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
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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
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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
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APPENDIX B1
DESCRIPTION OF WASTE TYPES
15
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
-------
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39
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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-------
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
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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
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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
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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
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APPENDIX D
RISK ANALYSIS
101
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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).
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APPENDIX E
ANALYSIS OF FEDERAL AND STATE LAWS
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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
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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
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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
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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
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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
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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
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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
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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
-------
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-------
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
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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.
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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.
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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.
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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
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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.
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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.
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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
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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;
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• 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.
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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.
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• 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.
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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
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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• 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.
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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.
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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
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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
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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
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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
-------
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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
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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
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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[
-------
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UJ
O
UJ
oc
O
z
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u
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OC
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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
-------
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199
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o o
o
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°
t
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O
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A
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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
-------
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Nl
to
m
U
tr
8
o
Q
UJ
i
Q.
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8 S
Q
CO
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Q.
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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
-------
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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
-------
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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