guidance and requests for comments
on proposed procedures*
                                     188

-------
                                 Table E.8

           Key Officials Interviewed in Harrisburg,  Pennsylvania


See Figure E.2


Department of Environmental Resources
          Wesley E. Gilbertson
          Deputy for Environmental Protection and Regulation

          William Buccarelli
          Chief, Division of Solid Waste Management
          Bureau of Land Protection and Reclamation

          Ernest Giovannitti
          Chief, Division of Industrial Wastes
          Bureau of Water Quality Management
Environmental Quality Board
          Mary C. Harris
          Administrative Officer
Joint Legislative Air and Water Pollution Control and Conservation Committee
          Peter S. Duncan, III
          Executive Secretary
                                    189

-------
             APPENDIX F




DEVELOPMENT OF ECONOMIC DECISION MAPS
                 191

-------
                                   INTRODUCTION

     The cost of disposing of a hazardous waste includes the cost of transporting it to a
processing  site  and the  actual  cost  of processing it  at that site. The former  cost  is
proportional to  the distance the waste must be transported, and the latter depends on the
utilized capacity of the processing facility. Processing costs per unit of waste are smaller in
large facilities, reflecting the economies of scale of large operations.

     In most cases, optimization of the disposal strategy requires a balancing of these two
factors, since the larger processing facility is often  farther from the source than the smaller
facility. (If it is  not, there is no selection problem; we choose the larger and nearby facility.)
The selection problem can be framed in terms of the two alternative strategies diagrammed
in Figure F.I.

     We adopt as conventions that:  (a) Processing Site 1 has a smaller capacity than Site 2
(i.e., T! < T2),  and (b) Processing Site 1 is closer to the source than Site 2 (i.e., M[ 
-------
                                                    I/)
                                                    UJ

                                                    O
                                                    UJ
                                                    oc
                                                    O
                                                    z

                                                    c/5
                                                    V)
                                                    UJ
                                                    u
                                                    O
                                                    OC
                                                    a.

                                                    01
                                                    z
                                                    cc
                                                    UJ
                                                    QC
                                                    r:
194

-------
     AC  "  ACHW + CTW ( AV  +   AC   +   ACHR +  CTR
where:
                   DETERMINING THE LOWER COST STRATEGY

     The lower cost strategy is determined as follows from the relative costs of processing
and transport. We define the unit costs (cost per pound of hazardous chemical contained in
the waste) as:

                     c      - processing cost.
                     CHW  ~ handling cost (loading and unloading).
                     CHR  = nandling cost of residue.
                     CTW  = transP°rt cost °f waste per mile.
                     CTR  ~ transport cost of residue per mile.
                     Cp    = final disposal cost.

     The total unit cost, cj, for  processing by strategy i is then


     Ci = CHWi + CTWi   ("Wl)* Cpi  + CHRi + CTRi(\i)+ CFi
where:

     M^yj = miles waste is transported
     MRJ = miles residue is transported.

 For most strategies, some of these terms will be zero. For example:

     •   if there is no residue for final disposal,
         cHRi = cTRi = cFi = °

     •   If the processing and final disposal occur at the same site, C^JR = c-p^= 0

     •   If the waste is processed at the source, cj^^i ~ cTWi = ^

The difference in cost between two strategies (i = 1  and i = 2) is
Again, for most pairs of strategies, some of the terms in Equation (2) will be zero. For example

     •   If both strategies involve moving the waste from the source,

         ACHW =  °

                                      195

-------
         if the final residue is disposed of at the processing site,

         ACHR  = CTR  - °
     Of the cost terms appearing in Equation (2), we assume that only the processing cost,
CD,  depends on capacity (throughput). The  chemical processing literature shows that  the
capacity dependence is well represented by
                                  c   a T'°-4
                                   P
                                                                            O)
Therefore:
        Ac   = c ,  — c
          P     Pl     I
               c»   Vl'w
             = c
                Pl
                                                                             (4)
     The breakeven condition  can be expressed  by setting Ac=0 in  Equation (2) and
solving for AMW (or AMj^, if that is important in comparing the two alternatives). Doing
this yields:
-AI*
               'TW
ACHW + AC
                              ACHR
                                              TR
(AMR)
                                                                             (5)
     Substituting Equation (4) and rearranging terms gives:

                                             0.4
                          *- i    r    /  J--i \
                  -A!
                   c  ,    r     /T \ "•*-,
                 -^   [^(x1)
                   CTW   L     \V    J
                      "TW
                        "HW     UHR
                                                  (AMD)
                                                                      (6)
                                       196

-------
     Further rearrangement, including division by CPQ, the unit processing cost at a capacity
equal to the source load, gives:

               CTW
               c            c
                Po         cpo
        (-AM)
CTW
CP)
                           -Po
                                  ACHW+  A°HR+
                               0.4
                               0.4
       AC
 -  r,       HW
 po

AcTR(AMR)
                                                                      AC
                                                                        HR
                                                                              (7)
     The subscript 0 refers to the source of waste, and in general T0 < Tt  < T2 • When the
source level (T0) is determined for a given type of processing for a given waste, the last term
in Equation (7) is just a number, A. Thus Equation (7) can be written as:
       (.AM) ()
                 po
                                0.4
                       r-   /T  \°'4
                       [-0    ]
  +  A
(8)
     Since AM has dimensions of miles and the ratio CJW/CPQ has dimensions of (miles)"1,
the expression (-AM) (CJ\V/CPQ) 's dimensionless. For convenience we designate this dimen-
sionless expression as AB.

     Equation (8) can be used to determine some general rules  for bringing wastes from
separate  sources  together.  Suppose, for example, that A in Equation (8) is zero, either
because the  steps associated with the term are not included in either processing alternative
or because they are the same in  each alternative. Consider a network of waste sources, each
producing a  load T0 of waste, and spacing on a rectangular grid of spacing g.*

     Finally, consider the following alternatives:
         Process on-site, or
         Collect waste from 4 or 9 sources.

     We  assume each source has the same quantity of waste as the on-site process; each is
located on a square grid; and the waste from  each source is brought  to a  processing site at
* Actual spacing in miles is 9(cDg/cTw).
                                         197

-------
the center of the square (Figure F.2). Determine over what range of grid sizes (values of g)
each alternative is best. First, let us compare collection by 4's with on-site processing. In this
situation,
              T,
              T2
              TO/T,
              T,/T2
              A,
          To
          4T0
          1
          0.25
          A2
where:
        = Ib/day process on-site
        = Ib capacity of on-site facility
 T2     = capacity of off-site facility
A,, A2  = handling and final disposal costs
              To
              T,
     From Equation (8):
                                    0.4,
                    (1)  (1 - 0.25U*H)  - 0.425
From the geometry of the network, Figure F.3:
               B   = /2 g . B   = 0
                /            l
Therefore, collection by 4's is better than on-site processing if
                    - B  <0.425
or if
                      <   0.425
Solving for g gives
                g   < 0.601.
     Therefore, collection by 4's is better than on-site processing if the grid size, g, is less
 than 0.601.
                                          198

-------
T
 01

JL
                                                                   CO

                                                                   LU
                                                                   <

                                                                   Z

                                                                   cc
0 x° °* x°
\ / *Vw. t/
* * » *
S*. * *
/* N / \
ox o o o



o o o o
^x^ \'

vt
5*
A
c
o
'*3
O
_«
"5
O
                                                                   Z
                                                                   g


                                                                   o
                                                                   o
                                                                   o
                                                                   LL
                                                                   a

                                                                   UL
                                      199

-------
                                         o         o
                      o
o
                          °
 t
9/2

 I
                          O
0
A
                                              //
                                                          o
       Collection by 4's
      Collection by 9's
  O Source of Waste


  XProcessing Site
                  FIGURE F.3   TRANSPORT GEOMETRY
                                   200

-------
    Now let us compare collection by 9's with collection by 4's. For this

             T,   = 4T0
             T2   = 9T0
          To/T,   = 1/4
          Tt/T2   - 4/9
             A,   - A2

From Equation (8),

           Afi - 0.1595


From geometry
Therefore
           /2g - /2g  <  0.1595
                  2
or

           g < 0.226.
    The results of these calculations for higher degrees of collection are summarized in
Table F.I.
                                   TABLE F.1

                       EFFECT OF DIMENSIONLESS GRID SIZE
                           ON DEGREE OF COLLECTION

         Optimum Degree                               Range of
         of Collection                                Grid  Sizes
         No collections                           larger than 0.601
         By 4's                                     0.226 to 0.601
         By 9's                                     0.121 to 0.226
         By 16's                                   0.0767 to 0.121
         By 25's                                   0.0532 to 0.0767
         By 36's                                   0.0407 to 0.0532
         By 49's                                   0.0302 to 0.0407
         By 64's                                   0.0240 to 0.0302
         By 81's                                   0.0197 to 0.0240

                                    201

-------
     The dimensionless grid size g can be converted to miles (m) according to
                                m = g
     The  ratio cpO/cTW Pr°bably lies in the range of  10 to 1000 for most processing
methods.  The data shown in Table F.I are plotted in Figure F.4 for values of cDQ/oryv of 1
to 1000. The parallel bands rising to the right show the ranges of grid size for which each
degree of collection is optimal. "Collection by 1" is on-site processing.

     Figure  F.4 is used as follows. If the source grid size (distance between  sources) is 30
miles,  and  the  value  of CpQ/c-rw  is  100, locate  the  point on the  decision map that
corresponds to these values. The point lies in the "Collect  by 4's" band,  so collection by 4's
is less expensive than on-site processing or collection from a larger number of sources.
                                         202

-------
10,000
 1,000  -
o
  100   —
   10
                                                                                    Collection By
                                                                               64  49  36   25   16
                                     10
                                                                   100
                                              Source Grid Size (miles)
1,000
                        FIGURE F.4   EFFECT OF GRID SIZE ON DEGREE OF COLLECTION
                                                 203

-------
The area to be served by a facility collecting waste from NC sources legated "g" miles apart
is
                             A = Ncg2                                      (13)
     Substituting Equation (12) into Equation (13) yields:

                                           ,0.91
                         A  =(1.23)    (eye  Q)1.09 (gcT/cPo)           <14)
     Substituting Equation (9) into Equation (14) and solving for "g" gives:
        .-    Ai in      CT   1.20    0  0.48
        g~  T2T  L1°
the contour line to be expressed in terms of source size (T0), the standard base cost and
capacity (CD* and T*) and the area A.

     These contours are shown on the decision map, Figure F.5.
                                       204

-------
                                                                                   LLJ
                                                                                   Nl
                                                                                   to
                                                                                   m
                                                                                   U
                                                                                   tr


                                                                                   8

                                                                                   o
                                                                                   Q
                                                                                   UJ


                                                                                   i
                                                                                   Q.
                                                                             O     2


                                                                            1     i


                                                                             8     S
                                                                                   Q
CO
                                                                             3
                                                                             o
                                                                            CO
                                                                                   Q.

                                                                                   >-
(S3||oi) saojnog u89/v\;ag
                         205

-------
            DETERMINING THE BEST STRATEGY FROM SOURCE SIZE

     Although we had developed a means for selecting a strategy on the basis of cost ratio,
we found that the decision maps can be expressed  in a more useful form by converting the
cost ratio to source size.

     Processing costs of different capacities are related by
                cpo/CTW  =   (cp*/CTW)
                                                    0.4
                                      (9)
     CDQ is the unit processing cost at one waste level and source capacity T0 gallons per
year, and cp*  and T*  are similarly related and refer to  a standard base waste load used to
estimate cost. The breakeven line between on-site processing is given by
                         cpO/cTW " 1<66g
     Substituting Equation (10) into Equation (9) and solving for g yields:
                                     (10)
                9 =
Cp*/CTW
                                                         0.4
                                                                      (11)
     For a given waste, we estimate the unit processing cost cp* at a standard base capacity
T*. Equation (11) can then be plotted for that process on a decision map with coordinates
"g" (mean source separation) and T0 (source  size). An example is shown in Figure F.5. In
the region above and  to the right of the breakeven line, on-site processing is optimal. Below
and to the left of the line, off-site  processing  is optimal. Below and to the left of the line,
off-site processing is more economical. Contours showing the optimal area to  be served by
each offsite processing facility can  be drawn on the map to indicate the  best configuration
of regional processing  facilities for off-site processing.

     The optimal number of sources to be collected (Nc) for off-site processing is given by

                                                                     (12)
                                       206

-------
             IMPACT OF "NONHAZARDOUS" WASTES ON ECONOMICS
                       OF TREATING HAZARDOUS WASTES

     The design of a system to dispose of a certain type of hazardous waste can be seriously
deficient unless the context in which the design is made is suitably comprehensive.  For
example, we can design a system (series of processing facilities)  to process chlorinated
hydrocarbons, based on the  nature and volume of these wastes. However, other hydro-
carbon wastes, which  are  not hazardous by our ground rules, are  processed in the same
way — incineration with  scrubbing of  the exhaust gases.  A commercial  processor who
accepts  these wastes can  also treat the hazardous chlorinated hydrocarbons, and has an
immediate  and significant  scale advantage  over a processor who accepts only hazardous
hydrocarbons.

     A system designed to process only hazardous hydrocarbons may never be used since
the sources of these  wastes  may find  commercial processors closer at hand and  less
expensive. To illustrate this possibility, consider the following situations:

     (1)  Sources of hazardous hydrocarbons exist on a square  grid of size g^ miles.
         The source level of each source is T0 gallons per year (gpy).

     (2)  Additional sources (at level T0 gpy) of nonhazardous hydrocarbons exist on
         a  square grid such that the grid  size for all  sources (hazardous plus non-
         hazardous) is gj. miles, g^ is related to gjj by


                                     9t =  A 9h                          (16)

         where a is the fraction of the sources that produce hazardous wasies.

     (3)  One system of processing sites (H) is available to process only the hazardous
         wastes, and another system (T) to process all wastes.

     How much of the hazardous waste would go to H and how much could be more
cheaply disposed of using the T system? Hazardous waste sources for  which dt — d^> A  will
use the T system rather than  the H system, where dt is the distance from the source to the
closest T center and d^ is the distance  to  the  closest H center. A is the allowable extra
transport distance to a  T center made possible by the greater economies of scale enjoyed by
the T center:

                                   A   N -0.4    M -0.4
                                   A  = Nh      -  Nt
                                        207

-------
where N^ and Nt are the design values of numbers of sources to be collected for common
processing in the H and T systems, respectively.

     In  order to express A analytically in terms of gn and gt (or g^ and a), we must describe
the decision map in an equation.  This  cannot  be  done exactly, since  the  map is discon-
tinuous with a range of g values associated with each N. (Recall that in terms of dimension-
less distances, the two-dimensional decision map shrinks to a one-dimensional line.) How-
ever, the map can be approximated by plotting g versus N and fitting a line through the
midpoint of the g values. This is done in Figure F.6. The resulting empirically determined
line is
                     N =  1.23g-1*09                                     (17)
     Substituting Equation ( 1 7) into equation ( 1 6) yields
                     A =0.92  (gh0'A36
and since g* = -y/~o~gh, Equation (18) becomes


                     A= 0.92  (1 -«0.2
     The question then is, "For how many of the hazardous waste sources is dt — d^ < A?
First, we assume that all  hazardous waste sources are a minimal distance from an H center,
namely d^ - g^/A/ZlvIost are farther away, so this assumption biases the analyses in favor of
the H centers. With this assumption, the decision criterion can be changed to


                      dt -R                                               (20)
where                 R = A +  \l&-                                       (21)

                         =          -   0'218    °-436                    (22)
                      R  = 0.92  (1 -  a')  gh-     +  0.707
     Those hazardous waste sources which lie within a circle of radius R centered at a T
center will use the T center. Assuming that hazardous sources are uniformly distributed, the
fraction failing to meet the above criterion and using the H center is equal to the fraction of
the total area outside of circles of radius R centered at the T centers. This in turn depends
on the relative values of R and the separation (S) between T  centers. Figure F.7 shows the
situation. The desired fraction (f^) is the ratio of the shaded area to the rectangular area (S
x S). From geometry, the following relations apply
                                        208

-------
      1.0
i   w
   e
   D
                              g = K/NJ



                    when   N = 4  g = 0.340



                           N = 100 g = 0.0175



                         / 0.340 \  _  /100\j


                      "  V0.175/     \ 4 /





                    and    0.0175 = K/1000'92



                          g =  1.21/N0'92
                    or     N = 1.23/g
                                    1.09
J = 0.92
K = 1.
     0.01
                                                               10
                                                     N — Degree of Collection
                               FIGURE F.6   EMPIRICAL FITTING OF DIMENSIONLESS DECISION MAP
                                                                                                                      100
                                                             209

-------
                      Sfladed Area to H Center
FIGURE  F.7   COLLECTION SITE DISTRIBUTION GEOMETRY
                        210

-------
                                                                                      GO
                                                                                      C)
                                                                                      CD

                                                                                      C)
                                                                       to
                                                                       cr
                                                                                     CM
                                                                                     ci
                                                                                                       z
                                                                                                       LU
                                                                                                       O

                                                                                                       I
                                                                                                       Q

                                                                                                       <
                                          LU
                                          CD
                                          v>
                                          LU
                                          O
                                          cc
                                          D
                                          O
                                          CO
                                                                                                       CO
                                                                                                       
-------

  where:   cos  2   =  2R      R >7^~                                     (23c)
            f h =  0

      The middle relation is necessary to account for overlapping of the circles. Values of f^
  and ft (1 - fjj) are plotted against R/S in Figure F.8. f^ is interpreted as that fraction of the
  hazardous waste sources which will utilize H centers rather than T centers.

      All that remains is to express R/S in terms of the g^ and  a, the given parameters.
  Equation (22) expresses R in these terms. The separation between T centers is given by
                                  9t
Using Equation (17),

            S =   /(1. 23  g)-l-09
                   1.11 g-0.545=1>11    0.455                     (25)
                           gt--    gt
                                                gt


Since  gt =   /a~  g^i   Equation (25)  becomes

              s  = lell  a0.227   %0.455                                    (26)
  Combining Equations (22) and (26) yields
              R            M-cxO.218)     n n,n     0.636 9h°-545
                                       gh-°-019 +  ——
                                        212

-------
We are interested in the range of R/S from zero to 0.707 (f^ from one to zero). To map out
the performance of the competitive systems, we:

     a)   substitute values of a. and gn into Equation (27) and compute R/S;

     b)   determine fu from Figure F.8;

     c)   list that value of f^ at the proper coordinate on an a versus gn plot; and

     d)   draw contours of constant f^ on the map.

     The a — gn decision map is  shown on Figure F.9. The map is used as follows: Given gu
and a, enter the  map  and locate the corresponding point.  Read off the value of f^. For
example, if  g^ = 0.1  and a= 0.3, the corresponding map point falls between the 0.10 and
0.30 fj^ contours. By interpolation, f^ =  0.25. This value is interpreted to mean that for the
assumed conditions 25 percent of the hazardous waste  sources would  use the H system
rather than the T system.

     The map is conservative; that is, the percentage of hazardous sources shown to use the
H centers is  biased on the high side. This bias arises from the simplifying assumption that all
hazardous sources are a minimal  distance from an H center; see Equations (20) — (22) and
the preceding discussion. In  fact, 50 percent is the  maximum H center usage. If all sources
were hazardous (a = 1.0, the  best  situation for H centers), the H and T systems would be the
same  and each would be expected  to  receive 50 percent of the waste  on the basis of
symmetry.

     Examination of the map shows that only at  small  grid sizes and large a does the H
system  get  much of  the  business anticipated  in its  design. The T system has a decided
advantage because  of:  (a) inherent  economies of  scale,  and (b) the  fact that optimal
collection practice puts T centers  closer together than H centers.

     This decision map can be used iteratively in H system design to show that for most
values of a  and g^, the optimum H system is no system at  all. Assume, for example, that
gk=  0.1  and a = 0.5.  From the decision map f^ = 0.60. Therefore, only 60 percent of the
hazardous wastes goes to  the H  center and the rest look like nonhazardous wastes to the
system designer. Therefore, of 100 sources, 70 go to T centers [50 + 0.4 (50)]  and 30 go to
H centers [50—0.4(50)]. We can compute a new a and g^ based on this allocation of sources
and get

                          a =  (0.5)  (0.60)  =  0.3

                                       /50"
                          gh - (O.D/.30"    =   0.129
                                       213

-------
                                                                          en
                                                                          o
                                                                          00
                                                                          0
                                                                          r-
                                                                          d
                                                                                         M
                                                                                         oc
                                                                          
                                                                         CM
                                                                         d
oq
P
CO
d
CN
d
    sajse/v\ snopjezBH Bupnpojj sgojnog j.o
                                  214

-------
     At these coordinates, fn= 0.15 so only 15 percent of the remaining sources assumed to
use the H centers would in fact do so (4 or 5 of 100 total).

     Recomputing a and gu again gives

                             a  = (0.3)  (0.15) =  0.045

                                            /30~"
                             gh = 0.129 /.045  -  0.334


     From the decision map at these coordinates, fu = 0, and all sources go to the T centers.

     This  iterative progression  suggests what  may be  otherwise obvious. The H centers,
which have an inherent disadvantage due to economies  of scale, cannot recover their costs
and  stay  in  business  if an  appreciable fraction  of the total wastes  to be  treated is
nonhazardous. The  H  centers could of course remain in business by pricing their services
below cost.
                                        215

-------
                   EFFECT OF SOURCE SIZE DIFFERENCES ON
                     RESULTS OF USING THE DECISION MAPS

     The decision model analysis is based on the assumption that all sources are of the same
size. In fact, sources vary markedly in size within a geographical area. The principal error
that can occur in applying the model with its uniform source size assumption is that a
larger-than-average source located near the boundary of the area served by the collection site
may find on-site  processing cheaper than using the site recommended by the model. The
likelihood of this occurring can be calculated as a function of source size and distance from
the collection site.

     Consider a collection site of capacity T! serving N sources. The mean source size T0 is

                                TO = TT/N                                (28)
     A large source of size T: (Tj > T0) is located on the boundary of the area served by the
site and is a distance

                                    „  (^N-l)
                                 m      J2       g                        (29)


from the site. (Mm is the maximum distance from a source in a square grid pattern to a site
located at the center of the N sources served.)

     The unit cost of using the site for disposal is

                                cs  * Cp1  + M  ctw                         (30)

and the cost of treating on-site is
Use of the central site is cheaper if
or if
                                        cpj                                (31)
                                   Cc < CJ
                                         j                                  (32)
                              CP1 + MCtw  < Cpj                           <33>
                                        216

-------
Solving for M gives
                            M <
CPJ  " CP1
   ctw
                                                                            (34)
     The "six tenths" rule, which gives cp a T"°'4 allows Equation (34) to be expressed as
                       •M
                                                                            (35)
     Solving for T.-/T! , the ratio of large source size to collection site capacity, gives
                                                 (2.5
   M -^=-
   _ cpl
                                             +  1
                                                                            (36)
     Equation (36) shows that if (TJTi ) is less than the right-hand term, the source will use
the collection site. If (T:/Ti ) is larger, on-site processing is more economical. As the distance
M increases, the limit of (Tj/Tj ) decreases, showing that the farther the source is from the
site, the smaller the source which allows economical on-site processing.
     The farthest a source can be from a collection site is Mm, Equation  (29). Mm is a
function of N and g, the source grid size. Also g was empirically related to N by
                                      po
                                                                            (37)
Substituting Equations  (28) and (29) into Equation (36)  and setting the term cpQ/cpj
which arises equal to N° -4 yields
                           <
                              0.840  (/N-1
                                  N0.517
                                                   _ 2.5
                                          (38)
                                        217

-------
     The source size T: can be expressed in terms of mean source size, T0, since T! = NT0.
The  equation can be generalized to source-site distrances (M) less than Mm by inserting a =
M/Mm into the right-hand term. Thus, Equation (38) becomes
1
                                 0.840  (/N-l)
                                -    N0.517
                                                        2.5
                                                                              (39)
     For a  collection  site serving N sources, all sources smaller than T; computed from
Equation (39) with a = 1 will use the collection site. For a < 1, say a = 0.5, all sources of
size T: computed from Equation (39) and lying with aMm of the site will use the site. Those
lying  farther away (from  oMm  to  Mm)  will enjoy cheaper  disposal on-site.  Assuming a
uniform distribution, the fraction of sources (and the fraction of any given size source as
well) lying within «Mm of the collection site is
                              P = <-Su>   = a                                (4°)
p is therefore the probability that a source of size T: will use the collection site.

     Using Equations  (39) and  (40)  yields the answer to the original question.  These
equations were solved for serveral values of N and a. The results are shown on Figure F.10.
Source size, expressed in multiples of the mean source size T0, is plotted on one axis. The
probability that a source of size T: will utilize the collection site is plotted on the other axis.
The figure shows that the larger the collection site, the less sensitive the use of the site is to
the occurrence of sources larger than the mean. For example, for a site serving 9 sources, all
sources smaller than 3.1 T0  will use the  site  no matter where they are located in the site
collection  area. Only about half the sources as large  as 4 T0 would use the site. As N
increases to 16, the comparable sizes are 5 T0  and  6.6 T0, and at N = 25,  they are 7.3 T0
and 9.9 Ts,0. We conclude,  therefore,  that the utility of  the  model is  not seriously
jeopardized by the assumption of uniform  source  size,  particularly  where the  model
recommends collection of upwards of 10 sources.
                                        218

-------
                                                                                  CO
                                                                               o
                                                                               o>
                                                                               c»
                                                                                   o
                                                                                  C/5
                                                                                   c
                                                                                   CD
                                                                                   0)
                                                                                   a.
                                                                               CO
                                                                                   Q.
                                     UJ
                                     Q
                                     O
                                     N
                                     CO
                                     HI
                                     o
                                     QC
                                     D
                                     O
                                     CO
                                     u.
                                     O

                                     O
                                     ui
                                                                           H  in .2
                                                                                  co
                                                                                   o
                                                                                   to
                                                                                             
-------
           UTILIZATION OF THE DECISION MAPS ON SELECTED WASTES

     To determine the true effectiveness of the model, we selected a few wastes and carried
them through the modeling process. We  chose incineration with alkaline scrubbing as the
process  and selected  from our 35 categories of wastes those that  could be treated by
incineration and  scrubbing:  the  organic  pesticides, many of the miscellaneous organic
compounds, and the aromatic and  aliphatic organochlorine compounds. Next we identified
waste streams in the Northeast region which fit these categories. Given the Icoation of these
sources and the description of type  and amount of waste generated by each, we:

     •   Estimated the cost for on-site processing of waste from the largest source.
         When this cost is  divided by the transportation cost, the smallest value of
         coO/cTW applicable to any of the samples sources results.

     •   Established  the on-site  processing costs  for  each  of  the  smaller  sources
         according to the  six-tenths  scale  rule. These  costs are higher than that
         estimated for the largest source and  therefore result in higher values of
         CP0/CTW-

     •   Estimated the average source grid size (g)  by taking the square root of: the
         area in  which the sampled sources were found  divided by the number of
         sources.

     •   Plotted CpO/c7\y versus  g for each of the sampled  sources on the decision
         map and listed the degree of collection shown on the map  for each source.
         The largest source (smallest C/cy) has the  smallest degree of collection.
     On  the basis  of waste source data  from  the  field,  we  identified  15 sources of
chlorinated  hydrocarbons as to  composition and volume.  Six represented  continuous
sources; the  remaining nine were "one-shot." The data are summarized in Table F.2.

     The  six continuous sources  range  in volume  from 750,000 gallons/year to 5000
gallons/year. One-shot sources range down to 800 gallons. To define the number of regular
sources that this sample represents, we took the six  continuous sources and four of the
one-shot sources. The inclusion of the latter four was arbitrary and based on the hypothesis
that there will  continue to  be  one-shot sources,  although perhaps not  as many as in the
recent past.

     The  choice  was also governed  by our  strategy of biasing our analyses, within the
uncertainties present, toward a recommendation for on-site processing. As is discussed later,
this bias is supported by few sources (large source grid size), low processing costs and high
transportation costs.
                                        220

-------
       Q

       o
                   W

                   !

                O  4-1

                C  -rl

                CO  iH

                4J  «H

                CO  O

               •H  n)
               13  4J

                0)  C
               4J  0)

                O  0
                0)  4-1

               •O Ct)

                O  0)
                   O
                   oo   o
                    I    O
                   O   CO
                o
                CM
                CO
                                        CM
m
CM
                CM
                                o
                                oo
                                                                        o
                                                                        en
o   o
oo   oo
en   CM
               in
               CO
oo
o
CO

<
       LLJ


       CO

       <




       O
cc
o

cc
O
                                          o    o
                                                               O  'O   O   O
                          W
                                                           oOoOCiOoOoOoOoOciOoO
                   ooooooooooooooo
                   ooooooooooooooo
                   OOOOOOOOOOOOOOOO

                                                                        OHOincn
                                                                        m         OCM
                                    m
                                               moooo
o
en
                        in
                        tTi
                         i
                        o
                        oo
                                    o
                                    en
                                      I
                                    m
                                    CM
m


o
en
                                     OOO
                           en   in   o   o
                                                     N
                                                     a
                                                     cu

                                                     •§
                                                     M
                                                     O
                                                     O

                                                     O
                                                          QQQ
    m



i   o
I   vO
                                                                             •a   -s
                                                                          in
                                                                                               S   S
                                                                                        rt
                                                                                        cu
                                                                                                                  M
                                                                                                                  CU
                                                                                                           cfl
                                                                                                           bO
                                                                   I
                                                                   CU


                                                                  <§
                                                                                             CO

                                                                                             3

                                                                                             O
                                                                                             3

                                                                                             C
                                                                                             •H
                                                                                             4J


                                                                                             O
                                                                221

-------
     The processing costs were estimated for the largest waste sources (750,000  gpy) and
scaled by the six-tenths rule for the smaller sources.

     Table F.3 summarizes the operating cost for such an  incinerator/scrubbing system
operating  at design capacity  of  750,000  gallons/year. Note that caustic  soda used to
neutralize and  scrub  out  the  HC1 generated,  would  be the  single largest  cost item, 13
tons/day or  $1100/day, based on $80/pound sodium hydroxide. If a cheaper  source of
alkali could be found, for example, lime, savings in the neutralization requirements, could be
substantial, although labor costs will go up somewhat for the handling of this  solid material.
However, whichever alkali  is used for the neutralization, we assume it will be used both for
the on-site recovery and for any off-site treatment systems that we are comparing in the
model. Therefore, these items would cancel out. The  19.4^/gallon for depreciation of the
facility is  based on our estimated $700,000 investment cost, depreciation over five years.
Figure F. 11  shows a  breakdown  of our  investment cost.  The utility requirements of
chemicals, cooling water, and fuel are detailed in Table F.4 and Table F.5.

     In  summary, the  processing costs for the 750,000 gallons/year source were  estimated
to be:

              Chemical and Utilities                54^/gallon
              Labor                                2
              Capital  Related Costs                26_
                                                  82?f/gallon

Only the scale-dependent costs (labor and capital related costs) are relevant to decision map
analyses of the source data. The sum of these costs is cpQ = 28<^/gallon.

     Transportation costs were obtained from several places. The literature*  cites line-haul
costs of liquids at 5^/ton-mile in the 750- to 1500-gallon range and 3^/ton-mile in the 3800-
to 5000-gallon range. (Line-haul costs are associated directly with  road miles traveled and do
not include terminal handling or administrative costs.) From private communications with a
company  transportating  wastes,   we  obtained estimates  of  costs  at  $1.50/mile for
5000-gallon tankers, which figures to about 7.5q!/ton-mile.  Since high transportation costs
bias  the  analyses  toward on-site  processing, we chose  to use  the  7.5^/ton-mile (or
0.03^/gal-mile) figure.
  Oi, W. Y., and  A. P. Hurter, Jr., Economics of  Private Truck Transportation, Wm. C. Brown Co.
  Dubuque, Iowa (1965), pp 170-171.
                                         222

-------
                               oo
                               ro
                               m
                                                                               co
                                                                               oo
                                                                               CM
                                                             CM
                                                             00
                       vD 00

                       vO CM
                       CO
                                          vD  CO
                                          sr  r*
                  CO



                  CTi
                                                                      oo

                                                                      st
                                                                               co
                                                                               ON
                                                                              tfl
                                                                             T>
               p

               •CO-
GO
O
U
cc
D
O
O
5
 I
CO

i
cc
cc
a
>
i
a
           •rl  CO
            c  o
           1=)  U
                        o si- CM
                        O 00 CO
                        rH     si-
                        si-  m O
                        O  O rH
                        O  O O
                        •co-
                                              CM
                                              CM
                                     CO
                                     00
                                     m
                                     oo
                                     m
                                                                                       CM
                  o
                  m   I
                  m
                                             rt
                                             4-1
                                             o
                                            H
                                                             o
                                                             o
                                                             o
                                              O
                                              O
                                              O
                                                9\
                                              m
                                              CO
                                     o
                                     o
                                     o
                                                                                                      s
                                                                                                     •H
                                                                                                      4-1
                                                                                                      CU
                                                                                                      ex
                                                                                                     o
 §
-So'
 rt  o
 u  o
 o    «
 M  O
T3  O
T3  4J
 
rH  C
CC
O

I
U
LL
O
z
o
    cd
    OOrH
,Q      cd
rH  g  60

O  O O
O  00 CM
si-  SO CO
                        CM
 Cd  O


 CO  rH

,C  6-S
    O
oo  m
                                                                                                      rH  (0
                                                                                                      CO, O
                                                                                                      00
                                                                                                         -a

                                                                                                      §  8
                                                                                                      O -rl
cc
LU
Z
O
                             OOrH
                                 O
                                                                                                      •H si-
                                                                                                      3 CM
                                                                                                      O"-'
                                                                                                      0)
                                                                                                      -O
                                                                                                      •^  t-l
                                                                                                      rH  CU
                                                                                                       cd  ex
                                                                                                       00
                                                                                                          CO
                                                                                                      o  >~>
                                                                                                      o  cd
                                                                                                      o  -a
                                                                                                        M
                                                                                                      co  m
                                                                                                      ca
                                                                                                      •rl
                                                                                                      CO
                                                                                                      cd
                                                                                                      P3
                                                                                                      •K
                                                  223

-------
r
                   c

                ELL
                                   CD
                                   O)
                                    u
                                    u.
                                    re
                                   ill
                                   O
                                                                O>
                                                       CO



                                                      UJ

                                                      O
                                                               CD
                                                               O)
                                                               u
                                                               ^
                                                               CD
                                     LU

                                     O
                                                      O)


                                                      .c

                                                      i—
                                                      to


                                                      IJJ

                                                      O
to


O
a
                               0)


                               a


                               tr
                               .S
                               u
i  §  8
CD  00
    CM
                     li
                                                                o  o  o   o   o
                                                                •*  CM  O   «-   «-
                                                                                    8
                                                                                              co
                                                                                              CM
                                                                                         00

                                                                                         X
   I
                                                                                               a

                                                                                              '5
                                                                                               CT
                                                                                              LU
                                                                                               R)
                                                                                              £
                                                                                               U
                                                                                              1
                                                                                             CM
                                                                                             O
                                                                                             0)


                                                                                             I
                                                                                             c
                                                                                              a
                                                                                              CD
                                                                                             O

                                                                                             •g
                                                                               8
                                                                               u
                                    tt
                                    c
                                                                         _      o
                                   o
                                   CM
                                    2
                                    CO

                                    "H3
                                       o
             Q.

             |


             Q.

             O>
             C
                     §   |
                     +-«   »-
                     (0   3

                     E  *
                     8  I
                                                            .
                                            C   "L   ®   **>  -*-'

                                            te                *
                              X

                              £
                             .2
                             '•5




                         ill
                                              s      _
                                              §      1
                                              S,      .E
                                              re      to

                                              2  ,  &
I
     §
     ID
f2-£omg.>--a^

 Sli-biS^bb
LL§_   <

                                                                               o
                                                                                                                  o
                                                                                                                  ._!

                                                                                                                  b
                                                                                                                  V)

                                                                                                                  O
                                                                                                                  U
                                                                                                                  C
                                                                                                                  HI
                                                                                                                  z

                                                                                                                  o
                                                                                                        LL

                                                                                                        LU

                                                                                                        CC

                                                                                                        D
                                                                                ^

                                                                                ^
                                                                                4^
                                                                                CO
                                                     224

-------
                                        TABLE F.4

                      CALCULATION OF AUXILIARY FUEL REQUIREMENTS



   Incineration of Chlorinated Hydrocarbons  -  Modular Disposal Cost

   Example:   Polychlorinated Biphenyls or Chlorobenzenes

       Heat  of combustion  (use hexachlorobenzene at 509 K Cal per gm/m°le):
                            Mol Wt C6C16 = 72  +  6  (35.5) - 72 + 213 = 285
        509K Cal
          285 g
          x  1,800 = 3,200 Btu/lb from combustion
        C,C1, + 60,
         DO     t
                    6C02 + 3C12
Heat Input  for 80 F
                                     1832 F
        285 Ib hexachlorobenzene
Flue Gas
C12 3 moles
CO 2 6 moles
N» 28 moles
Qj _3 moles
40 moles
1633 Ib flue gas
Cp Btu/16 I
0.17 x
0.28
0.27
0.26

IT 5 75 IK f\
                                          0.26
                                                     At
                                                   1752 F
                                                    Lb  Gas /mole

                                                             213
                                                             264

                                                            1060
                                                              96
                                                                           /-,
                                                                    1633
         285 Ib  C,C1,                                v,  „
                  D  O

        5.75 Ib y. 0.26 x 1,752 F - 2,570  Btu/lb to heat flue  gas

    Between 8,000 and 10,000 Btu/lb are required to sustain stable combustion of liquid
wastes, although the above heat balance indicates that C6C16 at 3,200 Btu/lb could reach a
combustion temperature of 1832F with no heat losses.

    To create a fuel mixture of 10,000 Btu heat content would require mixing C6C16 with
fuel oil
                       (x) (3,200) +  (1  - x)  (19,000) -  10,000

                      x  - 0.57  Ib C  Cl   per 0.43 Ib fuel  oil
                                    6 6

 Therefore, use one pound fuel oil per pound chlorinated hydrocarbon.
                                     225

-------
                                  TABLE F.5

                        CHEMICAL UTILITY REQUIREMENTS



A.   Caustic Requirements (NaOH solution)

     HC1 1040 Ib/hr  (from 1350 Ib/hr C,C1,)
                                       0  O

     Na,CO~ + 2HC1 	^ 2NaCl + CO  + HO
       t*  ~)                         £    £.


     NaOH + HC1 	> NaCl + H20       Use 4c/lb



     4§-r  x 1040 Ib/hr =1140 Ib/hr
     3b.;>

     40 lb NaOH
     35 lb Cl



B.   Water Requirements  for HC1 Scrubber

                                                            vap     liq
                                                 A°F        300  F  80 F
     Q = 37,460 lb   flue gas  (0.27 Btu )  (2960 - 300)= W  (1193 - 48 Btu)
                hr                 lb  °F                              lb

     W = 23,500 Ib/hr =  2,820 gph = 47 gpm


     23,500 x 359 ft3    760°R     .,„. nrir.  ,3,,
               18 lb x  492oR  =  724,000 ft  /hr water vapor


         Water C  =  0.47 Btu        Gas C  =  0.27 Btu
                P        lb°F            P        lb°F

                                       y—  Water  75  F

                 Flue Gas	^   Scrubber  —>    Flue  Gas  100 F
                  300 F        I	1	

                                   >Water  130  F
     Dry  flue  gas  37,460  lb_ x 0.27  x (300-100)°F = 2,023,000
                          hr
     Water  (23,500 lb + 2,100 lb)  (1193 - 98  Btu) = 28,032,000
                    hr          hr               lb
     HC1  solution  in NaOH =  916,000         = W (130-75)     W = 563,000 Ib/hr
                             30,971,000 Btu                  (67,520 gal/hr)
                                        hr

                                      226

-------
     The value of CPQ/CJ^ f°r the largest source is  therefore 28/0.03 = 933,  which is
rounded  to  1000 within the accuracy of the calculation. Values for the other continuous
sources (and one added  1000  gallon/year source to cover the range of the field data)  are
shown below.

                    Source Volume (gpy)         (c Q/CTW)*

                          750,000                   1,000
                           40,000                  3,200
                           20,000                  4,300
                           15,000                  4,800
                           10,000                  5,600
                            5,000                  7,400
                            1,000                 10,000

     The locations of  these sources range from Massachusetts  to  West Virginia, an area
roughly 500 miles by 300 miles.  Since we assume that the data represent 10  effective
continuous sources, the effective source grid size (separation between sources) is
                          300 x  500
                             10          -     120 miles
The area could be defined to be smaller, say 300 miles by 300 miles. However, in keeping
with our strategy to bias the analyses toward on-site processing, we chose the higher value.

     The seven source points are plotted on Figure F. 12. The collection bands in which each
of the source points fall are shown below:
                     Source Volume (gpy)      Degree of Collection
                          750,000                  9-16
                           40,000                   49
                           20,000                   64
                           15,000                   64
                           10,000                   81
                            5,000                  100+
                            1,000                  100+
 'Values for smaller sources computed from
                                      227

-------
     The interpretation is  that even if all 10 sources found in the area generated 750,000
gallons  of  waste per year they should be collected for processing at  a  single site. If all
sources were of 40,000-gpy volume, as many as 49 (39 more than in the total original
sample) should be  collected.  If  all sources were  even smaller,  still higher degrees of
collection are called for. The conclusion is that if our sample includes all sources of waste in
the area, the optimal strategy is to collect them all for processing at one site.

     Undoubtedly other sources of similar waste are in the area. What characteristics would
these sources have to show to change our conclusion that all sources should be collected for
common processing to the conclusion that on-site processing is justified? The decision map
shows that at a grid  size of 120 miles,  CpW/Cj^y must be 200 or lower to make on-site
processing justifiable (Point A on the decision map). The cost  ratio of 200 corresponds to a
source volume  of about 42 million gallons per year (according to the six-tenths rule), a
factor larger by more than 50 than the largest source found in the first sample. If we found
one  of  these very large sources, our conclusion would not  change. If we found two there
might be  some question,  depending on  their relative  location, as to whether the  total
number of sources should  be divided between two facilities, one near or at each very large
source.  Still this is not on-site processing for most of the sources. As the number of very large
sources increases, the separation between them decreases, reducing the feasibility of on-site
processing for even the very large sources.

     Based on these facts, it is impossible that identification of additional sources could lead
to a conclusion  that extensive on-site processing is economically  feasible. The only real
question that remains is the degrees, of collection which minimizes cost. Should waste from
all sources in the area be collected  at one processing facility or at two or three? The answer
depends on the size of the additional sources found. Suppose that we find 10 more sources,
bringing the total to 20. The effective grid size is
                              500 x  300           ._   ..
                                —^T;	    =      85 miles
     For the total collection conclusion to remain applicable, the average value of
for the 20 sources  must be 1150  or greater, corresponding  to an average  volume only
slightly less than that of the largest source in the original sample. In this range of values, the
degree of collection  called for is equal to or greater than the total number of sources found.

     As more sources are found, the effective grid scale shrinks, and the minimum value of
the average CPQ/CJW rises slightly, approaching 2000  for 100 sources. This  says that the
average volume  of all 100 sources must be at least 40,000 gpy, larger than all but one of the
six continuous sources found in the first sample.
                                        228

-------
Therefore, we conclude on the basis of this sample that:

a)   all sources of waste in the area should be collected for processing at a single
     facility; and

b)   the discovery of additional sources is highly  unlikely to change that  con-
     clusion.
                                    229

-------
                                                                                                   Collection By
   100,000
   10,000  -
f
o
    1,000
     100
                                                                                           81 64  49   36   25    16
         10
                                            100
                                                                               1,000
10,000
                                                     Source Grid Size (miles)
                                           FIGURE  F.12   DECISION MAP FOR TEST RUN
                                                          230

-------
              EFFECT OF ASSUMPTIONS ON DECISION MAP UTILITY

     This  model  computes  the  optimal  number of individual source  points from  which
wastes should be  collected and processed at a single facility.  It does this by balancing
transportation costs against the economics of scale inherent in large-scale processing. Since
the assumptions bearing  on the expression of these economies of scale are critical  to the
utility of the model, we examined them.

Assumption (1) Only those processing costs related to capital investment and labor are scale
dependent; costs  for chemicals and utilities are directly  proportional to amount  of waste
processed and are therefore independent of scale on a unit-waste basis.

     This  is not really an assumption; it is a fact. The incineration process requires additional
fuel  (proportional to the amount of waste and combustion air to be heated), cooling water
(proportional to the heat load and hence to the waste load) and  caustic soda (proportional
to the amount of HC1 absorbed in the scrubbing of the  stack gas and  hence to the waste
load).

     For  incineration  of 3000 gpd of chlorinated  hydrocarbon, the cost of utilities and
chemical predominates, as shown below:

                                                  S/day    l/gal
                      Chemical and Utility Costs    1616      54
                      Labor                        66       2
                      Capital Related Costs         787      26
                                                  2469      82

     However, only the costs of labor (2^/gallon) and  capital (26^/gallon) are included in
the scale-dependent processing cost utilized in the model.

Assumption (2) Labor and  capital related costs,  per unit of waste processed, vary with
processing capacity raised to the -0.4 power.

     While  we  are interested in  costs  per unit of waste  processed, the  literature on
processing-scale economics is written in terms of total  cost.  If the total capital cost of a
processing facility of capacity T is C, the unit processing cost of interest to us is

                                       c = C/T
                                         231

-------
The correlation of total cost with capacity for many kinds of chemical processing plants has
led to the "six-tenths rule,"* which is expressed mathematically as

                                      C a Tm

where m = 0.6.

     On the unit waste basis, this rule is expressed as
                                    C    Tm
                                c = — a  —  aTn
                                    T    T

where n = m-1 and has the value -0.4 when m = 0.6.

How accurate is the "six-tenths rule?" It is applied  to a plant as a whole and is made up of
weighted averages of the exponents applying to the individual components which make up
the plant. These exponents can vary widely, as shown below:

                  Equipment                     Exponent (m)

             Process furnaces                        0.85
             Stacks                                 0.80 (on flow area)
             Fans                                   0.68
             Shell and tube heat exchangers           0.65
             Cooling towers                          0.60
             Centrifugal pumps                      0.52
             Storage tanks (up to 40,000 gallons)       0.30
             Air Compressors                        0.28

             Source:   Popper, H. (Ed), Modern Cost Engineering Techniques,
                      McGraw-Hill (1967) p. 8(M08l


     When  these pieces of equipment are combined in  a complete processing facility, the
exponent which is found to apply to the plant as a whole usually comes out to be around
0.6, the low exponents  on tankage, compressors and pumps balancing the higher exponents
on furnaces and stacks. Depending on the mixture of components, the overall exponent may
be as low as  0.5 or as high as 0.8. For the incineration of chlorinated  hydrocarbons with
scrubbing of the exhaust gases, the overall exponent can be computed as shown below:
 "Aries, R.S., and Newton, R.D., Chemical Engineering Cost Estimation^ McGraw-Hill (1955) pp 15-16.
                                        232

-------
                                                                     Scaled
                                      Cost For           Size        Cost For
        Type of Equipment           3000-gpd Plant     Exponent   300-gpd Plant
      Tankage                          44,000           0.30        22,000
      Furnace                          40,000           0.85         5,600
      Spray chamber and scrubber       120,000           0.60        30,000
      Air compressor                    10,000           0.28         5,200
      Fans                             10,000           0.68         2,100
      Pumps                             2,000           0.52           600
      Stock                              8,000           0.80         1,300
                                     $234,000                     $66,800

                        234,000 '
                       V     ~
      and m = 0.55.


     The computed overall exponent of 0.55 is close to that given by the "six-tenths rule."

Assumption (3) Estimated capital costs are translated into processing costs per unit of waste
by applying factors generally accepted in the chemical processing industry.

     To convert the $234,000 estimated capital cost for equipment into unit waste costs
requires:

     a)  Multiplying the equipment cost by a factor to cover  construction, installation and
auxiliary equipment (such as piping) to give  the fixed capital investment (FCI). Recom-
mended factors range  from  3.0 to 4.7.* We used 3.0, because  it reduces the bias in the
capital estimate.

     b)  Multiplying the fixed capital investment by annual  factors to cover amortization
and interest (or depreciation), maintenance, and insurance and taxes. Well accepted factors
for the chemical processing industry are:


                     Amortization  and interest     20% of FCI
                     Maintenance                  5% of FCI* *
                     Insurance and taxes            2% of FCI***
                                                  27%
** *
'Popper, H., op cit, p.3.
Ibid, p. 243.
Ibid, p. 252.
                                        233

-------
     The  20%  factor associated with amortization  and interest corresponds to a payout
period of 7 to 10 years, depending on the interest rate. Although some of the equipment
components have longer physical lives, replacement of some components and major mainte-
nance of others (not covered in the 5% maintenance factor) become necessary toward the
end  of the payout period. Therefore, the  20% factor  is  a realistic long-term  figure,
recognizing that it is used in the early years to pay off the initial capital investment and in
later years as a depreciation fund for equipment replacement and major maintenance.

     Consequently, our capital related processing costs are

                         $234,000x3x0.27=  $190,000/year
                                          or    $790/day
                                          or     26^/gallon of waste


Assumption (4) Labor  costs are included in the processing costs scaled by the "six-tenths
rule."

     In our example, labor costs are a minor part of the cost (2^/gallon versus 26^/gallon in
capital related costs). The correlation of data from many types of processing facilities shows
that  total labor cost varies with the 0.25 power of the plant capacity.* For the very small
facilities we are  dealing with,  the exponent is  probably more  nearly zero (same labor
required independent  of throughput). However, because of its small  relative magnitude and
the conservative  effect which  results,  we included labor  costs with  capital related costs
under the six-tenths rule.

     How are  the results of this analysis affected  by the assumptions  described above and
the way in which the model is applied? The critical  degree of collection obtained from the
model is associated with the largest source.  The processing costs at this scale are estimated
directly; no scaling by the six-tenths rule is involved in obtaining this cost. In addition, our
use of a conservative factor for converting estimated capital equipment  costs to fixed capital
investment (Assumption 3 above)  tends to bias  this value on the low side, toward lesser
degrees of collection.

     The degrees of collection associated with the smaller sources depend on the scale factor
used to extrapolate from the computed cost associated with the largest source. In any case,
however, the degrees  of collection associated with these sources are higher than those for
the largest source, and their exact values are not critical to the analysis.

     The location of the collection bands on the decision  map depends on the scale factor.
We have seen that the capacity  exponent on total  cost rarely falls outside of the range from
0.5 to 0.8, and that for our specific  process is 0.55.
 "Popper, H., op cit, p. 252.
                                         234

-------
     The overall effect of all of these assumptions can be tested by redoing the analysis for
different values of scale  factor. Figure F.I3  shows the decision  maps and  source  points
based on  scale factors of 0.5  through 0.8. The following tabulation lists the degrees of
collection associated with each point for each value of the scale factor.

                                      Degree of Collection at m  equal to
      Source Volume (gpy)           0.5        0.6         0.7       0.8
           750,000
             40,000
             20,000
             15,000
             10,000
             5,000
             1,000

     In  each  case, the degree of collection associated with the largest source  is comparable
to the number  of sources.  In each case, the degree of collection associated with the smaller
sources  is  significantly larger than  the  number of sources found. Thus, the results are
independent  of the scale exponent over the widest range of values of the exponent deemed
feasible.
9-16
49
64
81
100+
100+
100+
9-16
49
64
64
81
100+
100+
9-16
36
49
49
64
81
100+
9
25
25
25
36
36
64
                                         235

-------
EiwJrorr.--.v-il  rr-.-ittS'.lo

-------