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                  APPENDIX D




     WASTE STREAM DATA SHEETS  FOR WASTES

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                                 A-257
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                                          A-258
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                                   A-259
-------
A-260
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A-261
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A-262
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A-263
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A-264
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                             A-265
-------
A-266
-------
2a/Milling    Gaseous (Continued)

     (a)   Production quantity calculated solely from specific
         activity of Rn-222f i.e., does not include Ibs/yr
         diluent (air).

     (b)   Production quantity does not include any airborne
         particulate wastes.  To date, no information found
         concerning quantity and/or activity distribution of
         particulates in ventilation exhaust.

     (c)    The actual distribution of the short-lived gas
          Radon 222 throughout the milling process is not
          known.  However, for the purposes of this study,
          it is assumed that all of the Radon^^? that is
          in secular equilibrium in the ore is released
          during the crushing and grinding operations and
          is exhausted to the air, through the ventilation
          control system.  The tabulated values do not in-
          clude the continued releases of Radon from the
          tailing piles as the Radon continues to be found
          from the normal decay of the radium contained in
          the tailings.    ~

  Note:   For additional bases and assumptions, see pages
          1.5, 1.6, 2.4 and 2.5 of Reference  A-9.
                              A-267
-------
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                   A-268
-------
2b/Milling    Liquid (Continued)

    (a)   Production quantity is that estimated for aqueous
         effluents from tailing ponds (S.OxlO8 gal/yr).
         About 7.0xl08 gal^Q(1.5 Ci) was discharged in this
         manner in 1967.     Most of the aqueous solutions
         discharged to tailing ponds are largely dissipated
         by evaporation or seepage.   Recycle of clarified
         water with limitation of plant water intake to
         just offset evaporation and seepage could be used
         to reduce effluent.

    (b)   For additional bases and assumptions, see pages
         1.5, 1.6, 2.4 and 2.5 of Reference A-9  .
                              A-269
-------
A-270
-------
2c/Milling    Solid (Continued)

     (a)   Production quantity based on estimated quantity of
          mill trailings in 1980.

                The bulk of radioisotopes, other than
                uranium, that are contained in the ori-
                ginal ore remain in the gangue which is
                stored in tailings piles...  Tailings
                comprise an assortment of particle size
                ranging from slime to sand...  Abandoned
                tailings piles are stabilized against
                wind and water erosion.

          Raffinate from the purification step and barren
          solution from the uranium precipitation step are
          chemically treated to precipitate the radio-
          isotopes; precipitate also is discharged with
          gangue to tailings piles.

    Note: For additional bases and assumptions, see pages
          1.5, 1.6, 2.4, and 2.5 of Reference A-9.
                              A-271
-------
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                           A-272
-------
3b/U Conversion Liquid   (Continued)

     (a)   Production quantity based on estimated quantity of
          off-gas scrubber solution being used in 1980 (^3000
          gal/min).   Approximately 180 gal/min of off-gas
          scrubber solution was treated in 1967, i«ett dis-
          charged to waterways via limestone beds. ~

   Note:   For additional bases and assumptions, see pages 151,
          1.6, 3.3,  and 3.4 of Reference A-9.
                             A-273
-------
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-------
3c/U Conversion Solid    (Continued)

     (a)   In one commercial facility solid wastes,  primarily
          contaminated inert fluidized bed material and ash
          from fluorination steps,  are drummed and  stored.
          Aqueous wastes are impounded.  In a second com-
          mercial facility, raffinate from a solvent ex-
          traction purification step is impounded in lime-
          stone lined earthen ponds.   Quantities of inerts
          and diluents associated with the above are un-
          known, therefore, production quantity calculated
          from specific activity of U-238.

   Note:   For additional bases and assumptions, see pages
          1.5, 1.6, 3.3, and 3.4 of Reference A-9.
                              A-275
-------
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4a/U-Enrichment Gaseous    (Continued)

     (a)   Airborne wastes containing uranium are those that
          leak from process equipment and escape exhaust air
          purification equipment.  Quantity of diluent (air)
          is unknown;  production quantity based on specific
          activity.

   Note:  For additional assumptions and bases,  see pages 1.5,
          1.6, 4.5, and 4.6 of Reference A-9.
                             A-277
-------
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                         A-278
-------
4b/U Enrichment Liquid   (Continued)

     (a)   Liquid wastes arise from chemical recovery of
          uranium from incineration of combustibles, flushes
          of process equipment,  and off-gas treatment and are
          discharged to the river after dilution and retention
          in a settling basin.  Quantity discharged is un-
          known and production quantity was calculated from
          specific activity.

   Note:   For additional assumptions and bases,  see pages 1.5,
          1.6, 4.5, and 4.6 of Reference A-9.
                              A-279
-------
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                                         A-280
-------
5a/Fuel Fabrication Gaseous    (Continued)

     (a)   Production quantity calculated from specific
          activity, does not include Ibs/yr diluent (air),

   Note:   For additional assumptions and bases/ see pages
          1.5, 1.6, and 5.1-5.9 of Reference A-9.
                             A-281
-------
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                                       A-282
-------
5b/Fuel Fabrication Liquid    (Continued)

     (a)   Liquid wastes resulting from the fuel fabrication
          process are the treated streams resulting from UF6
          conversion to UO?, precipitation or calcination
          conversion of Pu  (1^03)4 to PUC>2, from etching of
          fuel rods, scrubbing of off-gases and from non-
          process activities such as analytical operations,
          cleanup of glove boxes and process equipment,
          from labatories, showers, sinks, and etc.
          Production quantity was based on an estimated
          8,000 gal/MT of liquid waste produced per MTA~11
          and 5,400 MT of fuel fabrication activity in
          1980.

   Note:   For additional assumptions and bases, see pages
          1.5, 1.6, and 5.1-5.9 of Reference  A-9.
                              A-283
-------
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                                         A-284
-------
6a/Irradiation Gaseous    (Continued)

     (a)   Production quantity calculated from specific
          activity, i.e., does not include Ibs/yr
          diluent (air).

   Note:   For additional  bases and assumptions, see pages
          1.5, 1.6, and 6.3 of Reference A-9.
                              A-285
-------
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                          A-286
-------
6b/Fuel Irradiation Liquid    (Continued)

     (a)   Production quantity calculated from specific
          activity, i.e., does not include Ibs/yr diluent
          (water).   The effluent arises from the treatment
          of liquids resulting from coolant system leakage,
          contaminated drains, equipment decontamination,
          regeneration of ion exchange media, storage
          basins,  chemical analysis, and miscellaneous
          activities.  In 1971 it was noted that

                ...the liquid discharges (200,000 to
                about 6,000,000 gal/yr) are commonly
                diluted with the large volume (500,000
                to  5,000,000 gal/min) of condenser
                cooling water from a 1,000 MW  reactor
                before discharge to the river. A-i 2

          Installed capaq^tv jj^ojected for 1980 is about
          150,000 MW§.A~  'A~   Average effluent  (cooling
          tower blowaown) from the Trojan Nuclear Power
          Plant is  8,700 gal/min. A-13

   Note:   For additional bases and assumptions, see pages
          1.5, 1.6, and 6.3 of Reference A-9.
                              A-287
-------
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-------
7a/Reprocessing Gaseous (Continued)

     (a)   In general, fuel reprocessing involves acid dis-
          solution of spent fuel.   Most of the volatile
          fission products are volatilized during this
          step.  Currently, the noble gases are discharged
          to the atmosphere but greater than 99% of the
          radio iodine is removed.  Off-gas streams are
          diluted with ventilation exhuast and production
          quantity was calculated from an estimated 240,
          000 ftVmin stack effluent.A~

     (b)   Quantities of constituents were calculated by
          reducing information presented in Reference
          A-9 by a factor of 0.65.  This was done to
          reflect current projections of fuel reproces-
          sing requirements presented in Reference A-15.

     (c)   Proposed release requirements may require addi-
          tional krypton removal and some improvement  in
          iodine removal may be required if cooling time
          is reduced below about 200 days.  Potential
          techniques for removal of krypton (and xenon)
          from reprocessing plant gaseous effluents in-
          clude freon absorption, cryogenic distillation,
          low temperature carbon adsorption, room tem-
          perature carbon adsorption, carbon tectrachloride
          absorption, kerosene based solvent absorption,
          and the use of perma-selective membranes.  In
          addition to caustic scrubbing and AgNO-j impreg-
          nated adsorbers, potential iodine removal systems
          include HNO ~Hg  (NO^)2 scrubbing, concentrated
          HNOo~"Hg scrubbing^jcharcoal, and silver impreg-
          nated zeolites.A~

   Note:  For additional bases and assumptions, see pages
          1.5, 1.6, and 7.2-7.5 of Reference A-9.
                              A-289
-------

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                     A-290
-------
A-291
-------
7/b Reprocessing Low-Level Liquid (b)  (Continued)

     (a)   Production quantity was calculated from an
          estimated 3.2xl07 gal/yr effluent, apparently
          from the NFS West Valley treatment and lagoon
          system.A~1  However,  Reference A-8 noted that
          the discharge rate at this plant is about
          50,000 gal/day while average holdup time is
          one month.  Only this facility will have an
          aqueous effluent stream containing significant
          amounts of radioactivity.   The effluent arises
          from the distillation,  ion exchange, and chemical
          treatment of process condensates,  laundry wastes,
          decontamination operations,  and floor drains.

     (b)   Quantities of constituents were calculated by
          reducing information presented in Reference
          A-l by a factor of 0.65.  This was done to
          reflect current projections of fuel reprocessing
          requirements presented in Reference A-7.  .

     (c)   Reference A-l predicts that 4.6x10"* Ci of
          tritium will be discharged with aqueous wastes
          in 1980.  As a result of proposed release
          specifications, it appears that the NFS water
          discharge system may require further modifi-
          cations to minimize the discharge of tritium.
          By 1980, alternatives include either recycle  A_3
          or volatilization and discharge via the stack.

   Note:   For additional bases and assumptions, see pages
          1.5, 1.6, and 7.2-7.5 of Reference A-l.
                           A-292
-------
A-293
-------
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                                 A-294
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      A-295
-------
                                 A-6,  A_
7c/Reprocessing High Level Liquid         (Continued)

     (a)   About 99.9% of the nonvolatile fission products are
          removed in a high-level aqueous waste stream from
          the initial solvent extraction process.  In general,
          the waste stream is an aqueous nitrate solution of
          metallic constituents (chemicals added during re-
          processing and fission products).   Production
          quantity was based on average fuel exposure of
          33,000 MWD/MT, 2660 MT of spent fuel, and waste
          concentrated to 100 gal per  10,000 MWd(t).A~6/ A~7

     (b)   Assumed 2,145 MT of U-enriched fuel and 113 MT of
          Pu enriched fuel.A-7  For fission product distri-
          bution, however, calculated  on the basis that all
          fuel associated with U-enriched Diablo Canyon
          nuclear reactor, burnup of 3^,000 MWD/MT at 30
          MW/MT, 150 day decay time.A-   The transuranic
          constituents used the following values for Ci/MT
          after 150 day decay.  Assumed 0.5% of Pu in waste.

                               U-enriched    Pu-enriched
                               (Ci/MT)A"6    (Ci/MT)A-3


              Pu-238               2,810          8,950
              Pu-239                 330            573
              Pu-240                 478            778
              Pu-241             115,000        358,000
              Am-241                 200            750
              Am-243                 17             28
              Cm-242              15,000        165,000
              Cm-244               2,490         67,500
                           A-29 6
-------
                        APPENDIX E


WASTE  STREAM DATA SHEETS FOR WASTES  WHICH  QUALIFY  AS

     HAZARDOUS UNDER THE PURE COMPOUND APPROACH
    (0


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                          A-297
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-------
                     APPENDIX F

WASTE STREAM DATA SHEETS  FOR WASTES WHICH DO NOT QUALIFV
AS HAZARDOUS UNDER EITHER THE PURE COMPOUND APPROACH OR
         THE WASTE STREAM DECISION MODEL
                        A-309
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A-359
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                          APPENDIX G
             ESTIMATED VOLUME AND COMPOSITION DATA
               OF 17 CATEGORIES OF WASTE STREAMS
          PROCESSED BY THE MEDIUM SIZED MODEL FACILITY
Wastes received at the model processing facility are segregated
into 17 categories for treatment.  Each of these categories
represents either one specific waste or a blend of several
wastes having similar characteristics.  The volume and compo-
sition of the wastes in each of the categories are given in
Tables A-2 through A-19.  These data are based on the estimated
compositions and volumes of hazardous wastes being generally
received by currently established waste disposal firms.A~16
As such, the compositions and volumes are not intended to rep-
resent true averages of what might be processed with strict
enforcement of new pollution control regulations.  Currently
available information on the compositions and quantities of
potentially hazardous wastes discharged in the United States
is inadequate for accurate definition of the average waste
composition and volume data for a typical processing facility.
                              A-361
-------
                       TABLE A-2

        A-l CONCENTRATED SULFURIC ACID SOLUTIONS

Estimated Volume:  2,000 gallops per day
Concentration:  70% H-SO. average;  Range 30-98%

                                 Average
                              Concentration
      Other Constituents      	(%)	
      Hydrofluoric acid            0.5
      Hydrochloric acid            0.5
      Nitric acid                  0.5
      Heavy metals                 1.0
      Soluble organics             1.0
                       TABLE A-3

              A-2 CONCENTRATED MIXED ACIDS

Estimated Volume:  2,000 gallons per day
Estimated composition as follows:

                                 Average
                              Concentration      Range
         Constituents         	(%)	(%)
      Hydrochloric acid           10.0            5-20
      Nitric acid                  1.0            0-2
      Sulfuric acid               10.0            5-20
      Phosphoric acid              2.0            0-10
      Hydrofluoric acid            1.0            0-5
      Heavy metals                 0.5            0.1-2
      Soluble organics             0.5            0-1
-------
                        TABLE  A-4
      A-3 DILUTE ACID SOLUTIONS CONTAINING CHROMIUM
                  AND/OR OTHER OXIDANTS
Estimated Volume:  28,000  gallons  per  day

Estimated composition as follows:
                               Average
                            Concentration      Range
         Constituent
Cr+6
As+5
Mn+
H2S04
H Cl
HF
Aluminum (+3)
Nickel (+2)
Lead (+2)
Zinc (+2)
Copper (+2)
iron ( + 3)
Cadmium (+2)
Soluble organics
4.0
1.0
0.5
10.0
2.0
1.0
3.0
0.5
0.5
0.5
1.0
1.0
0.1
0.5
0.1-15
0-3
0-7
5-20
0-5
0-10
0-15
0-1
0-1
0-10
0-10
0.1-5
0-0.2
0-1
                         A-363
-------
                        TABLE A-5
    A-4 DILUTE ACID SOLUTIONS CONTAINING HEAVY METALS
                 (NO CHROMIUM NOR AMMONIA)
Estimated Volume:  15,000  gallons  per day
Estimated composition as follows:
                               Average
                            Concentration       Range
         Constituent              (%)             (%)
      Nickel  (+2)                 3.0             0-6
      Manganese  (+4)              0.5             0-1
      Copper  (+2)                 3.0'            0-15
      Arsenic  (+3)                1.0             0-2
      Antimony  ( + 3)               1.0             0-2
      Lead  (+2)                   1.0             0-2
      Mercury  (+2)                0.1             0-2
      Cadmium  (+2)                1.0             0-4
      Aluminum  (+3)               3.0             0-5
      Zinc  (+2)                   4.0             0-10
      Iron  (+2,4-3)               10.0             1-20
      Tin  (4-2)                    0.1             0-0.2
      Selenium  (4-4)               0.1             0-0.2
      Hydrochloric  acid           5.0             0-20
      Sulfuric acid              5.0             0-30
      Nitric acid                 1.0             0-2
      Phosphoric acid             1.0             0-20
      Soluble organics            0.5             0-1
                           A-364
-------
                        TABLE A-6
    A-5 DILUTE ACID SOLUTIONS CONTAINING HEAVY METALS
                   AND AMMONIUM SALTS
Estimated Volume:  10,000  gallons per day
    Average blended composition is expected to be similar
to A- 3 except for the following:
                               Average
                            Concentration      Range
         Constituent             (%)             (%)

      NH3                        5.0            2-10

      Cr                         0.1           traces-1

      Persulfate                 0.5            0-5
                       TABLE A-7
  A-6 ACIDIC NITRATE SOLUTIONS CONTAINING HEAVY METALS


Estimated Volume:  6,000 gallons per day

The average blended composition is expected to be similar to
that of A-4 except for the following:
                               Average
                            Concentration      Range
         Constituent        	(%)	        (%)

      Nitric acid               15             10-20
                          A-365
-------
                        TABLE  A-8
        A-7 ACID WASTES WITH HIGH CONCENTRATIONS
            OF HAZARDOUS METALS  (EXCEPT Cr+6)
Estimated Volume:  4,000  gallons per da>

Estimated Composition is similar to A-4 except  for the
following:
                               Average
                            Concentration      Range
         Constituent              (%)             (%)
      Arsenic (+3)               5               2-8

      Antimony (+3)              5               2-8

      Cadmium (+2)               5               2-8
                           A-366
-------
                       TABLE A-9






       B-l ALKALINE SOLUTIONS CONTAINING CYANIDES






Estimated Volume:  25,000 gallons per day




Estimated composition is as follows:
                               Average

                            Concentration      Range

         Constituent              (%)             (%)
      NaOH




      Na,C07
        £*  J



      CN~




      Ferro/Ferricyanide




      Chromium  (+3)




      Cadmium (+2)




      Zinc (+2)




      Copper (+2)




      Nickel (+2)




      Arsenic ( + 3)




      Iron (+2,+3)
10.0
3.0
5.0
1.0
0.1
1.0
2.0
2.0
0.5
0.1
2.0
5-20
1-5
0.1-10
0-10
0-0.2
0-2
0-3
0-5
0-2
0-0.2
0-5
                         A-367
-------
                       TABLE A-10


        B-2 ALKALINE SOLUTIONS CONTAINING SULFIDE


Estimated Volume:  12,000 gallons per day

Estimated composition is as follows:
                               Average
                            Concentration      Range
         Constituent              (%)             (%)
      NaOH                      10.0            5-12

      Na2C03                     3.0            1-8

      Na2S                       5.0            2-7

      Soluble organic            0.2            0.1-0.5
                       TABLE A-11



     B-3 CONCENTRATED ALKALIES (NO SULFIDE NOR CYANIDE)


 Estimated Volume:   2,000 gallons per day

 Estimated composition  is as follows:
                                 Average
                              Concentration     Range
          Constituent             (%)             (%)
      NaOH
       KOH

       Ca(OH)2

       Soluble  organics
20.0
5.0
5.0
2.0
0.5
15-50
1-10
0-20
0-15
0-2
                          ^-368
-------
                       TABLE A-12


          B-4 MISCELLANEOUS—ALKALINE SOLUTIONS
                 CONTAINING METALS, ETC.


Estimated Volume:  10,000 gallons per day

Estimated composition as follows:


                               Average
                            Concentration      Range
         Constituent        	(Jj	        (%)

      NaOH                       8.0             5-10

      Na2C03                     2.0             1-3

      Arsenic (+3)               2.0             0-3

      Selenium  (+4)              2.0             0-1

      Aluminum  (+3)              4.0             0-6

      Silicate                   2.0             0-5

      Soluble organics           3.0             0-5
                       TABLE A-13
              B-5 ALKALINE WASTES WITH HIGH
        CONCENTRATIONS OF HAZARDOUS HEAVY METALS
Estimated Volume:  2,000 gallons  per  day

Estimated composition is similar  to B-4 except  for  the
following:
                               Average
                            Concentration      Range
         Constituent        	(%)	        (%)

      Arsenic  (+3)                4               3-5

      Selenium  (+4)               2               1-3


                           A-369
-------
                       TABLE A-14
        C-l COMBUSTIBLE ORGANIC SLUDGES, SOLIDS,
                       AND LIQUIDS
Estimated Volume:  8,000 gallons per day or
                   64,000 pounds per day

Typical constituents:

Pesticides and similar materials - organic and organo-metallic

Monomers and polymers

Phenolics

Aliphatic hydrocarbons

Aromatic hydrocarbons

Oils

Still bottoms, tars

Halogenated aromatics

Alcohols, Amines

Organic acids and acid salts

N i trocompounds


Estimated breakdown:  80% pumpable
                      20% non-pumpable
                         A-370
-------
                       TABLE A-15
    C-2 CYANIDE CONTAINING SLUDGES, SLURRIES, SOLIDS


Estimated Volume:  1,000 pounds per day average;  it is expected
that there will be occasional bulk shipments of 1,000-4,000
gallons.  Liquid slurries and wastes containing less than
5% cyanide will go to the chemical oxidation system.  All
wastes with greater than 5% cyanide and all nonpumpable
solids and semi solids will go to the incinerator.  Probable
breakdown is anticipated to be 2/3 to the incinerator and 1/3
to chemical oxidation.
        Incinerator
Typical Average Composition

Ferro and Ferricyanides   5%  NaOH

NaCN/KCN
NaOH

Cyanate

Heavy metal hydroxides

Organic (insoluble)

Calcium hydroxide

Filter aids
       Chemical Oxidation System
      Typical^ Average Composition"
                                 10%

15%  Na2C03                      10%

10%  NaCN/KCN as CN~              4%

10%  Ferrocyanide/Ferricyanide    4%

 5%  Nickel (+2)                  3%

10%  Cadmium (+2)                 2%

 5%  Copper (+2)                  5%

 5%  Zinc (+2)                     4%

     Cyanate                      3%

     Organic (insoluble)           5%
                         A-371
-------
                       TABLE A-16

    C-3 CHROMIUM-CONTAINING SLUDGES,  SLURRIES,  SOLIDS

Estimated Volume:  1,000 pounds per day

Estimated composition is as follows:
         Constituent
      Chromium (+6)
      Nickel (+2)
      Zinc (+2)
      Ferricyanide
      Cadmium  (+2)
      Copper (+2)
      Iron (+3)
      Organics (insoluble)
      Filter aids
      Alkali or acid
                               Average
                            Concentration
 7.0
 0.2
 0.2
 0.2 '
 0.2
 1.0
 2.0
 5.0
 5.0
10.0
1-15
Do not expect bulk shipments in this category, only drum
quantities.  Bulk quantities high in chromium will be sub-
jected to recovery processes at waste sources.
                           A-372
-------
                       TABLE A-17
       C-4 INORGANIC SLUDGES, SLURRIES, SOLIDS, AND
           FILTER CAKES,  (NO Cr+6 NOR CYANIDE)
Estimated Volume:  32,000 pounds per day

Estimated composition is as follows:
                               Average
                            Concentration      Range
         Constituent              (%)             (%)
      Filter Aids                5              0-10

      Carbon                     2              0-5

      Insoluble organics         4              0-7
Heavy metals contained as hydroxides, oxides, sulfides,
fluorides, phosphates, chlorides, sulfates and carbonates.
Heavy metals include varying concentrations of arsenic,
mercury, cadmium, selenium and antimony at lower levels than
found in the C-6 category.
                       TABLE A-18
            C-5 AQUEOUS ORGANIC WASTE STREAMS


Estimated Volume:  10,000 gallons per day

Estimated composition:  These streams are made up largely of
the water-soluble organics such as low molecular weight
alcohols, amines, organic acids and their salts, aldehydes,
and ketones.  Other constituents will be phenolics, monomers,
pesticides, and emulsified oils.  Insoluble organics can also
be expected.  Average water content is estimated to be 90%.

All C-5 type wastes will go to incinerator with supplementary
fuel.
                          A-373
-------
                        TABLE A-19
         C-6 INORGANIC SLUDGES, SLURRIES, SOLIDS
      AND FILTER CAKES WITH HIGH CONCENTRATIONS OF
       HAZARDOUS HEAVY METALS  (NO Cr+6 OR CYANIDE)
Estimated Volume:  16,000 pounds per day

Estimated composition is as follows:
                               Average
                            Concentration       Range
         Constituent              (%)             (%)
AS04
AS2S3
sb+5
Pb+2
Hg+2
Carbon
Filter aids
H3P04
KMn04
CU++
Fe + 3
Zn+2
NaOH
Insoluble organic
4.0
6.0
0.1
0.1
0.1
2.0
5.0
5.0
8.0
3.0
2.0
1.0
5.0
4.0
0-10
0-20
0-1
0-1
0-0.2
0-5
0-10
0-20
0-15
0-5
0-7
0-3
0-15
0-7
                           A-374
-------
                         APPENDIX H
         PRELIMINARY PLANT DESIGN AND COST ESTIMATE
           FOR RECOVERY OF COPPER AND NICKEL FROM
                METAL FINISHING WASTE SLUDGE
DERIVATION OF COMPOSITION OF A TYPICAL
METAL FINISHING WASTE SLUDGE	

Typical concentrations of chromium, cyanide, copper,  zinc,
cadmium, iron, and nickel in combined effluents from  several
metal-finishing plants are as follows^"17:

                                     PPM

                      Cr             11.0
                      CN             28.0

                      Cu             17.2

                      Zn              3.7

                      Cd              1.4
                      Fe              2.4

                      Ni             24.0

The hexavalent chromium should be reduced to trivalent
chromium before precipitation.  The process suggested by
Lund-^~ 18 is as follows:

                 Wastes             Treatment

             Chromium wastes        0.35 pounds I^SO.
             at 2.0 pounds          , ,,,-      ,  _-,
             „ _    ^   ,,          1.95 pounds S00
             Cr03 per gallon             r        2
                                    10.3 pounds CaO

Iron wastes generally contain 10 percent H2SO4 at 0.4 pounds
iron per gallon.  Therefore when lime is used to precipitate
these heavy metals in the form of hydroxide, the quantities
of the precipitants would be  (on the basis of 1 x 10^ pounds
of wastewater):

          Cr(OH)3 = (13;M303) =21.4 pounds


          Cu(OH)2 = (17'(63%n-^ =26.4 pounds
                            A-375
-------
          Zn(OH)2  =     '6537     =   5'63  pounds
          cd(OH)2  .   (1.4M146.40)   .   ,.„  pounds
          Pe(OH,3  .     -;      =4.37  pounds
          Ni(0H)2  =         n      =   ".9  pounds

CaSO. produced  from the  treatment  of  Cr03=
CaSO. produced  from  the  treatment  of H2S04 in iron waste in

Ca(OH)2=


              d.65)(136)(16)(2.4)   = 17>9 pounds
                   ( 74 ) (6.5)

The results of the computation can  be  summarized as  shown in
Table A-20.

MATERIAL BALANCE

The composition of a typical metal  finishing  waste sludge is
shown in Table A-20.   The material  balances in the recovery
scheme are as follows:

                             4
           Feed rate  = 2  x 10  pounds dry solids per day

           Feed rate  in slurry (20% solid) =  1 x 10  pounds per day

           Leaching :

               H SO.  required (50% excess) =


               /(2.9) (3) (98)    (4.5) (98)    (1)  (98)
                   (2)  (52)        (63.54)       (65.37)
                (0.4)  (98)    (0.6)  (3) (98)    (6.3)  (98))
                  (112.4)       (2)  (55.85)       (58.71)  f
               (2 x 104\
               \  100  )
(1.5)   =  8,721  pounds per day
                              A-376
-------
               TABLE A-20

    COMPOSITION OF A TYPICAL METAL-
   FINISHING WASTE SLUDGE  (DRY BASIS)
Hydroxide
Element
Item
Cr (OH)
Cu(OH)2
Zn(OH)2
Cd(OH)2
Fe (OH)
Ni (OH)
CaS04
Total
Quantity
Pounds
21
26
5
1
4
37
284
382
.4
.4
.63
.82
.37
.90
.90
.42
Weight
Fraction
0
0
0
0
0
0
0
1
.056
.069
.015
.005
.011
.099
.745
.000
Item
Cr
Cu
Zn
Cd
Fe
Ni
Ca

Quantity
Pounds
11
17
3
1
2
24
83

.0
.2
.7
.4
.4
.0
.1

Weight
Percent
2
4
1
0
0
6
21

.9
.5
.0
.4
.6
.3
.8

                 A-377
-------
       Cost of tank (September 1972) =  (4,500)

          $5,719 (using Marshall & Stevens Cost Index)

                    Rotary Vacuum Filter

A filtration rate of 4 gallons per hour per square foot is as-
sumed for sizing the filter.  The fraction of the total filter
area submerged in the slurry is assumed to be 0.3.

                      (459)
       Filter area =  -Wr — — rz — ^y = 383 square feet

       Cost of rotary vacuum filter with 400 square feet total
       filter area (complete with a vacuum pump and auxili-
       aries) = $60,000

       Number of filters required = 3

                    Neutralization Tank •

The residence time of the solution is assumed to be 0.5 hours
for sizing the neutralization tank.

       Volume of filtrate from Filtration I = 9,589 +

          213 + 3,000 -  (62 4??o?1337)  = 10'137 gallons per
                                                 day

       Flow rate to Neutralization I =  10^37  = 422 gallons
                                                      per hour
       Volume of Neutralization Tank I = (0 . 5) (422) (1 . 2) =
          253 gallons (assuming 20% excess volume)

       Cost of tank (January 1967) = $3,000

       Cost of tank (September 1972) = (3,000) (^1'?) = $3,815
                    Precipitation Tank

The residence time of the solution is assumed as 0.5 hour for
sizing the precipitation tank.

       Flow rate = 425 gallons per hour

       Precipitation tank volume = (0 . 5) (425) (1. 2) =
          255 gallons (assuming 20% excess volume)

       Cost of Tank (September 1972)  =  $3,815A~19

                    Pumps and Motors

       Flow rate = 8 to 10 gallons per minute
                          A-378
-------
Cost of pump  (capacity, 10 gallons per minute; head,
    25 feet)  (January 1967) = $330A-2o
                                      334 1
Cost of pump  (September 1972 =  (330)  (||^L±) = $420

Cost of motor  (power, 1/4 HP) (January 1967) = $90A~2°
                                       334  1
:ost of motor  (September 1972) =  (90) (Ji±ii) = $105

Number of pumps required = 9

Number of motors required = 9

                Electrolysis

Cost of electrolysis system with  capacity of 46
    pound per day = $5,830A~21

Cost of electrolysis system with  capacity of 2,160
    pounds per day =  (5,830) (2'jJ°) 0.6 - $58,300
    (using 0.6 power scale-up factor)

                Raw Material

H~SO. required  (98% H_SO.) = ^|i = 8,899 pounds  per
 24                 I  4     u.yo
Cost of H2S04  (at $31.68 per ton)  =  (8,899)A~22

            =  $141 per day
CaO required = 5,554 pounds per  day
Cost of CaO  (at $19.00 per ton)  =  (5,554)

     <2^lnr)  = $53 per day
                Utilities
Wash water required = 3,900 gallons  per  day
Cost of wash water  (at $0.5 per 1,000 gallons) =  (3,900)

     (T76ro) = $2 per day
Power required for electrolysis  (at  1.5  kilowatt  hours
    per pound of Cu or Ni) =  (1.5) (900 + 1,260) =
    3,240 kilowatt hours per  dayA-23
Power required for pumping =  (•£-)  (0.746) (24) (9) =
    40 kilowatt hours per day
Number of agitators needed =  4

                      A-379
-------
Filtration I:

Total slurry to be filtered = 1 x 105 + 8,721 =
   108,721 pounds per day

Total solids in slurry =  (21 ' *\<}36.\  
-------
Electrolysis :

Cu produced =  (4.5)  (  =.  - )= 900 pounds per day
                      2  x 104
Ni produced  =  (6.3)  (  , „,. - )= 1,260 pounds per day

„ cn   ™H,,^rl  -  r(4-5^  <2)  (98)1  + r(6.3)  (2) (98),
 2  \ *  104     ~    (2)  <63-55>       [  (2)  (58.71)   ]
    ( , QQ - ) =  3,488 pounds per day


Precipitation :


CaO required for  neutralizing H2SO4 =  (35,59)  (56) =
   1,993  pounds per day


CaO required for  precipitating ^2(804)3 (50% excess) =
    (2.9)  (2  x 104)  (3)  (56)  (1.5)    ,  An,
   - (TO^l - \2] - T521 -- l,4Ub pounds  per day
CaO required  for  precipitating CdS04 (50% excess) =
    (0.4)  (2 x 104)  (56)  (1.5)    fin
   - -  - (112.41) - = 6° P°unds Per day
CaO required  for  precipitating ZnSO/ (50% excess) =
    (1)  (2  x 104)  (56)  (1.5)    oc_     ,       ,
   - - (TOO) - (65.38)   -  = 25? P°UndS per day

Total CaO  required  =  3,715 pounds per day

Total slurry  to be  filtered = 95,985 pounds per day

               -  (2.9) (2 x 1Q4)  (152) -  848 pounds per day
               -
Cd(OH)  produced - (0-4) (2 x 1Q4)  (146.41) = 104 pounds
Cd(OH)2 produced     (1QO)  (112-41)                ^ ^

                               4

Zn(OH)  produced -  U      X         ^^^" = 304  P°unds
      2                IQQ)  (65 .
                                                per day

CaS04 produced =  (35.59)  (136)  +


                         .  4,840
   5,353 pounds  per  day

Total solid in slurry =  6,609  pounds  per day

Water in filter  cake  (40%  solid)  =  (6/6?%L (60)  =
   9,914 pounds per day                 (40'

Amount of filtrate = 95,985  -  6,609  - 9,914  =
   79,462 pounds per day


                      A-381
-------
EQUIPMENT SIZING AND COST ESTIMATION

Equipment design for the conceptual process  evaluation  involved
the selection and sizing of the equipment  needed  in  the process.
Capital and operating costs were estimated as  follows.

                           Leaching Tank

The residence time of the slurry in the tank is assumed as 1
hour for sizing the leaching tank.

          Volume of water in feed = 80,000 pounds per day

            -(0?i337)(62.4) = 9'589 9allons P^ d^
                                               4
          Volume of solids in  sludge  =  {Q .1337) (100) (62 .4)

            .5.6    6.9    74.12   0.5   '^.37    3.79
            15.21   3.37    2.61   4.79    2.17    4.15

             -~-]  = 1,070 gallons per day
          Volumetric  feed  rate  =  9'5892^ 1'070  = 444 gallons
                                                       per hour
          Water produced in  leaching  = [ILiUi
             (4.5) (2) (18)     (1) (2) (18)    (0.4) (2) (18)
               (63.54           (65.37        (112.40)

             (0.6) (3) (18)    (6.3) (2) (18)  ,   ,2  X 1Q4N
              (2) (55. 85)       (58.71      J   l~T6"0   '   ~
            1,778 Ib/day =          (62.4)  =  213 ^aliens per day
          Volumetric  flow  rate  to  Filtration I  = [9,589 + 213

                            ____ _       (74.12) (2 x 10 4)
               (1.84) (62.4) (0.1337)    (100) (2 . 61 ) (62 . 4) (0 . 1337)

               \ -  (9>589  +  213  +  568  +  681)    11,051
                 --   - = —  -
             _
                                                             „*! /*r
                                                       = 460 gal/hr
           Leaching tank volume = (1) (460) (1.2) = 552 gallons
              (assuming 20% excess volume)

           Cost  of  tank (January 1967)  = $4,500
                              A-38 2
-------
       Power required for agitation at 10 HP  =  (10)
            (0.746)(24)  (4) = 716 kilowatt hours per day

       Total power required = 3,996 kilowatt hours per day

       Cost of power  (at $0.1 per kilowatt hour) =  (3,996)
            (0.01) = $40 per day

A summary of the equipment items and the estimated purchased
equipment cost is presented in Table A-21.  The estimated
fixed-capital cost is given in Table A-22.  The estimates of
the total manufacturing costs, including credits for recovered
metals for sale, are presented in Table A-23.
                            A-383
-------
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                                      A-384
-------
                            TABLE A-22

               FIXED-CAPITAL INVESTMENT ESTIMATE
                                                   Cost,
                  Items                       Dollars (1972)  2 °

Purchased equipment, E                             256,374

Purchased equipment installation, 39% E             99,986

Instrumentation (installed), 28% E                  71,785

Piping (installed), 31% E                           79,746

Electrical (installed), 10% E                       25,637

Buildings, 22% E                                    56,402

Yard Improvements, 10% E                            25,637

Service facilities (installed),  30% E               76,912

Land, 6% E                                          15,382

     Total direct plant cost, D                    707,861

Engineering and supervison, 32% E                   82,040

Construction expenses, 34% E                        87^ 167

     Total direct and indirect cost  (D+I)          877,068

Contractor's fee, 5%  (D+I)                          43,853

Contingency, 10%  (D+I)                              87,707

     Fixed capital investment                    1,008,628
                              A-385
-------
                          TABLE A-23

                DAILY OPERATING COST ESTIMATE*


                                          Daily Operating Cost,
               Items                         Dollars Per Day

Raw Material

   Sulfuric acid (98 percent at $31.68A~22
   per ton)                                        141

   Lime (at $19.00 per ton)A~22                     53

Utilities
                                              A— 2 3
   Electricity (at 12 mills per kilowatt.hour)      48

   Water (at $0.5 per 1000 gallons)                  2

Labor  (2 men per shift, 2 shifts per day at
   $7.62 per hour)                                 366

Supervision (20 percent of labor)                   73

Maintenance (5 percent of FCI per year)            233

Overhead (2.3 percent of FCC)                       89

Amortization (7 percent for 10 years)              552

Insurance and taxes(2.2 percent of FCI per year)    85

          Total daily operating cost              1,642

Credit

   Copper  (at $0.5 per pound) A~22                  450

   Nickel  (at $1.40 per pound) A~23                1,764

          Total Credit                            2,214


          Net Daily Profit                         572
*Easis:  300 days per year, 24 hour per day operation
                              A-386
-------
                         APPENDIX
       PRELIMINARY PLANT DESIGN AND COST ESTIMATE FOR
                 WASTE SOLVENT RECOVERY
PRELIMINARY PROCESS DESIGN

                        Storage Tanks

Storage tanks in the solvent recovery facility will be used
in three different situations:  storage of incoming wastes,
storage of condensed vapors from the Luwa evaporator, and
storage of the final products.  Listed in Table A-24 is the
capacity of each storage tank.  These storage facilities
should supply sufficient flexibility for any unusual con-
ditions .

                         Luwa Evaporator

The Luwa evaporator is an agitated wiped-film unit used to
separate the solvent from solids,  sludge, or nonvolatile mater-
ials (liquids or polymers).   The heat load is based on require-
ments for raising the solvents to the boiling point and vapor-
izing them.  This load based on 14,000 gallons per day, 300 days
per year and 24 hour per day operation amounts to 1.6 x 10^ BTU
per hour, assuming around 80 percent efficiency of heat utili-
zation.  Based on an overall heat transfer rate of 10,000 BTU per
hour per square foot, a Luwa evaporator with 106 square feet is
required.

                             Pumps

The solvent will be pumped from the waste storage tank to the
Luwa evaporator at the rate of 560 gallons per hour or 10 gal-
lons per minute by a centrifugal pump of 10 gallons per minute
and 60 feet head.  Pumps of the same size will also be used to
deliver feed to the distillation column and to move the products
from the distillation column to the storage tanks.


               Partial Condensers Cl, C2, and C3

The vapors from the Luwa evaporator will be condensed in three
different cuts and stored in tanks for further separations in
the distillation column.  The temperature of the coolant to
each condenser will be controlled to condense perchlorethylene
and o-dichlorobenzene in the first condenser; methyl chloro-
form, carbon tetrachloride, ethylene dichloride, and tri-
chlorethylene in the second condenser; and methyl chloride
and chloroform in the third condenser.
                             A-387
-------
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-------
The cooling loads in the three condensers and their sizes (based
on a heat-transfer rate of 1,000 BTU per hour per square foot) are

                     Cooling Load,              Heat-Transfer
 Unit                  Btu/hr                Surface Area, sq ft
  Cl                 0.131 x 10                   131

  C2                 0.833 x 106                  833

  C3                 0.153 x 106                  153


                      Distillation Column

The distillation column was sized on the basis of the unit used
by Chem-Trol Pollution Services, Inc. (Model City, New York).
The column will be a bubble-cap unit with 40 plates, each 3
feet in diameter.  There will be 18 inches between plates.

                           Reboiler

The reflux ratio is taken as 3 to 1 for sizing the reboiler.
The heat load on the reboiler is estimated as 1.47 x 10^ BTU
per hour.  Based on a heat transfer rate of 82,000 BTU per hour
per square foot, the total heat transfer surface area is esti-
mated as 18.3 square feet.  Allowing for heat losses, a reboiler
with a 40 square foot heat transfer area will be required.

                 Distillation Column Condenser

At a reflux ratio of 3 to 1 the cooling load of the condenser
is estimated to be 1.28 x 10^ BTU per hour.  At an assumed over-
all heat transfer rate of 1000 BTU per hour per square foot, the
heat transfer surface area required for the average load is es-
timated as 1,280 square feet.

                        Cooling Tower

The total cooling load on the process is estimated as 2.4 x 10
BTU per hour.  Based on a temperature rise of 10 °F for cooling
water through each of the condensers, the total cooling water
requirement is estimated as 240,000 pounds per hour or 480 gal-
lons per minute for sizing a cooling tower.

                      Cost Estimation

Preliminary cost estimation was made on the waste solvent recov-
ery process by the same process cost estimating method used in
Appendix H.  Specifications of equipment items and their estima-
ted purchase costs are given in Table A-25 .  Estimated fixed
capital investment cost is given in Table A-26 .  The total
                             A-389
-------
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                                                             A-  390
-------
                             TABLE A-26
                 ESTIMATE OF FIXED CAPITAL COST
            Component                                Cost, dollars

Purchased equipment (delivered), E                         $164,980
Purchased equipment installation, 39% E                      64,110
Instrumentation (installed), 28% E                           46,194
Piping (installed), 31% E                                    51,143
Electrical (installed) 10% E                                 16,498
Yard improvements, 10% E                                     16,498
Service facilities (installed), 55% E                        90,739
Land, 6% E                                                    9,898
          Total direct plant cost, D                       $460,060

Engineering and supervision, 32% E                           52,793
Construction expenses, 34% E                                 56,093
          Total direct and indirect cost, (D + I)           $568,946

Contractor's fee, 5% (D + I)                                  33,295
Contingency, 10% (D + I)                                      66,591
          Fixed capital cost                               $668,836
                               A-391
-------
processing cost, including the credit for the recovered sol-
vents,  is shown in Table A-27.  The recovery process shows a
net income of about $7,000 per day.  The process appears to be
a promising means of deriving a substantial income.
                              A-39 2
-------
                           TABLE  A-2 7

                 ESTIMATE  OF  OPERATING  COST



     Basis:  200 days per year, 24 hours per day operation

Fixed Capital Cost,  (FCC)                             $668,836

                                                    Daily Cost
          Component                               Dollars per Day


Utilities

   Electricity at 12 mills per kilowatt hour                5

   Steam at $0.85 per 106 BTU                              68

Labor

   $7.62 per hour, 2 men per shift                        366

Supervision

   20 percent of labor                                     73

Maintenance

   6 percent of FCC                                       154

Plant Overhead

   2.3 percent                                             59

Depreciation

   10 percent per year of FCC                             355

Taxes and Insurance

   5 percent per year of FCC                               57

          Total Daily Operating Cost                   $1,148

Credit for Solvents Recovered

   161,000 pounds per day  at $0.05 per  pound           $8,050 per da

Net Income                                             $6,902 per da
                             A-393
-------
A-394
-------
                           APPENDIX J


              PRELIMINARY CAPITAL AND OPERATING COSTS
           FOR MODEL PROCESSING AND DISPOSAL FACILITIES


Capital and operating costs were estimated for the various pro-
cessing modules of a medium size facility with a design capacity
of 122,000 gallons per day of aqueous waste and 74 tons per day
of combustible wastes.  Capital and operating costs were then
estimated, using scale-up factors, for a small facility (design
capacity of 25,000 gallons per day aqueous waste and 15 tons per
day of combustible waste) and a large facility (design capacity
of 1 million gallons per day and 607 tons per day of combustible
waste).  A scale-up factor of 0.6 was used consistently except
for the large evaporation module.  The 0.6 scale-up factor is
commonly used with good results in preliminary design work to
estimate the cost of larger or smaller equipment similar to that
for which cost data are available.  If the cost of a given sys-
tem at one capacity is known, the cost of a similar system with
x times the capacity of the first is approximately (x)^-6 times
the cost of the initial system.A-24 A scale-up factor of 0.9 was
used in estimating the cost of the large evaporation module since
multiple packaged evaporator systems were required.

The capital and operating costs for the processing modules or
module units are given in Tables A-28 through A-66.  The chemical
treatment module is broken down into four units:

     •   oxidation,

     •   reduction,

     •   neutralization-precipitation (primary), and

     •   sulfide precipitation  (secondary).

The liquid-solids separation is also broken down into four units:

     •   primary clarification and filtration,

     •   secondary clarification and filtration,

     •   incinerator scrubber water clarification and ash fil-
        tration, and

     •   brine filtration.

Subdivision of the chemical treatment and liquid-solids separa-
tion module allows detailed examination of the costs associated
                                A-395
-------
with the various steps in these modules.

Capital costs of the processing modules include the cost of
land, buildings, laboratory, auxiliary equipment, engineering
design, fees, and contingencies.  The cost of the administra-
tion/laboratory building, the process building, and land for
the medium size facility are given below:

                                             Cost
     Administration/laboratory building    $850,000
     Process building                       500,000
     Land (10 acres)                        100,000

The cost of the above items was subdivided amoung the various
processing modules according to anticipated usage or space
requirements.

The capital and operating costs of a secured landfill to pro-
cess and bury 157 tons per day of sludge containing hazardous
heavy metals are given in Table A-67.  A land area of 200
acres are used for burial activities.  The extra land is in-
cluded as a buffer zone to provide sufficient time for cor-
rective measures in the event ground water contamination is
detected in the vicinity of the burial trenches.  It is plan-
ned that the burial site will be used for a period of 30 years
Title of the land will be transferred to the State Govern-
ment as in the case of the Morehead radioactive waste burial
site in Kentucky.  The land will be leased by the disposal
company for a nominal fee and a charge of 4 percent levied on
the burial charge to cover administrative costs for perpetual
surveilance.  Significant cost items for the secured landfill
include an asphalting plant  ($703,000), a railroad spur
($491,000), land ($400,000), and trenching and backfilling
equipment ($191,000).  Miscellaneous items such as fencing,
roadways, and storage facilities account for the remaining
cost.

Operating costs based on fixed capital costs (FCC) are as
follows:                                          Percent
                                              of FCC per year

Capital amortization  (7 percent for 10 years)      14.24
Maintenance                                         6.0
Overhead                                            2.3
Insurance and taxes                                 2.2

The hourly rate for operating labor is $7.62 which includes
fringe benefits, assessments, and personnel supplies.
                          A-396
-------
Essential material costs used in estimating operating costs for
the treatment and disposal facilities are given below:

            Material                     Cost per ton, $

       Lime, unslaked                           18.00
       Sulfur dioxide                          220.00
       Caustic soda, 50 percent                 76.00
       Chlorine                                 75.00
       Sodium sulfide, flake                   145.00
       Hydrochloric acid, 35 percent            42.00
       Activated carbon                        700.00
       Asphalt                                  30.00

Anticipated personnel requirements for a medium size treatment
facility are given in Table A-68.
                               A-397
-------
                      TABLE A-28


  PRELIMINARY  COST  ESTIMATE  FOR  MEDIUM  SIZE  FACILITY

   WASTE RECEIVING, SEGREGATION, AND STORAGE MODULE


                                                  Dollars

FIXED CAPITAL COST                              $3,270,000


OPERATING COST, DAILY

     Labor                                           2,500

     Supervision                                       462

     Maintenance                                       755

     Utilities                                         138

     Laboratory Services                               213

     Overhead                                          289

     Taxes and Insurance                        	276

                                                     4,633

     Capital Amortization                       	1,791

     Total Operating Cost                       $     6,424


AVERAGE COST PER TON  (623 Tons per  Day)         $        10.30

AVERAGE COST PER 1000 GALLONS OF
     AQUEOUS-INORGANIC WASTE                    $        46.40
      (Basis: 9 pounds per gallon)
                          A-398
-------
                      TABLE A-29
   PRELIMINARY  COST  ESTIMATE  FOR MEDIUM SIZE  FACILITY
               AMMONIA STRIPPING MODULE
FIXED CAPITAL COST


OPERATING COST, DAILY

     Labor

     Supervision

     Maintenance

     Utilities

     Laboratory Services

     Overhead

     Taxes and Insurance



     Capital Amortization

     Total Operating Cost


COST PER 1000 GALLONS AMMONIA
     WASTE (10,000 gpd)

AVERAGE COST PER GALLON  (122,000 gpd)
                                                   Dollars
$773,800
$

$
      91

      23

     178

      50

      53

      68

      65
     528

     424
952



 95.20

  7.80
                          A-39 9
-------
                      TABLE A-30
  PRELIMINARY COST ESTIMATE FOR MEDIUM SIZE FACILITY
              CHEMICAL TREATMENT MODULE
         Chemical Oxidation of Cyanide Wastes
FIXED CAPITAL COST
OPERATING COST, DAILY
     Chlorine
     Labor
     Supervision
     Maintenance
     Utilities
     Laboratory Services
     Overhead
     Taxes and Insurance

     Capital Amortization

     Total Daily Operating Cost
 Dollars
$399,000


     877
     251
      34
      92
      50
      40
     109
 	3£
   1,487
     219
$  I,7u6
COST PER 1000 GALLONS CYANIDE WASTE  (25,000  gpd)  $      63.20

AVERAGE COST PER 1000 GALLONS  (122,000 gpd)       $      14.00
                           A-400
-------
                      TABLE A-31
  PRELIMINARY COST ESTIMATE FOR MEDIUM SIZE FACILITY
              CHEMICAL TREATMENT MODULE
       Chemical Reduction  of  Chromium-6 Wastes
FIXED CAPITAL COST

OPERATING COST, DAILY

     Sulfur Dioxide

     Labor

     Supervision

     Maintenance

     Utilities

     Laboratory Services

     Overhead

     Taxes and Insurance



     Capital Amortization

     Total Operating Cost
 Dollars

$337,000



     561

     129

      34

      78

      50

      40

      30

 	2_9

   1,030

     185

$  1,215
COST PER THOUSAND GALLONS OF
     CR+  WASTE  (42,000 gpd)                      $      28.90

AVERAGE COST PER THOUSAND GALLONS  (122,000  gpd)   $      10,00
                         A-401
-------
                      TABLE A-32
  PRELIMINARY COST ESTIMATE FOR MEDIUM SIZE FACILITY
              CHEMICAL TREATMENT MODULE
             Neutralization-Precipitation
FIXED CAPITAL COST




OPERATING COST, DAILY




     Lime




     Flocculant




     Hydrochloric Acid




     Labor




     Supervision




     Maintenance




     Utilities




     Laboratory Services




     Overhead




     Taxes and Insurance
     Capital Amortization




     Total Daily Operating Cost







COST PER THOUSAND GALLONS (122,000 gpd)





                          A-402
   Dollars




$3,592,000










     1,400




       500




        54




       391





       104





       829




        50




        40




       420




 	304





     4,092





     1,967
     6,059
        49.70
-------
                      TABLE A-33
  PRELIMINARY COST ESTIMATE FOR MEDIUM SIZE FACILITY
              CHEMICAL TREATMENT MODULE
            Metallic Sulfide Precipitation
FIXED CAPITAL COST







OPERATING COST, DAILY




     Sodium Sulfide




     Flocculant




     Labor




     Supervision




     Maintenance




     Utilities




     Laboratory Services




     Overhead




     Taxes and Insurance









     Capital Amortization




     Total Daily Operating Cost







COST PER 1000 GALLONS (212,000 gpd)








                           A-403
                                                  Dollars
$406,000
   1,450




     250




     117




      34




      94




      50




      40




      36




 	3£




   2,105




     222




$  2,327







$     11.00
-------
                      TABLE A-34
  PRELIMINARY COST ESTIMATE FOR MEDIUM SIZE FACILITY
            LIQUID-SOLIDS SEPARATION MODULE
          Primary Clarification & Filtration
FIXED CAPITAL COST







OPERATING COSTS, DAILY




     Labor




     Supervision




     Maintenance




     Utilities




     Laboratory Services




     Overhead




     Taxes and Insurance









     Capital Amortization




     Total Capital Cost







COST PER 1,000 GALLONS  (122,000 gpd)
                                                  Dollars
$3,216,700
        73




        23




       742




        50




        36




       284




       272
     1,480




     1,762
     3,242
        26.60
                         A-404
-------
                      TABLE A-35







  PRELIMINARY COST ESTIMATE FOR MEDIUM SIZE FACILITY




           LIQUID-SOLIDS SEPARATION MODULE







         Secondary Clarification & Filtration







                                                  Dollars




FIXED CAPITAL COST                             $2,284,200







OPERATING COSTS, DAILY




     Labor                                              79




     Supervision                                        23




     Maintenance                                      527




     Utilities                                          50




     Laboratory Services                                36




     Overhead                                         202




     Taxes and Insurance                              193




                                                    1,110




     Capital Amortization                       	1,251




     Total Daily Operating Cost                $    2,361







COST PER 1,000 GALLONS  (212,000 gpd)           $        11.10
                          A-405
-------
                      TABLE A-36








  PRELIMINARY COST ESTIMATE FOR MEDIUM SIZE FACILITY




            LIQUID-SOLIDS SEPARATION MODULE







         Incinerator Scrubber Water Clarifier







                                                  Dollars




FIXED CAPITAL COST                             $3,231,800




OPERATING COSTS, DAILY




     Flocculant                                       250




     Labor                                             79




     Supervision                                       23




     Maintenance                                      746




     Utilities                                         50




     Laboratory Service                                36




     Overhead                                         286




     Taxes and Insurance                        	273




                                                    1,743




     Capital Amortization                       	1,770




     Total Daily Operating Cost                $    3,513







COST PER 1,000 GALLONS (90,000 gpd)            $       39.00
                          A-406
-------
                     TABLE A-37








  PRELIMINARY COST ESTIMATE FOR MEDIUM SIZE FACILITY




           LIQUID-SOLIDS SEPARATION MODULE







                   Brine Filtration
FIXED CAPITAL COST




OPERATING COSTS, DAILY




     Chlorine




     Labor




     Supervision




     Maintenance




     Utilities




     Laboratory Service




     Overhead




     Taxes and Insurance









     Capital Amortization




     Total Daily Operating Cost







COST PER 1,000 GALLONS (212,000 gpd)
 Dollars




$231,000









      46




      31




      10




      53




      50




      45




      20




 	19




     274




     126
$







$
400
  1.89
                           A-407
-------
                      TABLE A-38








  PRELIMINARY COST ESTIMATE FOR MEDIUM SIZE FACILITY




                CARBON SORPTION MODULE
FIXED CAPITAL COST







OPERATING COSTS, DAILY




     Labor




     Supervision




     Make-up Carbon




     Maintenance




     Utilities




     Laboratory Services




     Overhead




     Taxes and Insurance









     Capital Amortization




     Total Daily Operating Cost







COST PER 1000 GALLONS (212,000 gpd)
                                                  Dollars
$941,000
     213




      23




     286




     217




      54




     107




      83




      80
   1,063




     515




$  1,578







$      7.44
                          A-408
-------
                      TABLE A-39







  PRELIMINARY COST ESTIMATE FOR MEDIUM SIZE FACILITY




       SUBMERGED COMBUSTION EVAPORATION MODULE







                                                  Dollars




FIXED CAPITAL COST                                $514,000







OPERATING COSTS, DAILY




     Labor                                              91




     Supervision                                        23




     Maintenance                                       119




     Utilities                                         103




     Fuel                                            1,425




     Laboratory Services                                40




     Overhead                                           46




     Taxes and Insurance                                44




                                                     1,891




     Capital Amortization                              282




     Total Operating Cost, Daily                  $   2,173







COST PER 1,000 GALLONS (212,000 gpd)              $      10.20
                           A-409
-------
                     TABLE A-40








  PRELIMINARY COST ESTIMATE FOR MEDIUM SIZE FACILITY




                  INCINERATOR SYSTEM
FIXED CAPITAL COST







OPERATING COSTS, DAILY




     Labor




     Supervision




     Maintenance




     Power




     Fuel




     Laboratory Services




     Overhead




     Taxes and Insurance









     Capital Amortization




     Total Daily Operating Cost







COST PER TON (74 Tons)
                                                  Dollars
$4,873,000
       706




       246




     1,124




       277




       923




       213




       431




       412
     4,332




     2,669
     7,001
        94.60
                           A-410
-------
                     TABLE A-41



   PRELIMINARY  COST ESTIMATE FOR  SMALL  SIZE  FACILITY

   WASTE RECEIVING, SEGREGATION,  AND  STORAGE MODULE


                                                   Dollars

FIXED CAPITAL COST                              $1,262,000



OPERATING COSTS, DAILY

     Labor                                             513

     Supervision                                        95

     Maintenance                                       291

     Utilities                                          28

     Laboratory Services                                44

     Overhead                                          112

     Taxes and  Insurance                               107

                                                     1,190

     Capital Amortization                        	691

     Total Operating Cost, Daily                $    1,881


AVERAGE COST PER TON (128  tons  per day)         $       14.70

AVERAGE COST PER 1,000 GALLONS OF
     AQUEOUS-INORGANIC WASTE                    $       66.20
     (Basis:  9  pounds per  gallon)
                          A-411
-------
                              TABLE  A-42








            PRELIMINARY  COST  ESTIMATE  FOR SMALL  SIZE FACILITY




                        AMMONIA STRIPPING MODULE
        FIXED CAPITAL COST







        OPERATING COSTS, DAILY




             Labor




             Supervision




             Maintenance




             Utilities




             Laboratory Services




             Overhead




             Taxes and Insurance









             Capital Amortization




             Total Daily Operating Cost







AVERAGE COST PER 1,000 GALLONS  (2,050  gpd)




AVERAGE COST PER 1,000 GALLONS  (25,000 gpd)
                                                           Dollars
$298,700
$




$
      91




      23




      69




      10




      53




      26




      25
     297




     164
461







225.00





 18.40
                                  A-412
-------
                      TABLE A-43
   PRELIMINARY COST  ESTIMATE  FOR SMALL SIZE  FACILITY




               CHEMICAL TREATMENT MODULE







         Chemical Oxidation  of  Cyanide Waste
FIXED CAPITAL COST







OPERATING COST, DAILY




     Chlorine




     Labor




     Supervision




     Maintenance




     Utilities




     Laboratory Services




     Overhead




     Taxes and Insurance









     Capital Amortization




     Total Daily Operating Cost







AVERAGE COST PER 1,000 GALLONS  (5,125  gpd)




AVERAGE COST PER 1,000 GALLONS  (25,000 gpd)
                                                   Dollars
$154,000
$




$
     180




     251




      34




      36




      10




      40




      14




      13
     558




      84
642







125.00




 25.70
                           A-413
-------
                     TABLE A-44








   PRELIMINARY COST ESTIMATE FOR SMALL SIZE FACILITY




              CHEMICAL TREATMENT MODULE







       Chemical Reduction of Chromium-6 Wastes
FIXED CAPITAL COST







OPERATING COST, DAILY




     Sulfur Dioxide




     Labor




     Supervision




     Maintenance




     Utilities




     Laboratory Services




     Overhead




     Taxes and Insurance
     Capital Amortization




     Total Daily Operating Cost







AVERAGE COST PER 1000 GALLONS  (8,610 gpd)




AVERAGE COST PER 1000 GALLONS  (25,000 gpd)
                                                  Dollars
$130,100
$




$
     115




     129




      34




      30




      10




      40




      12




      11
     381




      71
452







 52.50





 18.10
                           A-414
-------
                      TABLE A-45
   PRELIMINARY COST ESTIMATE FOR SMALL SIZE FACILITY




              CHEMICAL TREATMENT MODULE







             Neutralization-Precipitation
FIXED CAPITAL COST







OPERATING COSTS, DAILY




     Lime




     Flocculant




     Hydrochloric Acid




     Labor




     Supervision




     Maintenance




     Utilities




     Laboratory Services




     Overhead




     Taxes and Insurance
     Capital Amortization




     Total Daily Operating Cost







AVERAGE COST PER 1000 GALLONS  (25,000 gpd)





                           A-415
                                                   Dollars
$1,386,500
       287




       103




        11




       391




       104




       320




        10




        40




       123




       117
     1,506




       759
     2,265
        90.60
-------
                        TABLE A-46
   PRELIMINARY COST ESTIMATE FOR SMALL SIZE FACILITY



                CHEMICAL TREATMENT MODULE






             Metallic Sulfide Precipitation
FIXED CAPITAL COST






OPERATING COSTS, DAILY




     Sodium Sulfide




     Flocculant




     Labor




     Supervision




     Maintenance




     Utilities




     Laboratory Service




     Overhead




     Taxes and Insurance








     Capital Amortization




     Total Daily Operating Cost






COST PER 1,000 GALLONS  (43,400 gpd)
                                                  Dollars
$156,700
     297



      51



     117



      34



      36




      10



      40



      14



      13
     612




      86
     698
      16.10
                          A-416
-------
                        TABLE A-47

    PRELIMINARY  COST ESTIMATE  FOR  SMALL  SIZE  FACILITY
             SOLIDS-LIQUID SEPARATION MODULE

          Primary Clarification and Filtration

                                                   Dollars
FIXED CAPITAL COST                              $1,241,600

OPERATING COSTS, DAILY
     Labor                                              73
     Supervision                                        23
     Maintenance                                       287
     Utilities                                          10
     Laboratory Services                                36
     Overhead                                          110
     Taxes and  Insurance                        	105
                                                       644
     Capital Amortization                       	680
     Total Daily Operating Cost                 $    1,324

COST PER 1,000 GALLONS  (25,000 gpd)             $        53.00
                           A-417
-------
                        TABLE A-48






   PRELIMINARY COST ESTIMATE FOR SMALL SIZE FACILITY



             LIQUID-SOLID SEPARATION MODULE






         Secondary Clarification and Filtration




                                                  Dollars




FIXED CAPITAL COST                               $881,700






OPERATING COSTS, DAILY




     Labor                                             79




     Supervision                      '                 23




     Maintenance                                      203




     Utilities                                         10




     Laboratory Services                               36




     Overhead                                          78




     Taxes and Insurance                         	7_5_




                                                      504



     Capital Amortization                        	483




     Total Daily Operating Cost                  $    987






COST PER 1,000 GALLONS  (43,400 gpd)              $     22.70
                          A-418
-------
                       TABLE A-49






    PRELIMINARY COST ESTIMATE FOR SMALL SIZE FACILITY




             LIQUID-SOLIDS  SEPARATION MODULE






          Incinerator Scrubber Water Clarifier




                                                   Dollars




FIXED CAPITAL COST                              $1,247,500






OPERATING COSTS, DAILY




     Flocculant                                         51




     Labor                                              79




     Supervision                                        23




     Maintenance                                       288




     Utilities                                          10




     Laboratory Services                                36




     Overhead                                          110




     Taxes and Insurance                               106




                                                       703



     Capital Amortization                              683




     Total Daily Operating  Cost                 $    1,386






COST PER 1,000 GALLONS (18,450 gpd)             $        75.10
                          A- 419
-------
                        TABLE A-50






   PRELIMINARY COST ESTIMATE FOR SMALL SIZE FACILITY



             LIQUID-SOLIDS SEPARATION MODULE






                    Brine Filtration




                                                   Dollars



FIXED CAPITAL COST                                 $89,200






OPERATING COSTS, DAILY




     Chlorine                                            9




     Labor                                              31




     Supervision                                        10




     Maintenance                                        21




     Utilities                                          10




     Laboratory Services                                45




     Overhead                                            8




     Taxes and Insurance                           	8




                                                       142



     Capital Amortization                          	4_9_




     Total Daily Operating Cost                    $    191






COST PER 1,000 GALLONS  (43,500  gpd)                $      4.39
                          A-4 20
-------
                        TABLE A-51







   PRELIMINARY COST ESTIMATE FOR SMALL SIZE FACILITY



                 CARBON SORPTION MODULE






                                                  Dollars




FIXED CAPITAL COST                                $363,000






OPERATING COSTS, DAILY




     Labor                                             213




     Supervision                                       23




     Make-up Carbon                                    59




     Utilities                                         11




     Maintenance                                       83




     Laboratory Services                               107




     Overhead                                          32




     Taxes and Insurance                          	31




                                                       559



     Capital Amortization                         	199




     Total Daily Operating Cost                   $     758






COST PER 1,000 GALLONS  (43,400 gpd)               $     17.50
                          A-421
-------
                       TABLE A-52






   PRELIMINARY COST ESTIMATE FOR SMALL SIZE FACILITY




         SUBMERGED COMBUSTION EVAPORATION MODULE






                                                  Dollars




FIXED CAPITAL COST                               $198,000






OPERATING COSTS, DAILY




     Labor                                             91




     Supervision                                       23




     Maintenance                                       46




     Utilities                                         21




     Fuel                                             292




     Laboratory Services                               40




     Overhead                                          18




     Taxes and Insurance                         	17_




                                                      527




     Capital Amortization                        	108



     Total Daily Operating Cost                  $    635






COST PER 1,000 GALLONS (43,400 gpd)              $     14.63
                          A-422
-------
                        TABLE A-53






   PRELIMINARY COST ESTIMATE FOR SMALL SIZE FACILITY




                   INCINERATOR SYSTEM
FIXED CAPITAL COST






OPERATING COSTS, DAILY



     Labor



     Supervision



     Maintenance



     Power



     Fuel



     Laboratory Services



     Overhead




     Taxes and Insurance








     Capital Amortization



     Total Daily Operating Cost





COST PER TON (15 tons)
                                                  Dollars
$1,881,000
       706



       246



       434



        57



       189



       213



       166



       159
     2,170




     1,030
     3,200
       213.00
                          A-423
-------
                        TABLE A-54


   PRELIMINARY COST ESTIMATE FOR LARGE SIZE FACILITY

     WASTE RECEIVING, SEGREGATION AND STORAGE MODULE


                                                   Dollars

FIXED CAPITAL COST                            $11,543,000


OPERATING COSTS, DAILY

     Labor                                          20,500

     Supervision                                    3,788

     Maintenance                     '               2,664

     Utilities                                      1,131

     Laboratory Services                            1,747

     Overhead                                       1,021

     Taxes and Insurance                      	977

                                                    31,828

     Capital Amortization                     	6 ,322

     Total Daily Operating Cost               $     38,150


AVERAGE COST PER TON  (5,110 tons per day)     $          7.47

AVERAGE COST PER 1,000  GALLONS OF
     AQUEOUS-INORGANIC  WASTE                  $         33.60
     (Basis:  9 pounds per gallon)
                          A-424
-------
                        TABLE A-55






    PRELIMINARY COST ESTIMATE FOR LARGE SIZE FACILITY




                AMMONIA STRIPPING MODULE






                                                  Dollars




FIXED CAPITAL COST                              $2,731,500






OPERATING COSTS, DAILY




     Labor                                              91




     Supervision                                        23




     Maintenance                                       630




     Utilities                                         410




     Laboratory Services                                53




     Overhead                                          242




     Taxes and Insurance                        	231




                                                     1,680




     Capital Amortization                       	1,495




     Total Daily Operating Cost                 $     3,175






AVERAGE COST PER 1,000 GALLONS  (82,000 mgd)     $        38.70




AVERAGE COST PER 1,000 GALLONS  (1 mgd)          $         3.18
                         A-425
-------
                        TABLE A-56






   PRELIMINARY COST ESTIMATE FOR LARGE SIZE FACILITY



                CHEMICAL TREATMENT MODULE






           Chemical Oxidation of Cyanide Waste






                                                  Dollars




FIXED CAPITAL COST                             $1,408,000






OPERATING COSTS, DAILY




     Chlorine                                       7,191




     Labor                                            251




     Supervision                                        34




     Maintenance                                      325




     Utilities                                        410




     Laboratory Service                                 40




     Overhead                                         125




     Taxes and Insurance                       	119_




                                                    8,535




     Capital Amortization                      	771




     Total Daily Operating Cost                $    9,340






AVERAGE COST PER 1,000 GALLONS  (250,000 gpd)   $        37.40




AVERAGE COST PER 1,000 GALLONS  (1 mgd)         $         9.34
                          A-426
-------
                        TABLE A-57






   PRELIMINARY COST ESTIMATE FOR LARGE SIZE FACILITY




                 CHEMICAL TREATMENT  MODULE






         Chemical  Reduction  of  Chromium  6  Wastes






                                                   Dollars



FIXED CAPITAL COST                             $1,189,600






OPERATING COSTS, DAILY




     Sulfur Dioxide                                  4,600




     Labor                                             129



     Supervision                                        34




     Maintenance                                       275




     Utilities                                         410




     Laboratory Service                                 40




     Overhead                                          105




     Taxes and Insurance                               101




                                                     5,694



     Capital Amortization                              652




     Total Daily Operating Cost                 $    6,346






AVERAGE COST PER 1,000 GALLONS  (344,400  gpd)    $       18.40




AVERAGE COST PER 1,000 GALLONS  (1 mgd)          $        6.35
                         A-427
-------
                        TABLE  A-58
   PRELIMINARY COST ESTIMATE FOR LARGE SIZE FACILITY




                CHEMICAL TREATMENT MODULE






              Neutralization-Precipitation
FIXED CAPITAL COST






OPERATING COSTS, DAILY




     Lime




     Flocculant




     Hydrochloric Acid




     Labor




     Supervision




     Maintenance




     Utilities




     Laboratory Services




     Overhead




     Taxes and Insurance








     Capital Amortization




     Total Daily Operating Cost






COST PER 1,000 GALLONS  (1 mdg)
                                                  Dollars
$12,680,000
$






$
     11,480




      4,100




        443




        391




        104




      2,926




        410




         40



      1,122




      1,073
     22,089




      6,945
29,034






    29.00
                         A-428
-------
                        TABLE  A-59
   PRELIMINARY COST ESTIMATE FOR LARGE SIZE FACILITY




                CHEMICAL TREATMENT MODULE






             Metallic Sulfide Precipitation
FIXED CAPITAL COST






OPERATING COSTS, DAILY




     Sodium Sulfide




     Flocculant




     Labor




     Supervision




     Maintenance




     Utilities




     Laboratory Service




     Overhead




     Taxes and Insurance








     Capital Amortization




     Total Daily Operating Cost






COST PER 1,000 GALLONS  (1.74 mgd)
                                                  Dollars
$1,433,000
    11,890




     2,050




       117




        34




       331




       410




        40




       127




       121
    15,120



       785
    15,905
         9.14
                          A-429
-------
                        TABLE A-60






   PRELIMINARY COST ESTIMATE FOR LARGE SIZE FACILITY



             LIQUID-SOLIDS SEPARATION MODULE






          Primary Clarification and Filtration






                                                  Dollars




FIXED CAPITAL COST                            $11,355,000






OPERATING COSTS, DAILY




     Labor                                              73




     Supervision                                        23




     Maintenance                                    2,620




     Utilities                                         410




     Laboratory Services                                36




     Overhead                                       1,004




     Taxes and Insurance                      	96JI




                                                    5,127



     Capital Amortization                     	6,219




     Total Daily Operating Cost               $    11,346






COST PER 1,000 GALLONS  (1 mdg)                $         11.50
                          A-430
-------
                       TABLE A-61






   PRELIMINARY  COST  ESTIMATE FOR  LARGE  SIZE  FACILITY



             LIQUID-SOLIDS SEPARATION MODULE






         Secondary Clarification and Filtration




                                                  Dollars




FIXED CAPITAL COST                             $8,063,200






OPERATING COSTS, DAILY




     Labor                                              79




     Supervision                                        23




     Maintenance                                    1,861




     Utilities                                        410




     Laboratory Services                                36




     Overhead                                         713




     Taxes and Insurance                       	682




                                                    3,804




     Capital Amortization                      	4 ,416




     Total Daily Operating Cost                $    8,220






COST PER 1,000 GALLONS (1.74 mdg)              $        4.72
                          A-431
-------
                        TABLE  A-62







   PRELIMINARY COST ESTIMATE FOR LARGE SIZE FACILITY



             LIQUID-SOLIDS SEPARATION MODULE






           Incinerator Scrubber Water Clarifier




                                                  Dollars



FIXED CAPITAL COST                            $11,408,300






OPERATING COSTS, DAILY




     Flocculant                                     2,050




     Labor                         '                    79




     Supervision                                       23




     Maintenance                                    2,633




     Utilities                                        410




     Laboratory Services                               36




     Overhead                                       1,009




     Taxes and Insurance                      	965




                                                    7,205




     Capital Amortization                     	6 ,248




     Total Daily Operating Cost               $    13,453






COST PER 1,000 GALLONS  (738,000 gpd)           $        18. 2u
                          A-432
-------
                        TABLE A-63







   PRELIMINARY COST ESTIMATE  FOR LARGE  SIZE FACILITY



             LIQUID-SOLIDS SEPARATION MODULE






                    Brine Filtration






                                                  Dollars




FIXED CAPITAL COST                                $815,000






OPERATING COSTS, DAILY




     Chlorine                                          377




     Labor                                              31




     Supervision                                        10




     Maintenance                                       188




     Utilities                                         410




     Laboratory Services                                45




     Overhead                                           72




     Taxes and Insurance                                69




                                                    1,202




     Capital Amortization                         	466




     Total Daily Operating Cost                   $  1,668






COST PER 1,000 GALLONS  (1.74  mgd)                 $       0.96
                           A-433
-------
                       TABLE A-64







   PRELIMINARY COST ESTIMATE FOR LARGE SIZE FACILITY




                 CARBON SORPTION MODULE
FIXED CAPITAL COST






OPERATING COSTS, DAILY




     Labor




     Supervision




     Make-up Carbon




     Utilities




     Maintenance




     Laboratory Services




     Overhead




     Taxes and Insurance








     Capital Amortization




     Total Daily Operating Cost






COST PER 1,000 GALLONS  (1.74 mdg)
                                                  Dollars
$3,322,000
       213




        23




     2,345




       443




       767




       107




       294




       281
     4,473




     1,819
     6,292
         3.62
                          A-434
-------
                       TABLE A-65







   PRELIMINARY COST ESTIMATE FOR LARGE SIZE FACILITY




         SUBMERGED COMBUSTION EVAPORATION MODULE
FIXED CAPITAL COST*






OPERATING COSTS, DAILY




     Labor




     Supervision




     Maintenance




     Utilities




     Fuel




     Laboratory Services




     Overhead




     Taxes and Insurance








     Capital Amortization




     Total Daily Operating Cost






COST PER 1,000 GALLONS  (1.74 mgd)
                                                  Dollars
$3,413,000
        91




        23




       788




       845




    11,700




        40




       302




       289
    14,078



     1,869
    15,947
         9.16
*Scale-up factor 0.9 for multiple units
                          A-435
-------
                       TABLE A-66
   PRELIMINARY COST ESTIMATE FOR LARGE SIZE FACILITY



                   INCINERATOR SYSTEM
FIXED CAPITAL COST






OPERATING COSTS, DAILY




     Labor




     Supervision




     Maintenance




     Power




     Fuel




     Laboratory Services




     Overhead




     Taxes and Insurance








     Capital Amortization




     Total Daily Operating Cost






COST PER TON (607)
                                                  Dollars
$17,201,700
        706




        246




      3,970




      2,271




      7 ,569




        213




      1,522




      1,456
     17,953



      9,421
     27,374
         45.10
                          A-436
-------
                        TABLE A-67







   PRELIMINARY COST ESTIMATE FOR A SECURED LANDFILL







              Capacity - 157 tons per day






                                                   Dollars




FIXED CAPITAL COST                             $  1,970,000




OPERATING COST, DAILY




     Asphalt                                           942




     Clay                                                 4




     Labor                                           1,585




     Supervision                                       268




     Maintenance                                       455




     Utilities                                         214




     Overhead                                          174




     Taxes and Insurance                          	167




                                                     3,809




     Capital Amortization                            1,079




     Total Daily Operating Cost                      4,888




     4 percent Fee for State Administration       	196




                               Total                 5,084




COST PER TON                                   $         32
                           A-437
-------
                   TABLE A-68
      PERSONNEL REQUIREMENTS FOR THE MEDIUM
            SIZE PROCESSING FACILITY
Personnel                                    Number

Plant Operators                                78

Plant Supervisors                              12

Laboratory Chemists/Chemical Engineers          4

Laboratory Technicians                          6

Laboratory Supervisors                          1

Security Guards                •                 5

Mechanics                                       2

Electricians                                    2

Instrument Repairmen                            2

Process Engineers                               2

Secretaries                                     2

Plant Superintendent                            1

                                               117
                     A-438
-------
                          APPENDIX K
              WASTE DISPOSAL PROCESS DESCRIPTORS
EVAPORATION

Evaporation is the removal of solvent as vapor from a solution
or slurry.  As a unit process this is normally accomplished by
bringing the solvent to its boiling point to effect rapid
vaporization.  Heat energy must be supplied to the solvent and
the vapor evolved must be continuously removed from above the
liquid surface to prevent its accumulation.  The vapor may or
may not be recovered depending on its value.  The end product
may be a solid (upon cooling), but the transfer of heat in
the evaporator must be to a solution or suspension of a solid
in a liquid if the apparatus is not to be classified as a
drier.A-*5

A diagram of a simple evaporator system is given in Figure
A-2.^~26 Heat is transferred to the liquid in the evaporator
from a heating coil through which steam passes.  The steam
condenses in the coil giving up its latent heat to the liquid
to be evaporated.  The vapor flows to a condensing coil which
is cooled by circulating water, where it condenses, giving up
its latent heat to the cooling water in the condenser.  The
concentrated solution or slurry in the evaporator is period-
ically or continuously drawn off after the desired solids
level is attained.

Evaporation and distillation processes are widely used through-
out industry for the concentration of solutions and for the
production of pure solvents.  Considerable research and develop-
ment has been undertaken in recent years on the application of
distillation processes to the production of potable water from
sea water.

                     Operating Principles

The principal function of an evaporator is the transfer of
heat to the liquid to be evaporated.  It therefore follows
that:

     1.  evaporation depends on the temperature differ-
         ence between the heat source and the liquid to
         be evaporated.  Greater temperature differences
-------
                            FIGURE  A-2

                        EVAPORATOR  SYSTEM
                                                     CONDENSER
                                                             VAPOR
FEED WATER
                                                    \
                                                  CONDENSED
                                                    VAPOP
                               A- -140
-------
         lead to greater heat transfer rates, all other
         conditions being equal;

     2.  evaporation depends on the exposed surface area
         available for transfer of heat.  Large surface
         areas will transfer more heat than small surface
         areas, all other conditions being equal;

     3.  evaporation depends on the coefficient of heat
         transfer which is affected by the nature of the
         condensing steam, the tube wall, the boiling
         fluid, and any fouling agents present.

The design and operation of any evaporator are based on the
control of these fundamental factors. i~"26

An evaporator may be considered a special type of heat exchanger
and the heat transfer rate predicted from the equation:

     q = UA At

where U is the heat transfer coefficient, A is the surface area,
and At is the temperature difference.  The area may be either
the area on which the steam is condensing or the area of the
surface adjacent to the liquid solution.  The reciprocal of the
product of the overall coefficient and the area, 1/UA, is equal
to the sum of the individual resistances of the condensing
steam, the tube wall, the boiling fluid, and any fouling present.
The resistances of both the condensing steam and the boiling
fluid vary with position, so that 1/UA also varies.  Further,
the heat transfer coefficient in most types of evaporators is a
strong function of the temperature difference A.-^~25

The primary purpose served by a wastewater evaporator system is
normally the concentration of the wastewater solids, dissolved
and undissolved, although the distillate produced can be useful
in many instances.  If wastewater is supplied at a rate Mf and
produces distillate at rate M^, the rate of other material
rejected from the system is Mf-M^.  If the original concentra-
tion of solids in the wastewater is represented by Cf, the orig-
inal rate of total solids fed to the system is CfMf, so that
the amount of water in the feed is Mf (1-Cf).  Hence, the amount
of water in the reject stream is Mf (l-Cf ) -Mj .  The concentration
of solids in this reject stream is now C
                  reject stream is now C^Mf/ (Mf-M^) .   The ratio
of feed to distillate produced is Mf /M^ , which is usually called
the feed ratio xf.  The concentration factor xc is defined as
Xf/(Xf-l)  and is the factor by which the initial wastewater
                             A- 4 4 1
-------
       concentration is multiplied to give the concentration of
solids in the reject stream.A~27  This reject stream is called the
brine or evaporator blowdown, and the quantity Mf-M^ may be
denoted by M^.

The energy requirement for the evaporation of wastewater is
generally a major item in operating costs.  The absolute mini-
mum of energy necessary to separate pure water from a salt
solution is the effective heat of solution, A, which is approx-
imately 1.2 BTU/lb of distillate in the case of sea water evap-
oration.^""27  in actual practice with any process more energy must.
be consumed and this energy must appear in the distillate and/or
brine or must be rejected by some other device elsewhere in the
system.  In general, the energy balance includes such additional
rejection as well as the temperature excess of brine and dis-
tillate above the feed.  If, for example, wastewater is boiled
in a simple, single effect  (as in Figure A-2) evaporator system,
it will be necessary to supply a latent heat of at least Lf to
convert each pound of water into vapor and to extract L^ to con-
dense that vapor into liquid water.  The difference Lf-L^, the
latent heat of evaporation from the solution less the latent
heat of condensation of the pure water, is in fact A.  But to
condense the vapor to the desired product a cooling stream must
be used to extract L^, which must necessarily be rejected.
Hence the total rejection per pound of distillate is L^ in the
auxiliary stream.  If, for simplicity, the distillate and brine
products are at present assumed to be at the same temperature
as the feed, then A is the enthalpy difference of the products
above the feed.  Thus the total efflux enthalpy is L^+A, giving
a total Lf, which is necessarily equal to the energy supplied.

In certain complex forms of the distillation process, which will
be discussed later, it is possible to effectively use a sub-
stantial part of the latent heat L^ given out in condensing as
a contribution to the latent heat Lf required for evaporation.
Such use, generally called "regenerative", means that the actual
energy supplied per pound of distillate product can be much less
than Lf; this will be denoted by Lf/r.  Again under the assump-
tion that the end products are at the same temperature as the
feed, A  is the only enthalpy difference of the products.  Hence,
there must be an auxiliary rejection loop or cooling stream as
before, but this time rejecting (Lf/r) - A, so that the total
outlet energy will balance the total input Lf/r.

In a distillation plant of finite size, it is impossible to have
the brine and distillate products brought back to the feed tem-
perature (except in the unlikely event that the air temperature
is consistently below the sea temperature so that air can be
used as a coolant).  Hence, in general sjD(t)3-tf) and s(j(t(j-tf)
must be written for the enthalpy contents of reject brine and
                              •*  -1-1
                              M - 4 -i .
-------
distillate, respectively, in addition to A.  (Symbols Sj-, and
Sd denote specific heats of brine and distillate, respectively,
and tfc, td, and tf denote temperatures of brine, distillate,
and feed respectively.)  Thus, if the auxiliary cooling loop
rejects qa of heat per pound of distillate made, the energy
balance for this system is

     MdLf
Therefore ,


     Lf                        "b
     — = qa + A + sd(td-tf) + — sb(tb-tf)
                               Md
But,
                - x -1
     Md    Md

Hence ,
                            Lf
     r =                     f
or
          Lf
     qa - — - A - sd(td-tf) - (xf-l)sb(tb-tf)


It is customary to refer to a characteristic R, called the per-
formance ratio of the plant.  This is defined precisely as the
number of pounds of distillate produced per 1000 Btu of heat
input.  Hence,

     R = 1000Md
         heat input

Earlier we defined Lf/r as the heat input per pound of dis-
tillate produced.  Hence,

     R = (1000 Lf)r

Since L^ is of the order of 1000 Btu/lb, R and r have the same
order of magnitude, and each is an approximate measure of the
other.  Moreover, since r is defined from the relation
                             A-443
-------
      heat  input per pound of distillate product - Lf/r,

 it  represents  the number of pounds of distillate obtained from
 a heat  input of Lf, i.e., from the latent heat of evaporation
 of  1  Ib of vapor from water.  Thus, r is conventionally named
 the gained output ratio of the plant.

                         Process  Design

 ^o  generalization can be made which will serve as a reliable
 guide in the selection of the optimum type of evaporator and
 its auxiliaries.  Factors which must be considered in the selec-
 tion of the type of evaporator most suitable for waste liquid
 processing are:  (1) characteristics of the feed, such as com-
 position and amount of dissolved materials and their salting,
 scaling, corroding and foaming characteristics; (2)  amount of
 liquid  to be treated per hour and it fluctuations, and number
 of daily working hours involved;  (3)  volume reduction and decon-
 tamination factor required; (4)  ease of maintenance; (5) space
 limitations; and (6) economic limitations.A-2 a

 Coil or Pot Type Evaporator

 This type of evaporator is now seldom used in the chemical in-
 dustry but is  frequently used for processing radioactive wastes,
 especially for small installations.   A coil type evaporator in
 a simplified form is illustrated in Figure A-2.   Pot type
 evaporators are simply constructed and may be useful for simple
 batch operation.  In a small installation with a small heat
 load a jacketed kettle may be used.

Horizontal-Tube Evaporator

 The horizontal tube  evaporator was widely used for more than 50
years in the chemical industry but is seldom used now except for
boiler feed water preparation.   The distinguishing features in
 the design of this evaporator are the shape and arrangement of
 the evaporator tubes.   The tube  bundle is normally submerged.
One type of horizontal tube evaporator is illustrated in
 Figure A-3.

 Vertical-Tube Evaporator

The vertical tube evaporator,  as illustrated in Figure A-4
 is widely used throughout industry.   The body is normally a
 cylinder and the heating surface is  provided by short tubes,
 usually 2 to 3 inches in diameter, through the steam chest at
 the bottom of the vessel.  This  type  of evaporator gives high
 heat transfer coefficients at high temperature differences, but
 as temperature differences decrease  heat transfer becomes poor.
                              A- 4 4 .1
-------
      o:
      o
      o
      Q-
ro
 I
u_    
-------
                      FIGURE A-4


               VERTICAL-TUBE EVAPORATOR
     FEED
NPENS ATE
             VENT.
               n
               L
                                           VAPOR
fa*
\
                                              STEAfl
                                             T H I C K  LIn U 0 R
                        A-44*
-------
Liquid circulation past the heating surface is induced by the
pumping action of water vapor  formed in the tubes.

The return passage from above  the steam chest to the bottom
space is usually a cylindrical downtake.   Its cross-sectional
area should be of the same order of magnitude as the total
cross-sectional area of the tubes.  This arrangement is the
most commonly used standard vertical evaporator, but a vari-
ation without downtake called  the "basket-type" is also used.
Because the natural recalculation rate is  many times the feed
rate, the liquid entering the  bottom section is of the same
concentration as the product removed in continuous operation.
The circulating velocity and heat transfer rate are strongly
affected by the liquid level.  The highest heat-transfer
coefficients are achieved when the level,  as indicated by an
external gage glass, is only about halfway up the tubes.  A
slight reduction in level below the optimum results in incom-
plete wetting of the tube walls with a consequent increased
tendency to foul and a rapid reduction in  capacity.

When scaling or salting liquids are to be  evaporated it is cus-
tomary to operate with the liquid level appreciably higher than
the optimum.  To remove scale, the tubes are subjected to
cleaning by mechanical devices which limit the length of the
tubes.  The standard vertical  tube evaporator is versatile and
relatively inexpensive.

Fo r ce d- Ci rcul ati on Type

Liquid is circulated by a pump through the heating tubes at
relatively high velocities in  this type of evaporator with
relatively little evaporation occurring per pass.  Scale depo-
sition on the heat exchange surfaces is low and heat transfer
is high due to the high velocities of the  liquid.  The heating
element is generally contained in a separate unit and the tubes
may be either vertical or horizontal.

Multistage Flasn. Type

Multistage flash distillation  (MSF)  was successfully developed
early in the saline water conversion program.   MSF plants
accounted for more than two-thirds of the total production
capacity of plants of all sizes built since 1951, according to
a United Nations  survey issued in 1969.A~29  A simplified flow
diagram of the MSF process is shown in Figure A-5.  Heated
brine flows through a series of chambers at successively lower
pressures while water vapor flashes off in each chamber and
condenses on the surfaces of heat exchange tubes.  The heat
exchange tubes in the chambers contain brine which flows back
to the feed heater.   The returning brine captures the heat of
-------
i_n

-------
condensation in each of the flash chambers and thereby minimizes
the thermal input to the system.  Scaling problems are reduced
because no evaporation takes place on the heat exchange sur-
faces .

Multiple-Effect Type

Multiple-effect distillation generally refers to a system in
which the heat of condensation from one "effect" is used to
evaporate water in the succeeding "effect".  A simple multiple-
effect system is illustrated in Figure A-6.  Water enters the
first effect where it is heated and evaporated.  The vapor from
this effect is condensed in the second effect, which also boils.
Each effect is operated at a lower pressure than the previous
one, and the pressure changes correspond to the difference
required to produce the flow of heat needed.  The heat transfer
limitations of submerged-tube distillation require temperature
driving forces of around 25°F per effect and are therefore
limited to a few effects.

The vertical tube evaporation (VTE)  (multiple-effect distilla-
tion) process was selected by the Office of Saline Water to
demonstrate the economic feasibility of multiple-effect distil-
lation.  Superior heat transfer is obtained by allowing water
to fall through heat exchange tubes heated by steam which is
admitted into the space around and outside of the tube bundle
of the effect.  Hot vapor and brine emerge at the bottom of the
first effect.  The hot brine is pumped to the top of the second
effect and falls through tubes arranged vertically in this
effect.  The vapor produced in the first effect is condensed
in the second effect, producing fresh water.  This process is
repeated in each effect, producing both fresh water and heated
brine.

Vapor Compression Pisti11ation

Vapor compression distillation is based on the principle that
when a vapor is compressed, its temperature rises.  It then
becomes possible to condense the vapor at a higher temperature
and use the latent heat to evaporate more liquid.  An elemen-
tary flow diagram of this process is shown in Figure A-7.
Saline water is pumped into a heat exchanger within an evapo-
rator chamber where it is boiled.  Vaporizing fresh water is
piped to a compressor where its heat content is raised by com-
pression.  The compressed vapor then flows through the heat
exchanger giving up its latent heat to the boiling saline water
and is condensed to fresh water.  This method makes use of the
fact that the saturation vapor pressure of water increases with
pressure, so that by compressing the vapor, the subsequent con-
densation will be high enough to cause the evaporation of more
                             A-449
-------
                    FIGURE A-6

             MULTIPLE  EFFECT EVAPORATOR
t CO
                     SECOND
                     EFFECT
THIRD
EFFECT
           w-h  i—t*/wy-i
                            1
                                                BklNE
               i1 P £ S H
               WATER
-------
                     FIGURE  A-7

            VAPOR  COMPRESSION  EVAPORATOR
FEED
                                 VAPOR
          STARTING
         HEAT SOURCE
                            FRESH
                            WATER
                                      COMPRESSOR
                                     (HEAT SOURCE)
                       A-451
-------
water.  The energy input to this system is very low compared to
other distillation processes.   The vapor compression process
generally requires no auxiliary heat source for operation,
except for starting, other than that supplied through the motor
driven compressors.  Starting heat in the form of steam is
supplied by a small boiler.

      Film Type
This type of evaporator might be classed as a forced-circulation
type because it uses mechanical energy to improve heat transfer.
The heating surface consists of a single (vertical type) or
tapered (horizontal type) cylinder of large diameter in which
an agitating blade or series of wipers rotates.  The liquid
waste fed into the cylinder is agitated vigorously by the
rotating blades, becoming filmy by centrifugal force, and flows
along the heating surface.  The continuous formation of the
film permits a much higher concentration of thick liquor than
can be handled in other types of evaporators.

Submerged-Combustion Type

Submerged combustion evaporation utilizes combustion gases in
direct contact with the liquid to be evaporated as a means of
heat transfer.  It may consist simply of a tank to hold the
liquid and a burner that can be lowered into the liquid.  Because
there are no heating surfaces on which scale can deposit, this
device is well-suited for use with severely scaling liquids.

Another type of submerged combustion evaporator^"31 is  shown in
Figure A-8.  Fuel gas and air are mixed and then fired by a
high energy release burner into a combustion chamber.  Hot com-
bustion products from this chamber are exhausted through a
small port.  The liquid to be evaporated is injected at a con-
trolled rate from an annular feed chamber jacket in the exhaust
port of the combustion chamber.  A complete exchange of heat
takes place instantly as the liquid stream enters the exhaust
gas stream.

The heated product is separated from the quenched gas stream in
a cyclonic separator.  Spent gases are exhausted and the product
is collected and drawn off for ultimate disposal and for recyc-
ling with feed.

Solar Evaporation

Solar evaporation ponds are feasible only where annual evapora-
tion exceeds annual rainfall by more than 20 inches, as it does
in areas of the far West.A~31  In many arid areas it is possible
to evaporate brines to dryness in properly lined solar evapora-
-------
                         00

                         oo
                         CC
      01
      o
      a:
      o
      a.
CO

  i/")
    CD
    CXL
    eC

O  O
—i  I/)
I—  '—'
<:  o
                                                                                                    CO

                                                                                                    O
                                                                                      =a:  
-------
tion ponds.  The ponds may be abandoned after use by placing a
suitable cover material over the surface to prevent wind erosion
of the salts.  Contamination of groundwater is unlikely due to
negligible infiltration of rainfall into deep soil layers.

                       Process Economics
Major factors governing evaporation process economics include
the cost of equipment and installation, the cost of fuel or
steam, and the cost of operating labor.  The estimated cost
data for one type of evaporation process, multistage flash, are
given in Table A-69 for a 100,000 gpd plant evaporating waste-
water from 0.7 percent to 10 percent total dissolved solids.
Estimated costs are based on published data (1970)^~31 updated
to 1972 using the Chemical Engineering Plant Cost Index.

                     Process Modifications

Process modifications include feed stream pretreatment to con-
trol corrosion, scaling and foaming.  Acids or bases frequently
are added to adjust the pH of the feed to the optimum level to
control corrosion and/or scaling (e.g., calcium carbonate depo-
sition) .  Ion exchange and/or cold lime softening are also used
to remove scale forming elements such as calcium and magnesium.
Scale forming inhibitors such as polyphosphat.es are frequently
employed.  Foaming can be controlled through the use of various
antifoam agents.

Deentrainment devices are employed where it is desirable to
minimize the carryover of entrained salts into the distillate.
These are particularly important with respect to the evaporation
of radioactive wastes where high decontamination factors between
the feed and the distillate are necessary to meet discharge
standards for radioisotopes.

                     Process Applicability

Evaporation represents the most versatile wastewater processing
method available that is capable of producing a high quality
effluent.  It is, however, one of the most costly processes and
is therefore generally limited to the treatment of wastewaters
with high solids concentrations or to wastewater where very high
decontamination is required (radioactive wastes).  Many examples
are available throughout industry which illustrate the use of
tnis process.  One example is discussed below which involves the
treatment of high salt, radioactive wastes at the U.S. Atomic
Energy Commission's Hanford facilities in the State of Washing-
ton.^-32

A hot air sparge evaporator has been employed at Hanford to con-
centrate radioactive wastes to salt cakes.  This evaporator is
                              A-454
-------
                        TABLE A-69

           ESTIMATED COST DATA ON MSF EVAPORATION
                 PROCESS AT 100,000 GPD FLOW
Capital Cost, dollars                             174, 000 a

        (including installation)



Operating Cost

        Steam, (Ib/hr)                              (3,300)

               $/day @ $0.46/106 Btu                   36.5
        Electricity, (kw)

               $/day @ 12 mills/kwh                     8-7

        Operating Labor, $/day                        167.0

        Maintenance and Supply, $/day                   2.0

        Total Daily Operating Cost, $/day             214.2
(a)  Does not include the boiler cost, which is included in
    steam cost.
                            A-455
-------
similar to a submerged combustion type except that hot air is
used in place of gaseous combustion products.  The process is
operated by introducing electrically heated air through an air
lift circulator located in a large underground tank.  The off-
gases leaving the high salt solution in the concentration tank
are unsaturated with respect to pure water and contain entrained
radionuclides which must be removed prior to release on noncon-
densables to the atmosphere.  A diagram of the process is given
in Figure A-9.

A typical waste feed composition is as follows:

                 NaOH      -      2.1 M
                 NaAlO2

                 NaHO2

                 NaN03

                 PH

                 Sp. Gr.

                 137CS
0.5 M

1.5 M

1.1 M '

12.5

1.14

0.03 Curies/gal
The waste is concentrated to approximately 25 percent of its
original volume, which results in crystallization of many of
the salts contained therein.

CARBON ADSORPTION

Adsorption is said to occur when a substance is brought into
contact with a solid and held at the surface of the solid by
physical and/or chemical forces.  The solid is called the ad-
sorbent and the adsorbed substance is the adsorbate.  The amount
of adsorbate held by a given quantity of adsorbent depends upon
several factors including the surface area per unit volume (or
weight) of the adsorbent and the intensity of the attractive
forces.  The situation is more complicated when a liquid con-
taining two or more substances is brought into contact with the
solid adsorbent.  In this case competitive forces exist between
the solvent and the dissolved solute and between the solute
(adsorbate) and the adsorbent which determine the quantity and
rate at which the solute molecules are removed from the liquid
stream by the solid.  Activated carbon, which is produced from
an organic material that has been carbonized and subjected to
a controlled oxidation (activation) process to increase surface
area and develop a very porous structure, has been widely used
to remove organic and other contaminants from water.  It has
                              A-456
-------
     o:
     o
     CL.
LU   CD
a:   Q-
     t/o


     i—t
     <=c

     I—
     o
                                        A-457
-------
been used to remove dissolved refractory (i.e.  biologically re-
sistant) organics from municipal waste streams      and to clean
up industrial waste streams.A~3"  Also,  activated carbon has
been shown to remove some heavy  metals and other inorganics from
water.^~35'A~36  Usually, economical application of activated
carbon for wastewater treatment requires some method for regen-
erating the carbon.  This can involve contacting the carbon
with a solvent which has a higher attraction for the adsorbed
material than does the carbon, resulting in desorption.  More
often, however, the carbon is thermally regenerated in a
furnace under controlled oxidizing and temperature conditions.
Thermal regeneration of carbon is particularly applicable for
large plants and for those treating wastes containing a
variety of compounds.

The usual treatment technique involves the use of columns or
beds of granular carbon similar to the columns used for ion
exchange.  This can take the form of parallel (Figure A-10)
or series (Figure A-ll) operation of the carbon beds,
depending upon the concentration of the containment and the
degree of removal required.  Thermal regeneration requires the
removal of the carbon from the bed upon exhaustion, whereupon
it is regenerated and returned to the bed for further service
(Figure A-12).

                     Operating Principles

The attractive power of the solid surface in carbon adsorption
has been compared to the solubilizing power of a liquid at a
liquid-liquid interface such as between ether and water.  If
the aqueous phase of the ether-water system contained a contam-
inant such as propyl alcohol, the nonpolar ends of the alcohol
molecules would be attracted to the ether layer, whereas the
polar ends of the alcohol molecules would be attracted to the
water layer  (like dissolves like).  The result would be a con-
centration of propyl alcohol at the ether-water interface with
the molecules oriented so that the polar ends extended into the
aqueous layer and the nonpolar ends into the ether layer.  A
similar effect occurs at the surface of activated carbon where
the nonpolar or nonpolar ends of organic molecules are attracted
or "dissolved".  Generally, the more nonpolar a molecule is or
the longer its nonpolar "tail",  the stronger the attraction to
the carbon surface.  Also, it becomes obvious that the removal
capacity of the carbon depends upon its surface area per unit
volume  (or weight).  There is, however, often a limit beyond
which an increase in specific surface area does not result in
increased adsorption. ~    In  general, the  factors  influencing
adsorption at the carbon-liquid interface are given below in
Table A-70:
                             A-458
-------
    FIGURE A-10




PARALLEL OPERATION
     W A 3 T E I N
        i
                 C'') fJ T A C T 0 R
     ;;ASTE  OUT
      A-459
-------
               FIGURE  A-11



             SERIES  OPERATION
WASTE I
 CONTACTOR
                                      1
CONTACTOR
                                   WASTE  OUT
                  A-460
-------
                  FIGURE A-12



          CARBON  REGENERATION SYSTEM
CONTACTOR




MAKEUP
STORAGE





qutriC'i
TANK

                     A-461
-------
                                      A- 3 6
                           TABLE A-70
             FACTORS INFLUENCING ADSORPTION AT
                     CARBON LIQUID INTERFACE
             Attraction of carbon  for solute

             Attraction of carbon  for solvent

             Solubilizing power of solvent for solute

             Association

             lonization

             Effect of solvent on  orientation at interface

             Competition for interface in presence of

             multiple solutes

             Interactions of multiple solutes

             Coadsorption

             Molecular size of molecules in the system

             Pore size distribution in carbon

             Surface area of carbon

             Temperature
Tae adsorption of inorganic substances is quite variable.   Some
strong electrolytes show little adsorbability whereas others are
adsorbed to a high degree.   (Table A-71 gives some inorganic
substances adsorbable by activated carbon.)   The mechanisms of
inorganic adsorption are even less well understood than those
for organic adsorption.
                             A-462
-------
                         TABLE A-71A 36

             SOME INORGANIC SUBSTANCES  ADSORBABLE BY
                        ACTIVATED CARBON*
                        Iodine

                        Gold Chloride

                        Permanganates

                        Dichromates

                        Mercuric Chloride

                        Molybdates

                        Ferric Salts

                        Arsenates

                        Silver Salts
    *The extent of adsorption of many inorganic substances is
     greatly influenced by pH of the solution.


One mechanism appears to be chemical reduction, an example
being the reduction of halogens, possibly to halides.  In the
case of some heavy metals, it has been shown that the metal
ion has been reduced to the elemental metal which is deposited
in the pores of the carbon.  In that case, thermal regeneration
may not return the carbon to the expected state.

A second possible mechanism for removing inorganics from water
involves the process of co-adsorption, wherein organic or other
material in the water is adsorbed onto the carbon and assists
in attracting the inorganic material.  This may occur by com-
plex formation or other means.  The relationship of pore size
and molecule size can be important in "trapping" the molecule
or ion in the carbon.  Lastly, the simple filtering effect of
the carbon for solid particles may be important, particularly
if the pH of the water changes within the bed due to biological
action.
                             A-463
-------
Usually the regeneration  furnace is  fitted  with a scrubber and
afterburner to eliminate  possible particulates  and organic
vapors.  This approach has allowed the  thermal  regeneration of
activated carbon to result in final  disposal  wh^e at the same
time meeting most air pollution requirements.     'A~37

                        Process Design

Probably the most important items to consider at the beginning
of a carbon adsorption design are the rate  and  efficiency of
adsorption and the ultimate loading  capacity  of the carbon
expressed perhaps as mg of contaminant  per  gram of carbon.  This
information can be obtained by the isotherm test.  The Swindell-
Dressier Company, in a report for the EPAA~37 has described the
isotherm test and its interpretation.

    An  adsorption isotherm  is  a  batch adsorption test
    performed in  the laboratory  under standardized con-
    ditions.  It  will  be  valid  only  for the temperature
    at  which it  is  run,  which  should correspond  to the
    temperature  normally  encountered in the wastewater.
    The isotherm  test  actually  consists of a  series  of
    individual batch tests  which differ only  in  one
    respect, e.g.,  carbon dosage.   Different  carbons
    may also be  compared  by running their respective
    series of batch  tests at  the same time, or  in
    succession using the  same  batch of feedwater.  Each
    individual batch test is  run in a shaker  or  beaker
    with an attached mixer.   Organics are measured before
    and after contacting  the  feedwater with the  carbon.
    Interpretation  of  the test  results is discussed
    below.

    The wastewater  used  for the isotherm test  should  be
    the same feed as that to  be treated in the  full-
    scale plant.  If preliminary chemical clarification
    is  planned,  then the  isotherm feed should  be clari-
    fied with the same  coagulant at the same  pH, and
    then readjusted  to  whatever pH is deemed  suitable
    for plant operation  and discharge.

    Selection of carbon  dosages may be somewhat  arbi-
    trary at first.  It  is  usually necessary to  run
    several tests in succession to identify the  range
    of  dosages which will give the best isotherm results.
    The final isotherm plot must consist of adsorption*
    data collected  at  one time on the same batch of
    wastewater.   Either  TOO or COD  is an acceptable
    organic  parameter  by which to evaluate the results
    of an  isotherm  test.
                             A-464
-------
The procedure  for the isotherm  test  need not be
described  in  detail here since  it  may be found in
many places  in the literature....

The adsorption data may be evaluated by using a
logarithmic  plot of:  organics  removed per unit
dose of adsorbent versus residual  organic concen-
tration.   The  following example should serve to
describe the  procedure:

  Carbon dosage (M)   Residual  COD (C )
       (9/1)                 (nig/1)        X=Co-Cf X/M

        0                 130(=C )          -     ~
       0.25                  86    °          44    176
       0.50                  73              57    114
       1.00                  69              61     61
       2.50                  45              85     34
       5.00                  33              97     19

  plot log X/M versus log  C

The plot is  shown in Figure A.-11.   The isotherm
plot should  be linear, but frequently deviates from
this ideal.   Straight lines may be drawn through
many data  sets without trouble.   Individual deviant
points may be  discarded as a matter  of judgment.
Non-linear or  completely scattered sets may require
a least-squares fitted line; however, it could be
argued that  any data set which  truly requires a
least-squares  line is probably  worth redoing.  The
success of isotherm testing rests  with strict
attention  to  procedural detail.

Once a straight line of fair precision has been drawn,
it is  extrapolated towards the  right to the C  inter-
cept.  The resulting ordinate,  here  450 mg COD/g
carbon, is a  measure of adsorption capacity.  The
slope  of the  isotherm line may  also  be used to
characterize  the adsorption operation being tested.
Steeper slopes indicate good adsorption of organics
present in solution at higher  concentrations but not
at lower concentrations.   Slight  slopes indicate
comparable adsorption over the  entire range of
organic concentrations.  Higher slopes generally
indicate that  greater adsorption  efficiency in
column operations can be expected.
                          A-465
-------
                        FIGURE A-13
               TYPICAL ADSORPTION ISOTHERM
  1000
   800

   600

   400
 1  200
o
100
 80

 60

 40
    20
                                 T    I   I
      10
                          INTERCEPT=450
                                    I
              20           40    60   80 100
               Cf=RESIDUAL  ORGANICS  (COO,  rng/L)
                                                       200
                          A-466
-------
Column Configuration and Size

Brief mention was made in the introduction of the two principal
configurations of the contact columns   (see Figures A-10 and
A-12).  Some other possible configurations are possible, of
which the most important is probably the semi-continuous mode
in a single or parallel column.  The semi-continuous mode of
operations is essentially equivalent to the so called "con-
tinuous-loop" ion exchangers wherein sections of adsorbent are
removed from the waste-in end of the column for regeneration
at frequent intervals.  At the same time, an equivalent quan-
tity of virgin or regenerated adsorbent is inserted into the
column at the product end of the column.  In this manner a
semi-continuous counter current flow of wastewater and adsor-
bent is maintained.  The advantages include an inventory of
adsorbent and assurance that the adsorbent is being loaded to
the maximum extent possible which results in reduced regenera-
tion costs.

A disadvantage in this case is a reduced flexibility for auto-
matically handling the wide fluctuations expected in waste con-
centrations.  Also, the relatively low volumes of wastewater
expected may reduce the low carbon inventory advantage of semi-
continuous mode operation since the minimum number of columnus
(including backup) may be the same in both semi-continuous and
two-stage operation.

in comparing single column and multiple column operation for a
given volume of carbon, the M. W. Kellogg Company in a report
to the EPA^~38 found that for treating secondary sewage at the
same total contact time and hydraulic loading that the two
stage column operation (see Figure A-J2) was more economical
than either the single stage operation or when three or more
stages were used.

Regeneration of Spent Granular Activated Carbon

The Swindell-Dressier report gives a good description of the
regeneration process. ~37

    To make granular activated carbon economically feas-
    ible for wastewater treatment, the  spent carbon must
    be regenerated and reused.  Nhen a  carbon column has
    been operated for some time, the quality of its
    product water deteriorates gradually until it passes
    some predetermined limit beyond which it is no longer
    acceptable.   The carbon must then be regenerated.
    When the lead contactor  (assuming a multi-stage con-
    figuration) is taken offstream, the usual practice
                             A-467
-------
is for  the  number two contactor  to  become the new
lead contactor.   All Additional  contactors, if any
more are  used,  move up one place in the series.  A
spare contactor containing virgin and/or regenerated
carbon  is  inserted into the last position in series.

The thermal  regeneration of carbon  is presently the
only feasible  procedure for destroying adsorbed
organics.   Thus maximum effort has  been concentrated
on optimization of thermal regeneration techniques,
using a reducing atmosphere of flue gas and steam.

A typical  basic sequence for  the thermal regeneration
of carbon  is as follows:

  a.  The  granular carbon is  hydraulically trans-
      ported (pumped) in a water slurry to the
      regeneration station for dewatering.

  b.  After  dewatering, the carbon  is fed to a
      furnace  (usually of the multi-hearth type)
      and  heated to 1500°F -  1700°F in a con-
      trolled  atmosphere which volatilizes and
      oxidizes  the adsorbed impurities.

  c.  The  hot  regenerated carbon is quenched in
      water.

  d.  The  cooled regenerated  carbon is again hy-
      draulically transported to the adsorption
      equipment or to storage.

 The  thermal regeneration  process itself involves
 three  steps:

   a.   Drying

   b.   Baking (pyrolysis  of  adsorbates),  and

   c.   Activating  (oxidation  of  the  residue  from
       the adsorbate).

 The  regeneration  process  itself  requires  30  minutes:
 the  first 15 minutes  is  a  drying period during which
 the  water retained  in  the  carbon pores  is  evaporated,
 a  5-minute  period  during  which  the  adsorbed  material
 is  pyrolyzed and  the  volatile portions  thereof are
 driven off; and  a  10-minute  period  during  which the
 adsorbed material  is  oxidized and  the  granular car-
 bon  reactivated.
                          A-468
-------
.As a contactor  is  removed from service  for  regener-
ation, the  spent  carbon is usually  hydraulically
transported to  a  drain bin.  The drained  carbon is
dried during the  first step in a furnace  which heats
the carbon  up to  212°F (for this phase  of the regen-
eration).   During  baking, the temperature increases
from 212°F  to 1500°F, by which time  adsorbed
organics are thoroughly carbonized.   This is accom-
panied by evolution of gases and by  the formation
of a carbon residue in the micropores of  the acti-
vated carbon.  The objective of this  activating step
is to oxidize the  carbon residue with minimum
resultant damage  to the basic pore  structure,
consequently affecting maximum restoration  of the ori-
ginal properties  of the carbon.  The  activating gas
temperature during this step is about 1700°F, while
the carbon  temperatures range from  1500°F to 1650°F.
Flue gas supplemented by varying amounts  of additional
steam produces  the desired atmosphere.   Laboratory
experiments indicate that the most  important phase
of the regeneration process is that  of  activation,
with the critical  parameters being  carbon temper-
ature, duration of activation, and  steam  or carbon
dioxide concentration in the activating gas mixture.
Since most  commercial installations  are direct-fired
multiple hearth furnaces for regeneration,  the com-
bustion of  natural gas with air provides  the required
heat, while carbon dioxide, oxygen  and  steam, as part
of the products of combustion, are  the  activating
agents.  Extra  steam at approximately one pound per
pound of product  regenerated is supplied.  This
requires some steam generating equipment  and a boiler
feedwater treatment system.

For regeneration  processes utilizing multiple hearth
furnaces, the overall carbon losses  usually vary
from 5% to  10%  per regeneration cycle.   As  stated
before, the relatively high cost of  granular acti-
vated carbon (24$  to 30f per pound)  makes it eco-
nomically necessary to regenerate and reuse the
carbon.  If a 5%  loss of carbon per  regeneration
cycle is assumed,  then most of the  carbon originally
in use will have  been replaced after  20 cycles and
the bulk or aggregate properties of  the mix will
have approached a  constant value.

Multiple hearth furnaces used for regenerating carbon
should consider the BSP recommendation  that the
hearth area contain one square foot  per 100 Ibs of
carbon to be regenerated per 24 hours.   A slight over-
                         A-469
-------
     sizing of the furnace beyond this provides for  future
     expansion of a treatment plant at very low cost.

     The operating cost of the furnace can be developed  Ly
     assuming a fuel requirement of 3200 UTU and one pound
     of strain per pound of carbon.  The encrtjy required  to
     generate the steam will be approximately 1250 BTU per
     pound.

     The rate at which the carbon in a single contactor  is
     exhausted determines the minimum rate at which  th.i^
     same carbon must be regenerated (in order that  it mi.jttt
     be available for use again as a spare contactor).   The
     furnace must be oversized by a factor of two or more so
     that the design regeneration rate exceeds the exhaus-
     tion rate by a safe margin.

     The regeneration process may be monitored by reducing
     the apparent density of the carbon back to its  virgin
     value.  Larger apparent densities than the virgin
     value indicate an incomplete regeneration of the
     carbon and smaller densities are indicative of  burnina
     of the carbon.


Flexibility of Operation

Due to the expected large variations in the wastewater contam-
inant concentrations and the types of contaminants,  the  carbon
loading will vary.  As a result the carbon contacting  and
regeneration system must be designed with more  flexibility
than is normally found in specific applications.  The  usual
recommendation made in the literature to account  for expected
increases in the loading rate  (either higher contaminant con-
centrations or higher wastewater  flow rates) is  to overdesign
the regeneration furnace since this is generally  more  econom-
ical than having extra contact columns and carbon inventory.
The recommendation by Swindell-Dressier above that the  regen-
eration furnace be designed to handle twice the expected ioau
should probably be followed.  A higher regeneration  system
overdesign might be justified with widely fluctuating  organic
concentration.  A completely optimum design would requir« a
detailed knowledge of the volumes and concentrations of  uajc..--
water expected to be treated by the carbon system.   A  praotica..
approach would probably involve a regeneration  system  at least
twice the size needed for the expected mean carbon exhaustion
rate and contact columns that could handle a reasonable  increase
in flow rate, concentration, or both from the expected  Pican
until lower concentration/flow rate values resumed.   The uppe t:
limit of concentration might be determined by the economical
breakover point between carbon adsorption and perhaps  steam
                          A-470
-------
stripping.  The upper time limit before breakthrough might be
determined by the largest volume of a particular type of waste
processed.  Since corrosion potential would probably require
expensive materials  (the carbon itself is rather corrosive), a
larger than usual carbon inventory could be more economical in
this case.  In Figure A-12, if  the surge bin  and makeup
storage units were designed to  contain twice  the volume of a
single contact unit, an exhausted column could be emptied and
refilled with regenerated carbon and placed back into service
quickly.  This would allow treatment of the waste for short
periods even though the regeneration rate temporarily ran
below the carbon exhaustion rate.  It would also reduce the
necessity of having extra or oversized contactors.  Since acti-
vated carbon is rather expensive (24-30£/lb)  an economic
tradeoff between idle carbon inventory, contact column  capacity
and regeneration system capacity should be determined.
Upflow vs. downflow configuration is also discussed by  Swindell-
Dressier. A~3 7

     Downflow

     Downflow carbon beds accomplish both adsorption and
     filtration of wastewater.  Plants using  this mode
     of operation will utilize  hydraulic loadings of 2
     to 10 gpm/sq ft.  Ac the lower flow rate, suspended
     solids contained in the wastewater dre normally
     collected on the surface of t\e bed.  At higher flov
     rates, some of the suspc* .dec7 so ! ids may  penetrate  to
     s -;-.•• d ' c f --  -• J   co th .•
     s u r i a c e o
-------
in the backwash  water.   If anaerobic conditions
develop, sulfides may be generated in the column
and may appear in the effluent.

If the suspended solids  concentration in the  influent
to the carbon beds  is sufficiently great, the  cost
of backwashing must be weighed against the cost of
providing a pr2treatment step.

Upflow

Carbon beds operating  with the wastewater passing
upward through the  carbon can assume three differ-
ent modes.  At low  hydraulic loadings, less  than  2
gpm/sq ft, the fled  of  carbon will remain substan-
tially packed at  the bottom of the column.   At
higher hydraulic loadings, 4-7 gpm/sq ft, the bed
will become partially  expanded.  At much higher
rates, the carbor. will  be lifted and packed  against
the top of the column.   In the event that little  or
no freeboard is  available, the bed will  operate  as
a packed bed at  any velocity.

When the upflow  carbon  column is operated as a
packed bed, suspended  solids present in  the  waste-
water will be collected  on the bottom of the bed.
Unless preliminary  solids removal processes  are
employed, backwashing  of the solids from the bottom
of the bed may pose a  considerable problem,  so these
systems are not  recommended.

Operating as a partially expanded bed, the carbon
will not act as  a.  filter.  Suspended solids  will
pass into the effluent  largely undiminished.

In the  "pulsed bed  " system, wastewater is passed
upflow through the  bed.   Periodically, a column  is
briefly removed  from service, a portion  of  the
carbon in the bottom of the bed is withdrawn, and
a fresh equal charge of carbon is forced into the
tope of the bed.  As noted previuoslu, this  concept
is ony way of approximating true countercurrent
ope ration.

Gravity and Pressurized Flow

The main advantage  of  a  gravity flow system, which
may be operated  either downflow or upflow,  is the
elimination of large pumps and their associated
operating costs, and the reduction of costs  for  non-
                        A-472
-------
     pressurized vessels.  However, due to the limited
     available head, it is usually necessary to remove
     suspended solids by pretreatment  (e.g. through
     chemical clarification or filtration) so that head-
     loss and thus backwash requirements are not excessive.
     Operating a gravity flow system upflow as a partially
     expanded bed (rather than packed bed) is more attrac-
     tive in that the pressure drop across the bed will
     remain constant.  Thus this system can provide sus-
     tained operation over considerable periods of time.
     A supplementary solids removal step still may be
     necessary as either pie- or post-treatment.

     Pressurized flow offers the advantages of being able
     to operate a carbon bed at a higher flow rate and
     over a greater range of pressure build up before
     backwashing is necessary.  This permits the height
     of carbon contacting vessels to be limited to the
     carbon bed depth plus 50% for expansion during back- '
     wash .

     In summary, the pressurized flow, at additional
     operating and investment costs, offers guaranteed
     flexibility in overcoming increasing pressure drops
     through packed beds.  On the other hand, the
     gravity flow systems, although not fully evaluated
     at this time, offer considerable cost savings.


Normal Operating Conditions

Pressure depends upon upflow or downflow  configuration and upon
the suspended solids content of the wastes.  Temperature will
be near ambient.  The pH  normally would be near neutral as a
result of the previous neutralization  step.  However,  reduction
of the pH to about  three  may be required  at  times  to  control
anaerobic production of H2S.  The corrosion  resistance of
materials used  for  chemicals such as phenol  (SS  304)  would be
sufficient  to resist attack by pH  3 solution.

                       Process Economics

The major capital expenditures for  a carbon  adsorption system
of this type would  be for the regeneration system.   Since the
expected mean contaminant concentrations  will  be near 1,000 ppm,
the relative size of the  regeneration  system compared to the
regeneration system for treating municipal waste would be
higher and  thus  the costs would be  greater.  A rough  cost
estimate for 1,000  ppm phenol and  60,000  gallons per  day flow
rate shows  that  a regeneration furnace overdesigned by a factor
                             A-473
-------
of two represents over 45 percent of the total  capital  costs  of
a carbon adsorption plant.   This estimate was made  using  304
stainless steel.  If three  carbon contact columns of  304  stain-
less steel were used, they  would represent about 30 percent of
the total capital investment.   The piping pumps, valves and
initial carbon inventory represent the remaining 25 percent of
the total capital cost.  This is in sharp contrast  to the
capital cost breakdown reported by Swindell-Dressier in the
EPA Design Manual.  The design manual results  appear to be
primarily based upon treating relatively low level  secondary
municipal effluents.  The high percentage of the total capital
costs represented by the regeneration system is confirmed by
costs data of a carbon adsorption plant designed to treat
150,000 gpd of a wastewater from a herbicide manufacturing
plant containing over 200 ppm of various phenols and cresols
and 1,000 ppm of various alcohols.  The percentage  of the
total capital cost for the regeneration system was  nearly 50
percent for that operation.^"39

Based upon 60,000 gpd of 1,000 ppm phenol and using SS 304
throughout, the cost breakdown was approximately as follows:

     Three columns                              $157,000
     Valves                                      40,000
     Pumps                                       25,000
    *Thermal Regeneration System which
     includes the following:                    250,000

          Dewatering Tanks
          Surge Bin
          Screw Feeder
          Valve
          Furnace
          Quench Tank
          Diaphragm Pump
          Controls

     Carbon Feed Tank SS 304                     30,000
     Initial Carbon Inventory                      8,600
     Pipe                                        10,000

                                                $520,600
 *This does not include about $60,000 for the after burner
  and stack scrubber.   Location of furnace near incinerator
  would eliminate duplication.
                            A-474
-------
Using a 20 year useful life and five percent interest,  the
operating costs*  would be:

     Depreciation                               0.134
-------
powdered carbon may be used and incinerated on a once-through
basis since its cost is about one-third the cost of the granular
product (lOt/lb).

                    Process Applicability

Carbon adsorption can remove most types of organic wastes from
water.  Short carbon chain polar substances such as methanol,
formic acid, and perhaps acetone are incompletely removed.  The
removal of inorganic substances is treated in Process Design.

Several carbon adsorption plants are in successful full-scale
operation for tertiary treatment of municipal wastes.  Perhaps
the prime example is the plant at South Lake Tahoe, California,
which includes seven carbon contactors operating upflow in
parallel.   Figure A-14 is an illustration of a section
through a contactor.  The design provides for the semi-continuous
or "pulsed" carbon removal and replacement.  Figure  A-15  is  a
flow diagram of the regeneration system.

A typical analysis of the efficiency of the process is given in
Table A-72.

The carbon adsorption unit treating herbicide plant wastes
mentioned under Process Economics is operated by the Chipman
Division of Rodia Corporation.A~39  Table  A-73  is  an  analysis
of the waste treated by that unit.

The effluent standard which has been successfully met is 1
mg/1 phenol.

Figure A-16 is a flow diagram of the Chipman adsorption
unit.

Full scale carbon adsorption units have also been successfully
used for petroleum and petrochemical wastes.A~34   flow dia-
grams generally are minor variations of the ones previously
shown.

AMMONIA STRIPPING PROCESS DESCRIPTORS

Ammonia can be readily removed from alkaline aqueous wastes
by stripping with steam at atmospheric pressure.  The waste
stream, at or near its boiling point, is introduced at the top
of a packed or bubble cap tray type column and contacted counter-
currently with steam.  Due to its high partial pressure over
alkaline solutions, ammonia is removed from the waste and con-
centrated in the vapor phase.  The concentrated ammonia is
condensed and reclaimed for sale, and liquid effluents from  a
properly designed steam stripping column will be essentially
ammonia free.
                             A-476
-------
         FIGURE  A-14
    SOUTH LAKE TAHOE  UNIT
SECTION  THROUGH CARBON  COLUMN
     CARBON, INFLOW
                           SURFACE OF CARBOI
                                OUTLET SCREENS(S)
                                PRESSURE VESSEL
                                TANGENTIAL NOZZLES(
                         rMET SCREENS(8)
    A R B 0 f-1  OUTFLOW
           A-477
-------
        FIGURE  A-15
            STPUD
CARBON REGENERATION SYSTEM
A-3 3
                         SPENT CARBON FROM
                         CARBON COLUMNS
                         REGENERATED CARBON
                         TO CARBON COLUMNS
            A-478
-------
                         TABLE A-72
                                   A-3 3
                      SOUTH LAKE TAHOE
       A COMPARISON OF COD AND MBAS REMOVAL EFFICIENCY
        BETWEEN FIRST CYCLE CC-5 AND THIRD CYCLE CC-6
Carbon Column

Regeneration Period

Regeneration Cycle

Total Flow in Period

Total Pounds of Carbon
  Regenerated in Period
               Ibs reg.
Carbon Dosage     MG

Chemical Ozygen Demand
  Influent gm/1
  Effluent mg/1
  Percent Removal
  Ibs In
  Ibs Removed
  Ibs In/lb Carbon Reg.
  Ibs Removed/lb Carbon Reg.

Methylene Blue Active Substances
  Influent mg/1
  Effluent mg/1
  Percent Removal
  Ibs In
  Ibs Removed
  Ibs In/lb Carbon Reg.
  Ibs Removed/lb Carbon Reg.
  CC-5         CC-6

  11/15/68 to  10/5/69

  First        Third

  202.2        189.3
40960
  202
   18
    9
   47
30720
14695
     .75
     .36
     .55
     .13
   76.4
  927
  708
     .023
     .017
41100
  217
   18.2
    8.0
   55.0
28693
16084
     .70
     .39
     .55
     .13
   76.4
  869
  663
     .021
     .016
                             A-479
-------
                     TABLE A-73A 33

                 CHIPMAN HERBICIDE PLANT
                 ANALYSIS OF WASTEWATER*
           Component


Phenol and Cresol

Chlorophenols and Chlorocresols

Chlorophenoxyacetic Acids

Alcohols (Primarily Octyl)

Chlorides (as NaCl)

Sulfates (as Na2SO4)

Biochemical Oxygen Demand (BOD)

Chemical Oxygen Demand (COD)

Total Solids

Suspended Solids
Concentration
   (mg/1)
       10

      100

      100

    1,000

   50,000

    8,000

    2,000

    3,600

   62,000

       10
*pH 0.5
                        A-480
-------
      o:
      Q
     I
     <=C
•—    o
 I     •—>
-------
                      Operating Principle

The removal of ammonium ions and dissolved ammonia from aqueous
solutions by stripping is controlled by 1) the equilibrium
oetween the ammonia and ammonium ions in the liquid phase and
2)  by the partial pressure of ammonia gas over the solution.
The equations governing 1 above are:

     NH4  +  +OH~  =  NH^  + H~0


     KMH  =  LIH4 J L°H J = 1.8  x 10~5  at  25°C A~'13
     H2o = H  -f OH"
          Kw -  |H' I IOH  I - 10~14 at
          [OH J -  JOH+] = 10~7 at neutrality

     Therefore  NH.
               L-£J.   = 5.5 x 10-J at 25°C
It is apparent  from the above equations  that  the waste  solution
must be stripped on the alkaline  side  or at least  at  neutral
pH.  As ammonia is removed  from solution the  pH will  fall.
Therefore, depending on the  total ammonia concentration,  the
waste must have a high initial alkalinity or  have  buffering
capacity  (e.g.,  carbonate-bicarbonate or  phosphate  systems) .

For dilute ammonia solutions the  vapor liquid equilibria  is
described by Henry's Law:

           Y =  MX
     where Y -  mole fraction NH3  in the  vapor
           X =  mole fraction NH3  in the  liquid
           M =  Henry's constant,  a function of temper-
                ature, shown  in Figure  A-17. A~1*1*

By extrapolation of Figure  A-17,  M is  found  to be 20 at
212°F, the conditions of  saturated steam stripping.

The ammonia-rich vapor exiting from the  top of the stripping
tower would be  condensed  to  an aqueous ammonia liquid solution.
The partial pressure ammonia in an aqueous ammonia solution at
ambient temperature and pressure  is such that the  maximum con-
centration would be about 30 percent ammonia.   In  order to
                           A-482
-------
   1.5
   1.0
O
O

s:
<

oo
   0.5
                         FIGURE A-17


                   HENRY'S  LAW CONSTANT AS

                  A FUNCTION OF TEMPERATURE
             D WESTBERG AND GUSTAFFSON


             O PERRY'S HANDBOOK
                               ALOG(Y) - 0.02423 * X - 1.9523
     0
20      40       60      80     100


              IEMPERATURE, °F
120
140
                              A-483
-------
assure a uniform ammonia concentration in the product provision
should be made for a "reflux" stream from the vapor condensor.
In the case of a liquid feed which is rather low in ammoniacal
nitrogen, a lower vapor flow rate (V) to liquid flow rate (L)
ratio, V/L, would be required to maintain a constant overhead
concentration.  At the same time a larger contact depth would
be necessary  to effect the desired separation.  These problems
can be minimized by refluxing part of the condensed ammonia
stream.  The  ratio V/L within the column can be maintained
above a predetermined minimum.  Reflux has the disadvantage of
increasing steam requirements.

                     Process Applicability

This discussion has been directed toward treatment of ammonia
bearing wastes.  Much of the equipment and the same general
process could be used, however, to remove various volatile and
organic contaminants.  In place of condensing the overhead (any
reflux would  require condensation), the vapor would be routed
to the incinerator for combustion.  Application of the stripper
for organic contaminant removal would require that the Henry's
Law constant  for the specific system involved, contaminant and
water, must be larger than unity at 212°F and ambient pressure.
The larger Henry's constant the better the potential separation
and process economics.  Since the optimum feed point along the
length of the column is determined by Henry's constant and the
reflux ratio, using a column designed for ammonia removal may
result in less than the optimum system for organic removal.
Introduction  of several possible feed points into the stripping
column would provide flexibility.

                       Process Economics

The major factors which determine the economics of an ammonia
steam stripping operation are:  1) expected waste liquid flow
to be treated, 2) expected range of ammoniacal nitrogen concen-
tration, and  3) maximum allowable ammoniacal nitrogen in the
tower bottoms.  The diameter of the tower, size of process
lines, pumps, tanks, and other units are a direct function of
the waste liquid flow rate.  The steam flow rate and conse-
quently the condenser size and cooling water flow to the con-
denser are also direct functions of the liquid flow rate.  The
height of the tower and reflux ratios are direct functions of
the difference between the influent nitrogen concentration and
the bottoms nitrogen concentration.  Since the steam demand
and condenser duty are dependent upon the reflux ratio, they
are also functions of difference between input and bottoms
ammonia concentration.  The local market for 30 percent ammonia
nitrogen will also affect the economics.  If the product is
salable, part of the costs of removing ammonia from the waste
                          A-484
-------
would be returned.  If the 30 percent ammonia has to be shipped
to a market or given away, the net cost of ammonia removal is
increased.

Some of the energy costs could be reduced by installing a heat
exchanger between the feed and tower bottom steam to preheat
the feed, but since this would increase capital and maintenance
costs, it would not be justified for feed flow rates below a par-
ticular value.

     Example 1:  Coke ProductionA~"6' A~"7

In producing coke, the volatile components of coal are driven
off in ovens, then treated with a water wash.  Among the volatile
components thus separated from coal into an aqueous solution are
ammonia, phenols, and cyanides.  This solution is sent to an
ammonia still such as the one shown in Figure A-18.  The
approximate composition of this solution before and after strip-
ping is shown in Table A-74.  Because of the hiqh ammoniacal
nitrogen concentration, lime is introduced to drive the reaction
equilibrium to ammonia gas.  The lime addition results in the
"lime leg" and "fixed leg".  The dissolved NH3 is removed in the
free still area above the lime leg and the NH4+ is converted to
NH3 in the lime leg.  The high pH solution at the bottom of the
lime leg overflows into the fixed leg where the remaining NH-, is
stripped.  An important factor is the low removal of cyanides
and phenols, due to the lower vapor pressures for these compo-
nents brought about by the high pH of the solution.

     Example 2:  Ammonia Removal from Low Level Radioactive
                 Wastes

Ammonia and organic removal prior to ion exchange treatment of
radioactive wastes was successfully performed on a small scale
at Hanford, Washington.  Organic removal avoided "fouling" of
the ion exchange resins, whereas ammonium ion removal greatly
reduced the competition for sites on the cation resin and
allowed a much higher loading of the radioactive cations before
breakthrough.  Figure A-19 is a flow diagram of the total
system and Table A-75 summarizes the performance of the steam
stripper.  The boil-off rate, or fraction of bottoms converted
to steam, was 15 percent.
                               A-485
-------
                          FIGURE  A-18


                  DIAGRAM OF  AN AMMONIA STILL
              LIQUOR INLET
           (AMMONIA SOLUTION)*
             LIQUID DIRECTION
             GASEOUS DIRECTION
AMMONIA GAS
TO SATURATOR
TO WASTE*"
                                                   MILK OF
                                                  "LIME IN LEI
                                               - STEAM
                          A- 4 8 6
-------
CTv
 I
car
     
n!
cfi
C
o
-a

5
U




(U
-*->
Is

•d S
CO £n
i-l 3

II
S 6
a a
a a.
o o
CM iO
cu
> en
£ 0!
0 0 5
- a c.
C O
_„ OJ r-( 3
j^ txo i3 a,
*5 (25
^^^^^^H
C C C C G C!
-— . -— -, ^^ ^— -—- ~^~
CJ U U U CJ U
3. 3. 3. 3. 3. 3
•^ CN CO CO CN] i_O
1 1 1 1 1 1
o o o o o o

[- «D -^
Q CO O ^ LO
QJ ' I i i i i OD
i/) U OS U N'i,
                                           A-487
-------
                     TABLE A-74A~"8
         APPROXIMATE COMPOSITION OF CRUDE  LIQUORS
              TO AND FROM THE AMMONIA  STILL
    Liquor
To Ammonia Still
From Ammonia Still,
  in plant having
  no dephenolizer
Total ammonia
Free ammonia
Fixed ammonia
Cyanide, as HCN
Chloride
Sulfate
Phenols
pH
BOD
7000
4000
3000
20- 100
1100-6000
150-1000
400-3000
-
—
0.04- 2.
0
0
10
1100
150
400
9
2000
0.
2.
- 100
-5000
-1000
-2500
- 12.
-4000
5
04
5




c:

  Results expressed  as mg/liter,  except pH.
                    TABLE A-75A~"9
    CONCENTRATIONS OF TRIBUTYL PHOSPHATE, HYDROCARBON
    DILUENT, AND AMMONIA IN FEED AND STRIPPER BOTTOMS
                                    Concentration, mg/liter
                                   Feed     Stripper Bottoms
Tributyl Phosphate
Hydrocarbon Diluent
Ammonia
               24-65
                5-23
               16-22
      0.5 - 1.2
      1.0 - 2.2
      0.1 - 0.8
                          A-488
-------
                         APPENDIX L
                TRANSPORTATION OF WASTES FOR
                   PROCESSING AND DISPOSAL
In some instances volume reduction will be necessary before
wastes are shipped from a generation site.  Solids content will
be increased to the maximum extent consistent with a trade-off
of volume reduction costs with transportation costs.  Into this
volume reduction-transportation balance must be factored safety
considerations for handling and shipping the wastes, the expected
frequency of spills, and the projected costs for spill cleanup.
The complete transportation system is depicted by Figure A-20.

WASTE CLASSIFICATION

The waste streams may be classified into four types according
to the general physical characteristics which determine the
waste stream's handling and transportation requirements:

     •  Liquid

     •  Slurry/sludge

     •  Mud

     •  Solids

        1. Free-flowing (granular)

        2. Irregular bulk wastes

The solids contents for the first four classifications are
approximately as follows:  liquids, 0-3 percent; slurry/sludge,
10-40 percent; mud, 60-90 percent; and solids, 100 percent.

STORAGE METHODS

Anticipated modes of waste storage at the waste generation
source and/or the processing facility include:

     •  Lagoons

     •  Pits  (open or closed)

     •  Barrels  (drums)
                            A-489
-------
                                     U.I
                                     o
                                     <
                                     CC
                                        o
                                      02
                                     CO
                                                  DC
                                                  CL
                                     00
                                     
-------
     •  Tanks

        1. Stationary

        2. Motor vehicle exchange

        3. Rail car exchange

     •  Solid waste containers

        1. Motor vehicle exchange

        2. Rail hopper car exchange

The precise storage facilities at either the waste generation
sources or the processing facility will depend on the quantity
and characteristics of the wastes to be stored.

STORAGE FACILITY COSTS

                            Lagoon

Liquid wastes may be stored in a lagoon lined with 0.030-mil
polyethylene covered with about a foot of soil or clay.  Wastes
could be transferred to the lagoon directly from freight tank
cars.  Suitable lined lagoons of one acre and 3-1/2 to 4 feet
deep cost approximately $10,000.A~50

                       Stationary Tanks

Liquid wastes and slurried wastes may be stored in stainless
tanks.  Costs of stainless steel tanks with agitators are given
in Table A-76.

Corrosive liquid wastes may require nonmetallic tanks, typical
costs of which are given in Tables A-77 and A-78.

                             Drums
The cost of drums for storage and shipment of wet or dry wastes
is shown in Table A-79."

A flatbed truck of semi-trailer design with sides, which may be
used for layover storage of drums, costs approximately $6,500.A~51

DEMURRAGE CHARGES FOR RAIL FREIGHT CARS

Tank cars or gondola cars loaded with 55 gallon drums may be used
as storage containers.  Demurrage charges are typically as shown
in Table A-80.
                               A-491
-------
                         TABLE  A-76


           COST OF  STAINLESS  STEEL STORAGE TANKSA~52





      Capacity, Gallons                Cost,  Dollars
1
5
10
20
,000
,000
,000
,000
7,
12,
24,
32,
300
000
000
000
                         TABLE A-7 7


                COST OF POLYETHYLENE TANKSA~52
     Capacity,  Gallons                Cost  L;olicirs
(Flat bottom,  no agitation)


            1,000                           626


            3,000                           806


            5,200                         1,350
                          A-492
-------
                           TABLE A-78

          COST OF FIBERGLASS-REINFORCED PLASTIC TANKSA~52




       Capacity,  Gallons                Cost, Dollars
1,010
3,110
5,000
10,355
20,100
30,215
959
1,792
2,456
3,318
5,202
7,092
                           TABLE A-79

                    COST OF SHIPPING DRUMSA~53




             Type                    Unit cost, Dollars


New polyethylene-lined drums
(55-gal, snap-on ring sealed)              33.00

Used polyethylene-lined drums              15.00

Unlined drums                               9.75

Rubber lined drums                         gO.OO^11^
                            A-493
-------
                           TABLE A-80

                 DEMURRAGE COSTS FOR RAIL CARS




       Time on Site                    Fee, Dollars per Day


First 2 days (after 7 a.m..)                     0

Next 4 days                                    10

Next 2 days                                    20

Additional days                                30
Note:  There is no charge for Saturday and Sunday if car is
       on site for less than three days.  There are no charges
       if cars are leased.  The same fees would be applicable
       to a hopper car for dry wastes.
                           TABLE A-81

                  COSTS OF SEMI-TRAILER TANKS A~ 54




Material                  316 SS     304 SS     Carbon Steel

Cost of unit, dollars     15,732     13,090        8,225

Federal tax, dollars       1,122      1,100          617

Total cost, dollars*      16,864     14,100        8,842


* Sales tax additional.
                            A-494
-------
                 Motor Vehicle Units (Liquid)

Motor vehicle exchange tanks may be used for temporary storage.
Costs for 5,000 gallon units are shown in Table A-81.

               Motor Vehicle Units  (pry Solids)

Dry irregular solid wastes will be delivered in containers and
stored in sheltered storage areas.  The containers will be used
as temporary storage units.  Typical equipment costs are shown
in Table A-82.

A wide range of compacting units are available, from household
size to large paper balers.  Cost of one compactor which may be
used for solid waste handling is as follows:

     25 HP - (bales formed are 48 inches by
             48 inches by  30 inches)               $8,250A~55

LOADING AND UNLOADING OF WASTES

                            Methods

Choice of loading and unloading method(s) at either the source
or the primary facility will depend upon the type of wastes
being handled.  A representative list of loading/unloading
alternatives could include:

     •  gravity flow (for liquids and light slurries);

     •  pump (centrifugal for liquids and sludges/slurries);

     •  fork lift  (with drum handling and front loader attach-
        ment) ;

     •  screw, bucket,  or belt conveyors (for mud only);

     •  tank, flatbed,  or containerized tailgate dump motor
        vehicle exchange;

     •  tank, drum loaded gondola car,  or hopper rail car
        exchange; and

     •  gas  cylinder hand truck.

The loading and unloading method used will depend on the quan-
tities and characteristics of the wastes, whether wet or dry.

Gravity feed will be used for transferring liquids and light
slurries from stationary holding tanks to mobile tanks or drums
                            A-495
-------
                         TABLE A-82

        COSTS FOR SHIPPING UNITS AND STORAGE FACILITY
                    FOR DRY SOLID WASTES
          Unit

Semitrailer tail end dump truck
(38 feet long - 50 cubic yards
capacity)

Containers with bottom discharge
doors (300 cubic feet capacity -
crane required for discharge)
Additional equipment which might be used by the
generator facility is listed below:
                          Cost, Dollars
                             12,000A~56
Solid waste compactor
(for use with con-
tainers below)
        Size of Unit

         (15 hp unit)
         (30 hp unit)
Containers for
above units
Capacity, Cubic Yards^

           6

           8

          10

          20 1/2

          22
Cost, Dollar^"57

  11,175
  12,970
Cost, DollarsA 57

     640

     740

   1,230

   3,635

   3,740
                        A-496
-------
over short distances.  Fast transfers can be made by this method
with a minimum of layover time for the receiver.

Pumps may replace the gravity feed when necessary with the
same benefits of fast transfer.  When small and variable quan-
tities of liquids, slurries/sludges, or mud are generated over
a lengthy period, the wastes may be stored in a drum and loaded
onto the receiver as required.

Conveyors will be used only for muds, salt crystals, or grain-
like solid wastes.  The conveyor selected will depend on the
type of solids and the length of the run.

Motor vehicle exchanges are a common practice where semi-trailers
are left at the site for loading or unloading.  This type of
operation may be used where docking space and storage space are
available and convenience is desired.  This system is universally
practiced for shipment of irregularly shaped dry solid wastes.

Rail car exchange is comparable to motor vehicle exchange except
that demurrage charges are involved and large regular volumes
would be shipped.

                            Costs

Gravity flow is the simplest way to move liquids or slurries.
No costs are involved in these studies since the liquids are
brought to sufficient height for gravity flow by the generating
unit.

Pumps vary in cost according to height of head and capacity.
Several stainless steel pump costs are listed in Table A-83.

A heavy duty fork lift truck with electric drive, battery charger,
and barrel handling attachment costs about $12,000.  This unit
would load, unload, and tip the barrel to empty contents.  The
cost of a similar unit with front loading bucket for solid
waste handling would be about the same.

Conveyors would be used to transport muds from thickeners or
lagoons.  Typical conveyor costs are shown in Table A-84.

TRANSPORTATION OF WASTES

                Containers for Transportation

The types of containers to be considered for waste transportation
include the following:
                           A-497
-------
                        TABLE A-83




           COSTS OF STAINLESS STEEL CENTRIFUGAL PUMPSA~5 8
Capacity, Gallons
per Minute
30
50
100
200
400
500



Type of
Conveyor
Screw A- s 9
BeltA-60
BucketA~6 1
Head, Feet
30
30
30 1
30 5
30 7
30 7
TABLE A- 8 4
CONVEYORS FOR HANDLING

Capacity
Tons per Hour
55 (sand)
HP
1/2
3/4
1/2

1/2
1/2

MUDS



50 (100 pounds per cubic
foot of material
14 (100 pounds per cubic
foot of material
Cost, Dollars
635
687
1,035
1,170
1,860
2,040


Installed
Cost
Dollars*
2,400
2,755
2,940
*For 30 foot length
                        A-498
-------
      o  barrels  (drums);

      •  motor vehicle and rail car exchange tanks;  and

      •  open body unit motor vehicle tail dump and  rail hopper
         cars.

 Construction materials for the containers will be dictated
 primarily by the corrosiveness of the wastes to be  transported.
 Specifying the use of one material will eliminate the need for
 segregation of containers, thereby reducing the chance of acci-
 dents.  Corrosive wastes  included as candidates for disposal at
 a centralized facility are mineral acids and inorganic salts.
 Reinforced fiberglass or  polyethylene, either as the primary
 construction material or  as a liner, are the recommended container
 materials for all types of inorganic and organic wastes except
 those containing hydrofluoric acid.  For these, containers
 lined with epoxy, phenolic resin, or butyl rubber are recommended.

 Polyethylene-lined 55 gallon snap-on ring-sealed steel drums
 will be used for all classes of wastes, wet or dry.  The lined
 drums will give  the strength and corrosion resistance required
 for most wastes.  The containers will be used exclusively for
 transporting toxic wastes and will be identified with a specially
 designed label so that they will not be misused.

 Tanks will be used for liquids and light slurries.   The motor
 vehicle tank will be a one compartment unit with a  capacity of
 5,000 gallons.  It will have a hot rolled steel or  stainless
 steel body, depending on  the corrosive properties of the waste
 shipment.

 The rail tank cars, which will be one compartment units with
 10,000 to 15,000 gallons  capacity, will be available in a vari-
 ety of tank materials. The tanks may be interior lined, nickel
 clad, or stainless steel  clad and insulated and heated.  Such
 tank cars can be leased or rented from railroads.

 The tail dump motor vehicle would be a containerized unit which
 could be picked  up by the transporter.  These units would be
 constructed of hot rolled steel.  The rail counterpart of the
 tail dump truck  would be  a sealed and bottom dumped hopper car.
 This unit would  be constructed of hot rolled steel  and would
 handle dry solid wastes.

                      Transportation Modes

The two principal methods of transporting wastes to  the storage/
disposal site will be:  motor vehicles, both flatbed  (for drums
                            A-499
-------
ui wastes)  and tank; and rail  ca.rir..  ooth flatbed (gondola cars)
and tank.

The mode of transportation used will be dictated by availabil-
ity, flexibility for waste collection, safety requirements, and
waste quantity to be transported.

A substantial amount of wastes will be shipped via flatbed motor
vehicle in lined 55-gallon drums.  This mode of transportation
is relatively safe.  In the case of an accident, smaller quanti-
ties would need recovery after spillage.  Five hundred gallons
of wastes may be shipped in a standard load, but loads as high
as 700 gallons could be shipped on special vehicles.

Rail cars will be used for exceptionally large loads.

                    Size of Transporters

The unit size of transporters will be determined by the quanti-
ties of wastes regularly collected in each trip.  Typical waste
quantity volume ranges to be considered for sizing a transporter
unit might be up to 5,000 gallons,  5,000 to 10,000  gallons,  and
10,000 to 15,000 gallons.

A motor vehicle can transport 50,000 pounds, or approximately
one hundred 55-gallon drums.  Compartments of tank freight cars
or individually lashed down tanks can hold 5,000 to 10,000
gallons.  A standard tank freight car can hold 10,000 to 15,000
gallons.

A substantial portion of the wastes will most likely be shipped
in barrels or drums via motor freight.  Tanks will be used for
liquids when there is regular need for transporting large quan-
tities.  Rail transport will probably be needed for exceptionally
large loads.  A flatbed rail car can transport as many as two
hundred fifty 55-qallon drums.

                     Transportation Costs

Freight costs for shipping wet or dry wastes via motor vehicle
in 55-gallon drums are listed in Table A-85 and for shipping
liquids, slurries, or sludges in tank trucks in Table A-86.

The cost for shipping dry or wet waste materials by rail is
about the same for each.  For a fixed rate, however, a specifi-
cation must be submitted to the railroad office for review.
Estimates of cost for waste shipment are given in Table A-87.
The type of car used  (flatbed, gondola, tank, hopper) has little
effect on the rate charges.
                            A-500
-------
                        TABLE A-85
    MOTOR VEHICLE FREIGHT RATES FOR SHIPMENTS IN DRUMSA~62
              Rate, Dollars per Hundredweight
Load Size
 300
Distance, miles

 200      100       50
Full Load
40,000-44,000 pounds
1.10
1.10
0.80
0.75
Half Load
20,000 pounds
1.20
1.10
0.90
0.83
Single Drum
500 pounds
4.07
4.00
3.90
3.85
Extras
Thirty dollars per stop and no
more than three stops per load.
An additional cost of $0.70 per
mile is assessed for deviations
from a normal straight line route.
                          A-501
-------
                         TABLE A-86
    MOTOR VEHICLE FREIGHT RATES FOR SHIPMENTS IN TANKSA  6 3
             Rate, Dollars per Hundredweight




                                     Distance, miles

Load Size                    300      200      100        50
>32,000 pounds              1.29     0.90     0.52      0.35


>40,000 pounds              1.09     0.77     0.45      0.30
Extras                      Extra charges are made for mixed
                            loads at $25 per stop and for
                            attaching and detaching hoses
                            and loading and unloading at
                            $12 per hour.
                         TABLE A-87


 RAILROAD FREIGHT RATES FOR SHIPMENT OF HAZARDOUS WASTESA~6!*


            Rate, Dollars per Hundredweight





                                     Distance, miles

Load Size                    300      200      100        50
Approximately               1.47     1.21     1.00        .75
24,000 pounds

110,000 pounds              1.31     1.08      .89        .66
                        A-502
-------
SHIPPING REGULATIONS

The quantity of toxic materials which can be shipped in any one
container is regulated by the U.S. Department of Transportation.
Table A-88 lists some of the quantities of toxic materials in
their commercial forms.

Some of these materials are shipped in tank lots of 10,000 gal-
lons or more.  They are listed in Table A-89.

SPILLAGE DETECTION METHODS

Prevention, control, and detection of spillage of toxic wastes
during transit is a significant concern.  Prevention and control
would be handled primarily on the basis of selection of con-
tainers, size of containers, and rate of dispersion after
spillage.

Detection of spillage may be accomplished by either chemical or
physical means.  The criteria for selection of a detecting de-
vice or test are speed of response, reliability, and ruggedness.
The following physical tests may also be used.

     •  Weigh entire shipment

     •  Weigh drum suspected of leaking

     •  Measure liquid level in container  (tank)

     •  Measure conductivity of area where spill has occurred

     •  Measure light transmittance within enclosure

     •  Measure temperature of shipment

'.Two chemical tests which can be used to detect spillage are a
spot test for specific waste spillage and a sniff test of the
thermal conductivity of the atmosphere.
                               A-503
-------
                         TABLE A-88

        DEPARTMENT OF TRANSPORTATION CODE REGULATIONS
    FOR SHIPMENT OF HAZARDOUS MATERIALS VIA TRUCK OR RAILA~65
           Compound
  Shipment Size (maximum
     in one container)
Acrolein

Aldrin

Ammonium chromate

Ammonium dichromate

Antimony pentafluoride

Arsenic trichloride

Arsenic trioxide

Bromine pentafluoride

Calcium arsenate

Calcium arsenite

Calcium cyanide

Chlordane

Chlorinated aromatics

Chlorine

Chlorine trifluoride

Chromic acid

Copper arsenate

Copper Cyanide

Cuprous cyanide

Dinitrotoluene
            i qt

200 Ibs dry or 1 qt liquid

          100 Ibs

          100 Ibs

      25 Ibs or 1 qt

          55 gals

          200 Ibs

          150 Ibs

          200 Ibs

          200 Ibs

          100 Ibs

            T.C.

            T.C.

          150 Ibs.

          100 Ibs

    100 Ibs or 1 gal

          200 Ibs

          450 Ibs

          450 Ibs

 tank car (nonrestrictive)
                         A-504
-------
                     TABLE A-88  (Continued)
           Compound
  Shipment Size  (maximum
     in one container)
Fluorine

Lead arsenate

Lead arsenite

Lead cyanide

Manganese arsenate

Methyl bromide

Methyl chloride

Methyl parathion

Mercuric chloride

Mercuric cyanide

Mercuric diammonium chloride

Mercuric sulfate

Mercury

Nickel carbonyl

Nickel cyanide

Parathion

Phosgene

Potassium arsenite

Potassium cyanide

Silver cyanide

Sodium arsenate

Sodium arsenite
          6 Ibs

          200 Ibs

          200 Ibs

          225 Ibs

          200 Ibs

          55 gal

          300 Ibs

          100 Ibs (27%)

          200 Ibs

          200 Ibs

          200 Ibs

          200 Ibs

          55 gals

          Cylinders

          200 Ibs

200 Ibs dry or 1 qt liquid

Cylinders (not accepted)

          200 Ibs

200 Ibs dry or 55 gal wet

          225 Ibs

          220 Ibs

          55 gals
                              A-505
-------
                   TABLE A-88 (Continued)



          Compound                   Shipment Size (maximum
                                        in one container)

Sodium bichromate

Sodium chromate

Sodium cyanide                     200 Ibs dry or 55 gal wet

Zinc arsenate                                200 Ibs

Zinc arsenite                                200 Ibs

Zinc cyanide                                 25 Ibs
                          TABLE  A-8 9

        HAZARDOUS MATERIALS  SHIPPED IN TANK  CAR  LOTS
                 OF  10,000 GALLONS  OR MOREA~66
      Acrolein                  Chlorinated biphenyls

      Dinitrotoluene            Hydrocyanic acid,
                                stabilized
      Aldrin solution
                                Potassium cyanide,
      Antimony pentachloride    liquid

      Arsenic chloride, liquid  Sodium arsenite solution
      Arsenic acid (containing  Sodium bichromate
      not over 0.05% NHO )
                                Sodium cyanide,
      Chlordane                 liquid
                         A-506
-------
                          APPENDIX M


              HAZARDOUS WASTES FACILITIES SITING


PROCEDURE FOR DEVELOPING PARAMETER WEIGHTS

The weighting technique used in assigning relative values to
the site-selection criteria is based on the Delphi Procedure.
In general, this procedure results in a technique which is
systematic in nature, minimizes individual bias, produces con-
sistent comparisons, and aids in the convergence of judgment.
The steps followed in this weighting procedure were:

     •  The details of the weighting procedure were
        explained to the participants.

     •  An explanation of the criterion areas, the
        various parameters involved, and their impor-
        tance in site selection was presented by a repre-
        sentative of each criterion area to the assembled
        group of professional participants.  Essentially
        equal time was allotted to each presentation and
        ensuing questions.

     •  The four criterion areas were ranked by the
        individual participants in the following manner.
        A value of 1 was assigned to the category the
        individual considered the most important.

     •  The criterion area considered second most impor-
        tant was compared to the first to determine how
        much the second was worth compared to the first.
        This value was expressed as a decimal (0< X <_!) .

     •  These pairwise comparisons were continued until
        all four criterion areas had been evaluated
        (compared second with first, third with second,
        and fourth with third).

     •  The evaluation cards were collected and the per-
        centages were calculated and expressed over a
        common denominator.  The averages over all indi-
        viduals in the weighting process were calculated.

     •  The individuals were notified of the results of
        the weighting procedure.  The information included
        the group mean and variance and other pertinent
        information.
                            A-507
-------
     «  The same procedure, without steps 1 and 2, was
        repeated with the same group of individuals to
        increase the reliability of the results.  The
        second iteration results showed little change from
        the first.

An essentially identical procedure was followed by the profes-
sional participants in the earth sciences evaluations in arriving
at weightings for the four major subcriterion areas of geology,
hydrology, climatology, and soils.

Additional information on the background and application of the
Delphi Method is presented in the following reports:

     Dakley, N.C., "The Delphi Method:  An Experimental
     Study of Group Opinion," The Rand Corporation,
     RM-5888-PR (June 1969).

     Pill, Jrui, "The Delphi Method:  Substance, Context, a
     Critique and an Annotated Bibliography," Socio-Economic
     Planning Science, 5, pp 57-71  (1971).
                             A-508
-------
                            TABLE A-90

                   SITE  SELECTION CRITERIA AREAS
WASTE CONSIDERATIONS

A.  GEOGRAPHIC DISTRIBUTION  AND DISPERSION OF SOURCES
B.  INTRINSIC HAZARD  -  TYPE  AND SEVERITY
C.  VOLUME OR OTHER CAPACITY FACTOR
D.  UNIQUENESS AND FREQUENCY
E.  REGULATORY STATUS

PROCESS CONSIDERATIONS

A.  BASIC APPROACH

    1.  RECOVER AND RECYCLE
    2.  INERT AND DISPERSE
    3.  PACKAGE AND STORE

B.  ANTICIPATED SITE  EFFLUENTS  - AIR,  WATER,  SOLID
C.  HAZARD INVENTORY
D.  UTILITY NEEDS.

GEOLOGIC CONSIDERATIONS

A.  ROCK TYPE  [RELATED  TO ULTIMATE DISPOSAL/STORAGE METHOD(S)]

    1.  STRATIGRAPHIC SEQUENCE
    2.  STRUCTURAL RELATIONSHIPS
    3.  MINERAL POTENTIAL  (ECONOMIC)
    4.  HISTORICAL POTENTIAL (PALEONTOLOGICAL AND ARCHEOLOGICAL)

B.  GEOLOGIC HAZARDS

    1.  EARTHQUAKE RISK
    2.  TECTONICS  (SUBSIDENCE,  FAULTS  AND FOLDS)
    3.  LANDSLIDE POTENTIAL
    4.  VOLCANIC POTENTIAL

PHYSIOGRAPHIC CONSIDERATIONS

A.  TOPOGRAPHIC

    1.  ELEVATION
    2.  SLOPE
    3.  ACCESSIBILITY
                            A-509
-------
                      TABLE  A-90  (continued)


B.  SOIL TYPES

    1.  PRIMARY DISPOSAL  (STORAGE  OF ULTIMATE WASTE PRODUCT)

        a.  ERODABILITY  (TEXTURE,  STRUCTURE,  PERMEABILITY)
        b.  DEPTH TO BEDROCK AND GROUNDWATER
        c.  SORPTION  (SUITABILITY/CAPACITY FOR HAZARDOUS
            MATERIALS)

    2.  SECONDARY DISPOSAL  (LOW-LEVEL OR DILUTE PROCESS
        WASTE STREAMS)

        a.  DEPTH TO BEDROCK AND GROUNDWATER
        b.  SORPTION  (SUITABILITY/CAPACITY)
        c.  LEACHING POTENTIAL

    3.  ACCIDENTAL SPILLS OF PROCESS FEED OR WASTE STREAMS

        a.  SOIL TEXTURE AND STRUCTURE
        b.  DEPTH TO BEDROCK AND GROUNDWATER

    4.  ENGINEERING LIMITATIONS

HYDROGRAPHY

A.  WATERWAYS
B.  FLOODPLAINS AND SWAMPS
C.  TIDAL BASINS
D.  SEICHE POTENTIAL
E.  TSUNAMI POTENTIAL

HYDROLOGY

A.  CONFINED/UNCONFINED AQUIFERS

    1.  DEPTH
    2.  EXTENT
    3.  POROSITY, PERMEABILITY, TRANSMISSIVITY
    4.  CHEMISTRY
    5.  PRESENT AND FUTURE USES

CLIMATOLOGICAL CONSIDERATIONS

A.  DIFFUSION CHARACTERISTICS
B.  EXTREME CONDITIONS
                             A-510
-------
                     TABLE A-90  (continued)
    1.  FREQUENCY AND SEVERITY OF  HURRICANES,  TORNADOS,
        THUNDERSTORMS, OTHER LOCAL STORMS  AND  WINDS

C.  POTENTIAL EVAPORATION
D.  SEAONSAL CLIMATOLOGY

    1.  AIR TEMPERATURE
    2.  RELATIVE HUMIDITY
    3.  FOG FREQUENCY
    4.  SOLAR RADIATION

TRANSPORTATION CONSIDERATIONS

A.  ECONOMICS AND SAFETY  (RISK) WITH  RESPECT TO

    1.  CARRIER  (MODE)
    2.  DISTANCE
    3.  ROUTING
    4.  MODAL SPLITS
    5.  TYPE OF MATERIAL TRANSPORTED
    6.  SOURCE OF WASTE PRODUCTION
    7.  VOLUME OF MATERIAL TRANSPORTED

B.  ACCESSIBILITY OF TRANSPORTATION

    1.  RAIL

        a.  MAINLINE
        b.  SECONDARY

    2.  HIGHWAY

        a.  INTERSTATE AND MAJOR HIGHWAYS
        b.  SECONDARY ROADS

    3.  WATERWAY ACCESS

ACCESSIBILITY OF UTILITIES

A.  ELECTRICAL POWER
B.  FUELS
C.  WATER
                            A-511
-------
                       TABLE A-90 (continued)
WATER, LAND AND AIR  RESOURCES  CONSIDERATIONS

A.  LAND OWNERSHIP AND  PRIOR ASSOCIATION WITH HAZARDOUS WASTES
B.  SECURITY AND PUBLIC ACCESS
C.  REGULATORY STATUS
D.  LIVESTOCK AND GRAZING
E.  CROPS AND TIMBER
F.  INDUSTRIAL

    1.  MINING
    2.  LIGHT AND HEAVY MANUFACTURING
    3.  COMMERCIAL

G.  RECREATIONAL
H.  AIR TRANSPORTATION  - CORRIDORS AND AIRPORTS
I.  WATER

    1.  IRRIGATION
    2.  COMMERCIAL AND  DOMESTIC WATER SUPPLY
    3.  SURFACE WATER TRANSPORTATION

J.  UNIQUE NATURAL OR HISTORICAL AREAS

HUMAN ENVIRONMENT CONSIDERATIONS

A.  DEMOGRAPHY

    1.  POPULATION - DISTRIBUTION AND DENSITY

B.  PUBLIC ACCEPTANCE
C.  AESTHETICS

    1.  UNIQUE LANDFORMS,  FAUNA OR FLORA COMPOSITIONS
    2.  FREQUENCY AND PROXIMITY OF UNIQUE AREAS TO VIEW

BIOLOGICAL CONSIDERATIONS

A.  BIRDS AND WILDFOWL

    1.  NATIONAL, STATE AND LOCAL REFUGES
    2.  MAJOR FLYWAYS INCLUDING SPECIES AND DENSITIES
    3.  RARE AND ENDANGERED SPECIES AREAS

B.  TERRESTRIAL WILDLIFE

    1.  NATIONAL, STATE AND LOCAL REFUGES
                             A-512
-------
                     TABLE A-90  (continued)


    2.  ECOSYSTEM QUALITY AND STABILITY

        a.  SPECIES DIVERSITY AND DENSITY  OF PRODUCERS,
            HERBIVORES AND CARNIVORES

    3.  RARE AND ENDANGERED SPECIES AREAS

C.  AQUATIC LIFE

    1.  NATIONAL, STATE AND LOCAL REFUGES
    2.  ECOSYSTEM QUALITY AND STABILITY

        a.  SPECIES DIVERSITY AND DENSITIES OF PRODUCERS,
            BENTHOS AND FISH

    3.  RARE AND ENDANGERED SPECIES AREAS
                            A-513
-------
                     TABLE A-91
           EXISTING AND POTENTIAL HAZARDOUS
          WASTE TREATMENT AND DISPOSAL SITES
Existing Sites Operated by Federal Agencies

USAEC

     Hanford Works, Benton County, Washington
     Savannah River Plant, Aiken County, South Carolina
     National Reactor Testing Station, Bingham County, Idaho
     Nevada Test Site, Nye County, Nevada
     Oak Ridge, Anderson County, Tennessee
     Los Alamos Scientific Laboratory, Los Alamos County,
       New Mexico
     Pantex Plant, Randall County, Texas
     Rocky Flats Plant, Jefferson County, Colorado
     Fernald, Butler/Hamilton Counties, Ohio

POD

     Edgewood Arsenal, Maryland
     Pine Bluff Arsenal, Arkansas
     Rocky Mountain Arsenal, Colorado
     Tooele Army Depot, Utah
     Umatilla Army Depot, Oregon
     Anniston Army Depot, Alabama
     Pueblo Army Depot, Colorado
     Newport Army Ammunition Plant, Indiana
     Lexington Bluegrass Army Depot, Kentucky

State Licensed Radioactive Waste

     Morehead, Kentucky
     Beatty, Nevada
     Hanford Works, Washington
     West Valley, New York
     Sheffield, Illinois
                       A-514
-------
                         TABLE A-9 2

       COMMERCIAL RADIOACTIVE WASTE BURIAL SITE CHARACTERISTICS

        Characteristics                           Site
 Background

 Ownership  of  site

 Population -  density in area
 Location re towns  and cities
 Area  of:  (1)  site;  (2)  controlled
    acres
 Communications
 Precipitation (in.)
      Morehead, Kentucky

State of .Kentucky, leased to
   NECO
Rural, sparse  (Maxey Flats)
10 mi northwest of Morehead

(1) 200 (est); (2) 1000  (est)
Fair; state hwy N and S
46/yr (heavy storms)
Site Characteristics

Drainage
Bedrock depth  and materials  (est)

Surficial material  - depth;  types

Groundwater -  depth; slope

Land and water use  downstream

General soil characteristics
Well drained
50-75 ft (?); shale, sandstone,
   siltstone
50-75 ft (?) shale, clay,
   siltstone
35-50 ft ("perched" 2-6 ft);
   erratic
Very little nearby, distant
   (no data)
Very impermeable; good soil
   sorption
Operation - Equipment and Methods

Monitoring instruments and devices
Waste handling machinery

Trenches - (1) dimensions;
    (2) design; (3) water pumped?

Waste handling -  (1) transport by
   company; (2) processing;
    (3) burial procedures
Essentially same as at Beatty
Usual - crane; dozer; fork-
   lifts; etc.
(1) 300 x 50 x depth 20 ft;
(2) usual design, sump;
(3) Yes
(1) and  (2) same as Beatty
   (both NECO);  (3) per
   "Radiation Safety Plan"
   (NECO)
                                A-515
-------
                       TABLE A-92 (continued)

      COMMERCIAL RADIOACTIVE WASTE BURIAL SITE CHARACTERISTICS

       Characteristics                           Site
Background

Ownership of site
Population - density in area
Location re towns and cities
Area of  (1) site; (2) controlled
   acres
Communications
Precipitation (in.)
        Beatty, Nevada

State of Nevada, leased to NECO
Desert, virtually uninhabited
About 12 mi southeast of Beatty
(1) 80; (2) desert, not
   controlled
Good; hwy U.S.95
2.5-5.0/yr
Site Characteristics

Drainage
Bedrock depth and materials (est)

Surficial material - depth; types

Groundwater - depth; slope
Land and water use downstream
General soil characteristics
Adequate
575+ft; various sedimentary
  and metamorphic
^575 ft (?); alluvial clay,
   sand, etc.
275-300 ft; SE^30 ft/mi
Very little, desert conditions
Semi-arid desert; deep soil
Operation - Equipment and Methods

Monitoring instruments and devices

Waste handling machinery

Trenches - (1) dimensions;
    (2) design; (3) water pumped?
Waste handling -  (1) transport by
   company; (2) processing;
   (3) burial procedures
14 survey instrs; film, air
   monitors; etc.
Tank truck; trailer  trucks;
dozer; 35-T crane
(1) 650 x 50 x depth 20 ft;
(2) usual design, i.e., drain
to sump, 4 ft backfill;
(3) no water collected

(1) yes;  (2) liquids solidified;
(3) sp. nu. mat. spaced at
bottom, slit trench  for high-
activity materials
                               A-516
-------
                        TABLE A-92  (continued)

      COMMERCIAL RADIOACTIVE WASTE  BURIAL SITE CHARACTERISTICS

       Characteristics                           Site
Background

Ownership of "site

Population - density in area
Location re towns and cities
Area of  (1) site;  (2) controlled
   acres
Communications
Precipitation  (in.)
  Hanford Works, Washington

State of Washington, leased
   to NECO  •
No residents, inside AEC plant
25 mi north of Richland

(1) 100;  (2) 1000 state owned
Good, AEC Hanford reservation
6-8/yr.
Site Characteristics

Drainage
Bedrock depth and materials  (est)
Surficial material - depth;  types

Ground water - depth; slope
Land and water use downstream
General soil characteristics
Well drained
250-450 ft; basalt
150-350 ft; silty sand, gravel,
   clay
240 ft; N and E * 15-35 ft/mi
Columbia River - all uses
Little precipitation; deep
   dry soil
Operation - Equipment and Methods

Monitoring instruments and devices

Waste handling machinery

Trenches - (1) dimensions;
    (2) design; (3) water pumped?

Waste handling -  (1) transport by
   company; (2) processing;
    (3) burial procedures
As licensed - survey instrs,
   film, counters
Usual - crane, shovel, dozer,
   lifts, etc.
(1) 300 x 60 x depth 25 ft;
(2) usual design;
(3) no water collects in sump
(1) yes, 95%; (2) liquids
   solidified; (3) sp. nu. mat.
   spaced, separate trench for
   ion-exchange resins
                                A-517
-------
                        TABLE A-92  (continued)

      COMMERCIAL RADIOACTIVE WASTE BURIAL SITE CHARACTERISTICS

       Characteristics                           Site
Background

Ownership of site
Population - density in area
Location re towns and cities
Area of  (1) site; (2) controlled
   acres
Communications
Precipitation  (in.)
     West Valley, New York

NYASDA, leased to NFS
Rural, less than 50/sq mi
About 30 mi SW of Buffalo

(1) 10+; (2) 3345 state owned
Good; U.S.  hwy and rwy
40/yr
Site Characteristics

Drainage
Bedrock depth and materials  (est)

Surficial material - depth; types

Groundwater - depth; slope

Land and water use downstream

General soil characteristics
Several creeks
50-75 ft; type bedrock not
   stated
25-35 ft glacial till;
   25-35 ft silty till
Variable; slopes with surface
   drainage
Farming; no domestic surface
   s upply
Slow water movement; good
   sorption
Operation - Equipment and Methods

Monitoring instruments and devices

Waste handling machinery

Trenches - (1) dimensions;
   (2)  design; (3)  water pumped?
Waste handling -  (1) transport by
   company  (2) processing;
   (3) burial procedures
Variety, types, and numbers -
   as licensed
Usual - crane, shovel, dozer,
   lifts, etc.
(1) 700 x 35 x depth 20 ft;
(2) usual design, bottom
   slope  2: 100;  (3) yes

(1) no;  (2) no low-level
   processing; (3) usual,
   trenches filled, mounded
   cover
                             A-518
-------
                        TABLE A-9 2  (continued)

      COMMERCIAL RADIOACTIVE WASTE  BURIAL SITE CHARACTERISTICS

       Characteristics                           Site
Background

Ownership of site

Population - density of area
Location re towns and cities

Area of  (1) site; (2) controlled
   acres
Communications

Precipitation  (in.)

Site Characteristics

Drainage
Bedrock depth and materials (est)

Surficial material - depth; types

Groundwater - depth; slope

Land and water use downstream

General soil characteristics

Operation - Equipment and Methods

Monitoring instruments and devices

Waste handling machinery

Trenches - (1) dimensions;
   (2)  design; (3) water pumped?

Waste handling -  (1) transport by
   company; (2) processing;
   (3)  burial procedures
     Sheffield, Illinois

State of Illinois, leased to
   NECO
Rural, sparse
3 mi SW of Sheffield;
   others 3-7 mi
(1) 27; (2)  isolated, -not
   controlled
Excellent, expressways and
   2-lane hwy
35/yr
Intermittent drainage
40-60 ft; shale and  clay,
   deeper is sandstone
50-60 ft; glacial -  silty
   clay, loess
40-60 ft (SW), 15-25 ft  (N) ;
   N ^ 100-150 ft/mi
No specific information;
   probably limited
Low permeabilities;  some
   shallow soil cover
Survey instrs; monitoring
   system  and  lab
Usual -  lifts, dozer,  crane,
   etc.; medium  cap
 (1)  500  x  40 x depth 20  ft;
 (2)  usual, drain and sump;
 (3)  no
 (1)  yes;  (2) liquids solidified
   vermiculite and cement;
 (3)  usuaL, per regulation
                               A-519
-------
                      TABLE  A-93


       SITES  RECOMMENDED  BY  GSA,  FOREST  SERVICE,
           AND BUREAU OF  LAND MANAGEMENT
State

Arizona



California


Colorado
Idaho


Illinois

Kansas

Maryland

Missouri

Montana


Nebraska


Nevada
New Mexico
County

Cochise
Maricopa
Yuma

Inyo
Morro

Baca
Delta
Otero
Pueblo
Weld

Banock
Power

La Salle

Morton

Prince George

Jackson

Carbon
Fergus

Dawes
Sioux

Clark
Esmeralda
Humboldt
Lander
Lincoln
Mineral
Pershing
Washoe

Catron
Hidalgo
                      A-520
-------
         TABLE A-93 (continued)


SITES RECOMMENDED BY GSA, FOREST SERVICE,
    AND BUREAU OF LAND MANAGEMENT
State

North Dakota

Oklahoma

Oregon


South Dakota



Utah



Virginia

Washington


Wyoming
County

McHenry

Muskogee

Deschutes
Morrow

Butte
Fall River
Meade

Box Elder
Iron
Tooele

Pittsylvania

Franklin
Lincoln

Campbell
                  A-521
-------
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                          APPENDIX N

            EXISTING STATE LEGISLATION/REGULATIONS

For each State included in the survey, this appendix contains:

   •  a descriptive summary of relevant laws, regulations,
      etc., dealing with transportation, processing, and
      storage/disposal of hazardous wastes;*

   •  a table summarizing respective State agency respon-
      sibilities for hazardous waste transportation, pro-
      cessing, and storage/disposal; and

   •  summaries of any law library searches conducted.

This information will be found for each State on the pages
indicated below.

                                               Page

Alabama                                       A-612
California                                    A-615
Colorado                                      A-623
Illinois                                      A-629
Kansas                                        A-634
Maine                                         A-637
Michigan                                      A-643
Nevada                                        A-649
New Jersey                                    A-655
New York                                      A-657
Oregon                                        A-661
South Carolina                                A-674
Texas                                         A-677
Vermont                                       A-680
Virginia                                      A-683
Washington                                    A-686
* In the course of conducting^EFis survey, voluntary opinions
were offered by various State agency personnel as to the
probable public or State government attitude regarding
management of hazardous wastes.  These are included as
appropriate.
                            A-611
-------
                           ALABAMA

The Rules and Regulations of the Alabama Air Pollution Control
Commission reign supreme, setting standards described as "the
toughest in the country".

Although there is no specific reference to hazardous waste dis-
posal in this law, resident engineers say the law can be applied
to any situation.  Explicit legislation exists on radiation and
pesticides only insofar as solids are concerned.

Any county or municipality could pass local ordinances which
would constrain a national disposal system of hazardous wastes,
and some counties such as Jefferson and Mobile have published
sets of standards which for the most part follow the State code.
A total of 14 acts were identified in the Alabama Code that
could apply to hazardous waste disposal, the nine most relevant
of which are included in this report.

In regard to radioactive materials, the State has not provided
a public site but requires such materials to be sent to other
States for disposal with the exception of the University of
Alabama, which operates a disposal site for its radioactive
wastes.  The inclination of residents to accept the establish-
ment of a site in Alabama as part of a national disposal system
appears doubtful.

Other factors in addition to the lack of radioactive material
sites include the lack of regulations on explosives and land
use.  The Air, Water, Solid Waste, and Radiation Divisions of
the Department of Health regulate the transportation, processing,
and storage/disposal of hazardous wastes for their own respective
areas; inland waterway transport is especially controlled by the
Alabama Water Improvement Commission.  Pesticides are under the
control of the Department of Agriculture through licensing,
examination, and inspection.

Although it does not possess any regulatory power at present,
the Alabama Development Office would be a factor in the estab-
lishment of a national site since it is charged with Statewide
comprehensive planning.  Through contracts, the Alabama Develop-
ment Office has control over the functions of the Alabama Plan-
ning and Development Commission.  There is no indication of any
lack of cooperation between these agencies; good lateral commun-
ication between them can be assumed.


A significant  legal  confrontation  is expected  to occur due  to  a
physical restraint involving disposal of chemical wastes by  six
chemical manufacturing plants  in Decatur.  The plants have been
                             A-612
-------
dumping in a county landfill but the State Health Department
has enjoined them to stop without providing an alternative.
This constitutes an unusual example in Alabama of local control
being overridden by a State agency.
                          Highlights

 •   State  has  not  provided public disposal site for radiologi-
    cal materials, which are  sent to other States.  Law re-
    quires disposal on  State  or Federal land and sites are
    too costly.  Other  indications of officials' attitudes are
    not negative.

 •   Physical restraints are a current major problem in Decatur
    where  6 chemical manufacturers are dumping in landfill.
    The Department of Health  says stop, but no alternative site
    is available.

 •   The University of Alabama has radioactive waste site for
    own waste  with same regulations as AEG, but there is no
    State  site.

 •   Air pollution  control regulations "toughest in the country"
    (EPA).  Any  locality could pass constraining ordinances.

 •   State  legislation authorizes local solid waste regulations.
    Explicit legilsation exists on radiation and pesticides
    only.

 •   Water  pollution control regulation standards of Alabama
    Water  Improvement Commission could be used, particularly
    if inland  waterway were used for transport.

 •   Division of  Agricultural  Chemicals accounts for all pes-
    ticides by licensing and  written examinations and inspec-
    tions  and  also regulates  manufacture.

 •   Alabama Development Office has contracts with Planning
    and Development Commission which gives some control of
    planning and influence on Federal programs.  They would be
    involved in  any implementation through water quality manage-
    ment plans for State's river basins.  No indication given
    of excessive lack of interagency cooperation.  No indica-
    tion given on  lateral communication.

 •   State  adopted  AEC, DOT regulations and set own high air
    standards.
                            A-613
-------
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                          CALIFORNIA

State of California legislation is already well organized,
strongly favoring local or regional control.  This concept
is generally inconsistent with the implementation of a national
disposal system for hazardous wastes.

EPA has not approved California's plan of statewide control of
environmental problems; the State plan is merely a compilation
of local or regional plans.  The newly created Office of
Planning and Research, an agency within the Governor's Office,
was formed to assist State and local agencies in their planning
and has no control functions.  The Governor is charged with
preparing a comprehensive State Environmental Goals and Policy
Report every four years.  Therefore, the Office of Planning
and Research probably comes the nearest to fulfilling the role
of a primary agency even though its function is strictly
advisory.

Areas in which regulation is lacking in California include the
processing and disposal of explosives and statewide zoning
pertaining to land use; also, there are no existing facilities
for disposal of radioactive waste material.

Although there currently is no statewide policy for solid waste
disposal a State Solid Waste Management Board within the Resources
Agency has been formed and charged with development of a plan
by 1975.  Solid wastes now are regulated loosely by the State
and Regional Water Quality Control Boards of which there are
nine.  California's interstate water quality standards have
been approved by EPA.

A single air quality plan is required in basin areas, so de-
signated by the State Board.  The Coastal Zone Conservation
Commission is charged with planning for regions bounded by the
mountains and the sea.

The key to control of the environment in California rests in the
hands of the municipalities, counties, or regions and poses
a serious obstacle to establishment of a national site.  A
strong introspective attitude in combination with land use
control determined by geographical boundaries reinforces the
control of air and water disposal by localities.  The prime
future statewide influence would probably come from the Governor's
Office via the Office of Planning and Research.

Control of transportation and safety standards by State agencies
presently forms the only factor consistent with a national site.
DOT regulations have been adopted.
                             A-615
-------
                          Highlights

•  State legislation is oriented to local  determination.   Whether
   or not this local conceptualization of  implementation  is  con-
   sistent with a national plan is questionable.   EPA has not
   approved California's implementation plan.

•  A single air quality plan is required in areas  designated by
   State Board as a basin.  Coastal Zone Conservation Commission
   plans for regions bounded by sea and mountains.

•  State plan is compilation of various local  plans.   Munici-
   palities currently have existing facilities individually
   regulated, air standards are set by county  on regional boards.
   Water standards are regional.  Pesticide regulation is in
   process.

•  Safety is extensively regulated by the  Department  of Industrial
   Relations, the State Highway Patrol and the State  Fire Marshall,

•  Local character of new legislation would imply  a personal
   basis for interagency cooperation, with little  jurisdictional
   dispute.

•  Constraint on land use seems clearly defined through geogra-
   phical organizations (basins, regions,  districts).  Attitude
   is definitely introspective.

•  Transportation permits, licenses pertaining to  size of ship-
   ment, safety, types of cargo are issued. DOT regulations
   adopted.

•  Differing interstate standards should be similar  to other
   States adopting DOT regulations.

•  Wide diversity of agencies has a definite local or regional
   flavor.

•  There are nine regional water quality control boards and  a
   new Office of Planning and Research in  the  Governor's  Office.
   State requires local agencies to establish  planning agency.

•  California Environmental Act is similar to  National Environ-
   mental Protection Act.
                            A-616
-------



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WASTE DISPOSAL SITES ARE BEING CATEGORIZED
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                 Law Library Search Findings

Solid Waste

California currently has no statewide policy for solid waste
disposal.  The newly created State Waste Management Board with-
in the Resources Agency is to adopt a plan by January 1,  1975,
Government Code §66770.  Primary responsibility for adequate
solid waste disposal is to rest with local governments -  §66730.
Each county is to prepare a plan by January 1, 1976, §66780.
The State Department of Health is directed to "prepare and sub-
mit minimum standards for solid waste handling and disposal" to
the Board by January 1, 1975, for inclusion in the State  plan.

At the present time solid waste disposal is essentially regulated
by the State and Regional Water Quality Control Boards.  A des-
cription of their activities is included on pages 41-44 in the
Hazardous Waste Disposal Survey conducted by the California State
Department of Public Health.  The actual regulations are  in sub-
chapter 15 of the water regulations.  The authority for this
regulation is questionable.  Section 14040 of the Water Code,
upon which authority is placed, specifies that regulations are
to be adopted for "liquid" waste.  The State Board presumably is
relying on §13050 (d) which defines waste as including solids.

Water Quality Control

The State Water Resources Control Board coordinates all water
quality activities.   The nine regional water quality control
boards are required to adopt water quality plans - Water  Code
§13241.  Permission for waste discharge must be obtained  from
the regional boards - §13263.  Regional Boards have cease and
desist powers - §13301.  Interstate water quality standards have
been approved by EPA.

Air Pollution

A summary of the effect of California air pollution law relating
to hazardous wastes is in the California Hazardous Waste  Disposal
Survey on pages 44-47.

Discharge of injurious or annoying material into the air is pro-
hibited by statute §24243.

Air control boards can make all necessary regulations, Health
and Safety Code §24260, and order abatement, §24605.  Two or
more counties may form a regional district - §24330, §39301.
                            A-618
-------
Land Use Control

The State Office of Planning is a division of the Department
of Finance - Government Code §65013.2.  Its functions, other
than the maintenance of a comprehensive state development
plan, are limited to advising and coordinating activities of
local planning boards.  The State plan is a compilation of
local plans - §65015.

The newly created Office of Planning and Research is in the
Governor's Office - §65037.  This body has no control functions,
but was formed to assist State and local agencies in their
planning process - §65040.

The Governor of California is charged with preparing every four
years a comprehensive State Environmental Goals and Policy
Report - §65041.

Regional planning districts are authorized by vote of 2/3 of
the cities and counties within a district - §65061.3.  Each
district may maintain a comprehensive regional plan - §65065.1.

In the Lake Tahoe area, a single regional planning agency
composed of cities and counties in both California and Nevada
has been created - §67040.  An interim plan, §67073, and a
comprehensive regional plan are required - §67070.  The agency
is to adopt regulations to effectuate the plan - §67100.  The
regulations are to contain standards, including specific
standards for solid waste disposal, shoreline development,
and waste disposal in shoreline areas - §67100.  The agency
is to police the region to ensure compliance with the regula-
tions - §67105.

Every city and county in California is required to have its
own planning agency - §65100.  Each agency is required to
maintain a general plan - §65101.  Plans must include a wide
variety of elements - §65302.  Specific plans for a limited
area are also authorized - §65450.1.

Every city and county was required to submit to the State
Resources Agency by June 30, 1972, an "open-space plan for
the comprehensive and long-range preservation and conversa-
tion of open space land within its jurisdiction" - §65563.

Legislative bodies of cities and counties may establish an
area planning commission - §65601 - or a district planning
district - §66140.  Cities and counties are given broad
zoning powers in §65850.  Zoning ordinance must be consistent
with the general plan by January 1, 1973.
                            A-619
-------
A San Francisco Bay Conservation and Development Commission has
been created - §66620.  It has prepared the San Francisco Bay
Plan which is a "comprehensive and enforceable plan for the
conservation of the water of the San Francisco Bay and the de-
velopment of its shoreline" - §66603.  The Commission's permis-
sion must be obtained before filling, extraction of materials,
or substantial changes in structures can be performed - §66632.

In the November 7, 1972 election California voters passed the
Coastal Zone Conservation Act.  The Initiative measure creates
a Coastal Zone Conservation Commission and six regional commis-
sions - Public Resources Code §27000.  The Commission is to
submit to the legislature a land use plan for land between the
seaward limites of State jurisdiction and the peak of the coastal
mountain range - §27300.  Between 1973 and 1976, a permit will
be required for development between the seaward jurisdictional
limit and 1,000 yards inland - §27400.

Nuisances

Legislation relating to nuisances begins at §3479 of the Civil
Code.  Public and private nuisances are defined and remedies
provided.  Activities authorized by statute cannot be deemed a
nuisance - §3482.

Radiation Control

The State Department of Public Health administers disposal and
transportation of radioactive material, Health and Safety Code
§26500, §25651.

Disposal of radioactive material which will result in signifi-
cant contamination of the environment is prohibited.  The Depart-
ment can prohibit any activity with radioactive wastes if there
is danger of contamination - §25603.  The Department is also
charged with monitoring storage, packaging, transportation, and
loading of radioactive waste - §25606.

Regulations have also been promulgated for disposal of radio-
active material.  Concentration limits have been adopted for
release into air or water - Title 17, §30269.  Disposal in a
sewer system is permitted if the waste is dispersible in water
and does not exceed concentration limits - §30287.  Burial is
permitted if radioactive material is appropriately spaced and
within concentration limits - §30288.  The following restriction
should be noded:

   The department will not approve any application for a license
   to receive radioactive material from other persons for dis-
   posal on land not owned by the State or Federal Government -
   330288 (b).
                            A-620
-------
Regulations for intrastate transportation of radioactive
material have also been adopted by the Department.   The
regulations require conformity to 49 C.F.R., Parts  170-190;
14 C.F.R., Part 103; and 46 C.F.R., Part 146 - Title 17,
§30373.

Transportation of Hazardous Materials in General

The State Highway Patrol is authroized by §34500 of the Vehicle
Code to regulate operation of vehicles containing hazardous
materials as defined in 49 C.F.R., 172, 173.  The Patrol has
adopted 49 C.F.R., 171, 172, 177, 178, Administrative Code,
Title 13, §1222 (a).  Some additional regulations supplement
the DOT regulations.  Transportation of radioactive materials,
flammable liquids, explosives, and other materials  specifi-
cally provided for do not come under the authority  of the
Highway Patrol - §34500.

The Department of Public Works has extensive regulations
governing transportation of hazardous materials on  California
toll roads and bridges.  California Administrative  Code,
Title 21, Chapter 2, Subchapter 1.

All haulers of liquid waste, except sewage, fertilizer, or
radioactive material, must be registered with the State Water
Resources Control Board, Water Code §14020.

Transportation and Storage of Explosives

Legislation applicable to intrastate transportation of explosives
in quantities greater than 1,000 pounds is in §36000 of the
Motor Vehicle Code.  Transportation of quantities less than
1,000 pounds is in §12000 of the Health and Safety  Code.

A license from the State Highway Patrol is required for trans-
portation of explosives.  The Highway Patrol is given extensive
authority to designate routes and inspect vehicles.  Equipment
requirements are also designated - Motor Vehicle Code §31610.

The State Fire Marshal is authorized to adopt regulations
governing transportation of flammable liquids - §34000.  The
regulations are found in subchapter 11 of Chapter 1, Title 19,
California Administrative Code.  The regulations are quite
detailed.

Pesticides

The California Department of Agriculture establishes regula-
tions for handling of agricultural chemicals and the empty
containers.
                            A-621
-------
A recent amendment to the Agriculture Code makes it unlawful
"for any person to store, transport, handle,  or dispose of any
economic poison or of any container which holds or has held
such economic poison, except in compliance with rules and re-
gulations of the director", Agriculture Code  §12991.  Hearings
were held early in November 1972 on proposed  regulations for
handling and disposal of pesticide containers.   Economic poisons
are broadly defined to include most all agricultural chemicals
- §12753.

Industrial Safety

The California Department of Industrial Relations, through its
Division of Industrial Safety, has issued extensive regulations
to protect workers from hazardous materials.   Regulations exist
for radiation and radioactivity, control of hazardous substances,
and explosives and fireworks.   Further discussion is on page 47
of the Hazardous Waste Disposal Survey.
                            A-622
-------
                           COLORADO

The most anti-Federal-control attitude of any State among the
16 surveyed is presented by Colorado, which is unique in that
noting existing regulation is easier than noting its nonexis-
tence.  This can probably be traced to the development of the
State and its political structure under the influence of extreme
topography, resulting in local determination.  The Colorado
Land Use Commission policy is that "the decision-making author-
ity ... shall be at the lowest level of government possible".
That agency would probably be the key to any Statewide imple-
mentation of a hazardous waste management system in the future,
as it is charged with development of an overall plan for the
State.

However, existing legislation authorizes county and city
governments to override any regional plans by a two-thirds
vote;  this would be a continuing obstacle for implementation
of a national disposal system unless the State performed a
complete turnabout in its political heritage/philosophy and
rescinded such legislation.

Colorado is, again due to its history  (particularly involving
mines), different from many of the other States surveyed in
that it has regulations for disposal of solid wastes.  However,
regulation of air and water quality is lacking, as it also is
for explosives, pesticides, safety, and the transportation,
processing, and storage of radioactive materials.   There are
regulations for radioactive disposal (by burial in special
landfills) but no specific disposal sites for either radio-
active or other hazardous waste materials.  DOT transportation
regulations have been adopted; however, cities and counties
again can override these for areas within their jurisdiction.

The existence of large leases and mining claims creates a
stronger flavor of deference to private interests  than is
observed in any of the other 16 States surveyed; for instance,
the approval of the Land Use Commission is not required for
construction of a private waste processing or disposal site.

                          Highlights

•  "...The decision-making authority as to the character and
   use of land shall be at the lowest level of government
   possible."  Colorado Land Use Commission policy is to pre-
   pare overall plan.  Regional plans can be overridden by
   county and city governments.  Approval of Commission is
   not required for construction of a private waste processing
   or disposal site.  Local/individual concept seems inconsis-
   tent with Federal program.
                             A-623
-------
<3  Severe topography of much of the State would substantiate the
   apparent local flavor of implementation.

»  There are no radioactive waste disposal sites.   Radioactive
   material is now placed in special landfills.  Regulations
   have been adopted, but no specific regulations on hazardous
   waste materials.

•  DOT safety regulations have been adopted and are enforced by
   the Public Utilities Commission.

*  In interagency cooperation, what limited regulation exists
   seems clearly defined as to whose jurisdiction prevails.

•  An interim plan for State land use was completed in December
   1972.  Existence of large leases and claims of mining property
   may be unique for the State and may be a basis for deference
   to private interests in waste disposal.

•  DOT transportation regulations have been adopted, but towns
   and cities can override these inside their corporate limits.

•  Cities, towns, and counties may set stricter air standards
   than the State.  EPA has approved Colorado air standards
   except for motor vehicles.  Interstate water standards have
   been approved and DOT standards adopted.

•  Local emphasis in political control, but State can issue
   cease and desist orders with Governor's concurrence to pro-
   tect the general public welfare.

•  State has adopted fewer of the DOT guidelines than any other
   of the 16 States surveyed.

                 Law Library Search Findings

Solid Waste

Administration of solid waste laws is within the State Depart-
ment of Health.  Regulations adopted by the Department of Health
became effective April 1, 1972.

Disposal sites in unicorporated areas must be approved by the
local county commissioners, CRS 36-23-2.  The Department of
Health issues a recommendation regarding proposed sites to the
commissioners - CRS 36-23-2.  Approval cannot be granted by
county commissioners if the Department of Health does not concur
- CRS 36-23-5.  Sites must conform to the comprehensive county
land use plan - CRS 36-23-4  (3).
                            A-624
-------






















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-------
Radioactive materials can only be disposed of in specially de-
signated sites.  Section 3 (1) (d)  (Regulations).

"Hazardous material and toxic substances" are defined as "liquids
or solids which can be dangerous to man, animal, and plant life
unless properly neutralized".  Previous regulations required
hazardous and toxic wastes to be neutralized before disposal.
At the present time, disposal is permitted if air and water
quality standards can be met.  There is no specific regulation
relating to disposal of hazardous wastes.

Air Pollution

Air pollution control is administered and enforced by the Air
Pollution Control Commission in the State Department of Health,
CRS 66-31-4, 66-31-13.  Cities, towns, counties, and combinations
thereof are authorized to adopt and enforce stricter emission
standards than State standards, CRS 66-31-25.  The Commission
is authorized to adopt emission and ambient air quality standards,
CRS 66-31-7, -8.  A variance board exists to grant variances for
good cause, CRS 66-31-15.  EPA has fully approved the Colorado
air implementation plan, except for motor vehicle implementation.
The approved portions will have to be reeaxmined,  however, to
see if they contradict the "nondegradation" result ofthe recent
Sierra Club court case.

Water Pollution

Water pollution control is administered by the Water Pollution
Control Commission within the Colorado State Department of Public
Health.  The Commission is authorized to adopt water quality
standards, CRS 66-28-8  (1), and discharge standards, CRS 66-28-8
(2).  Interstate standards have been adopted.

Written permits are required to dispose of radioactive or toxic
wastes "underground in liquid or explosive form",  CRS 66-28-9
(2).  The Commission must find that there will be no harm re-
sulting.

Notice of plans to operate a system to dispose of wastes must be
given to the Commission, CRS 66-28-12.

Land Use Control

County and regional planning authorities are authorized in
CRS 106-2-2, 2-4 and are required to prepare waste plans.
Regional plans are not binding on cities or counties, CRS 106-
2-5 (b).  A 2/3 vote can override the regional planning author-
ity when zoning changes for sites greater than 20 acres are in
question, CRS 106-2-9(2)(c).
                            A-626
-------
Approval of the regional planning authority is apparently not
needed for construction of a private waste processing or
disposal site, CRS 106-2-9(1) (a).  Zoning in unincorporated
areas is authorized, CRS 106-2-10.

The Division of Planning within the State Department of Local
Affairs acts as an information source and advisory body for
local governments, CRS 106-3-2.

In 1971, the Colorado Land Use Commission was created, CRS 106-
4-2.  The legislative declaration accompanying the article
states that "land use, land use planning, and quality of
development are matters in which the State has responsibility
for the health, welfare, and safety of the people of the State
and for the protection of the environment of the State",
CRS 106-4-1(2).  The Commission is charged with developing a
"total land use planning program" for the State, CRS 106-4-3
(I) (a) .

The Commission is directed to "recognize that the decision-
making authority as to the character and use of land shall be
at the lowest level of government possible", CRS 106-4-3(1)(b).
It can, however, issue a cease and desist order with the
Governor's concurrence to the person in control of any activity
"which constitutes a danger of irreparable injury, loss, or
damage of serious and major proportions to the public health,
welfare, or safety", CRS 106-4-3 (2) (a) .

Radiation

The State Department of Public Health is designated as the
radiation control agency of Colorado, CRS 66-26-3.  It is
authorized to acquire sites for concentration, storage, and/
or permanent disposal of radioactive materials, CRS 66-26-3(7)
(a).  The site and radioactive material are to be permanently
owned by the State, CRS 66-26-3(7)(h).  Licensees may be
authorized to operate disposal sites, CRS 66-26-3(7)(b).  The
Department of Health indicates that no sites are presently
being operated.  Radioactive material is going into specially
designated landfills.  Regulations for disposal of radioactive
material have been adopted.  Rules and regulations pertaining
to radiation control, RH 4.10-4.16.

Pesticides

Colorado requires registration of pesticides but does not have
specific regulations relating to transportation or disposal.
                            A-627
-------
Transportation of Hazardous Material

The Colorado Public Utilities Commission has adopted Department
of Transportation regulations in Title 49 of the Code of Federal
Regulations, Parts 173-178 and 397.

Towns and cities are authorized to regulate or prevent the
storage and transportation of combustible or explosive material
within their corporate limits, CRS 139-32-1(54).

Nuisances

"Towns and cities are authorized to declare what shall be a
nuisance and to abate the same and to impose fines upon parties
who may create, continue, or suffer nuisances to exist", CRS 139-
32-1(58).

A local board of health may destroy and abate nuisances which
in "its opinion may be injurious to the health of the inhabitants
within the town, city, or county", CRS 66-3-13.  The State
Department of Health is authorized to act if the local board does
not, CRS 66-3-2.
                            A-628
-------
                         ILLINOIS

If the environmental regulations of all the States of the
nation were as well oriented along Federal guidelines as are
Illinois', establishment of a national hazardous waste manage-
ment system would be nearly accomplished.  The legislation/
regulations existing within this State are based on a 1966
adoption that followed Federal guidelines closely; as such,
the present body of regulation is well defined and already
operational.

The few areas still not regulated include the disposal, pro-
cessing, and storage of explosives and the safe handling of
hazardous materials.  There are no facilities in existence
for handling hazardous materials other than radioactive ones.
Illinois is one of five States with an operational disposal
site for radiological wastes—a site located on public land
but operated by a private firm.

One potential problem involves groundwater pollution from
solid waste landfills; this is under the technical supervision
of the Illinois Geological Survey.  Another relative weakness
is the poorly defined or regulated area of transportation, in
which DOT regulations have not been adopted.  This is para-
doxical in that most other States, many of which are strongly
local in attitude, have already adopted these regulations.

Another potential problem area is that of differing interstate
standards, because Illinois standards exceed those of the
Federal guidelines.

One of the most significant facets of Illinois' adoption of
EPA standards is that the State agency can overrule local
zoning and siting decisions and also can investigate indus-
tries to determine whether they are sources of pollution and
what their methods of control are.

                         Highlights

•  Attitude and inclination are favorable.  Existing and/or
   new legislation designed around Federal guidelines is
   already fully organized and operational.

•  Some groundwater pollution problems exist.

•  Illinois is one of five States with radioactive waste
   disposal sites operated by private firms on State land.
   Department of Public Health regulates radioactive wastes,
   all other wastes are regulated by State Environmental
   Protection Agency.
                            A-629
-------
•  DOT safety regulations have not been adopted and there are no
   rules and regulations other than placards and licenses.

•  Interagency cooperation appears clearly defined and viable.

•  Good attitude of State agencies toward hazardous waste manage-
   ment system exists.  Voters must decide on land use through
   referendum.  There is local government disposal via EPA
   regulations (both judicial and legislative).  1966 Illinois
   law used for EPA.

•  Transportation is not very well defined or regulated.

•  Illinois State standards generally exceed Federal interstate
   standards.

•  Political structure is well defined and operational.

•  State used Federal guidelines in adopting 1966 State legisla-
   tion.  Federal regulations are followed on transport of
   pesticides.

                   Law Library Search Findings

In reviewing the legislation a number of key terms were located
in the index of the State codes.  A more thorough search was
then performed in reviewing the actual laws.  The following is
the list of terms used:

   1.  Wastes
   2.  Industrial Wastes
   3.  Pollution of Water
   4.  Sanitation
   5.  Economic Poison
   6.  Disposal
   7.  Natural Resources
   8.  Environmental Protection Agency
   9.  Environment
  10.  Interstate Sanitation Commission
  11.  Department of Agriculture
  12.  Ecology
  13.  Air Pollution
  14.  Chemicals
  15.  Zoning
  16.  Radioactive Materials
  17.  Department of Highways
  18.  Water Quality
  19.  Garbage and Refuse
  20.  Insecticides, Pesticides
  21.  Sewage
                            A-630
-------
  /2  Utilities
  23- Motor Vehicles
  24„ Ionizing Radiation
  25. Navigable Waters and Shorelines
  26. X-Ray Equipment
  27. Water
  28. Dangerous Substances
  29. Hazardous Substances
  30. Conservation
  31. Health
  32. Municipal Pollution Control
  33. Planning Commission
  34. State Land Use and Development
  35. Sanitary Landfill
  36. Soil Conservation
  37. Transportation

Unless specifically stated, it may be assumed that restraints
were not found under the terms searched.  This list is by no
means exhaustive or comprehensive, nor does it assume that
restraints cannot be found under different terms or sections
of the State code.

Restraints are few as most of the legislation is stated in
very general terms, with provisions for unusual or exceptional
circumstances that may arise.

Recent legislation which has not yet been incorporated into
the State code but which has been passed by the General
Assembly is referred to as a Public Act (PA).

Transportation

Registration is a prerequisite for interstate commerce.  18-303.
It is unlawful to transport misbranded hazardous substances.
11-1/2:262.  Transportation of nitroglycerin is prohibited.
PA 77-2274.  Carrier of hazardous substances must show records
on request.  11-1/2:262.

Industrial Waste Disposal

The State has the right to charge individuals for such disposal.
42:421.

Radiation Installations

Must be registered with the Director of the Department of
Public Health.  111-1/2:195.  Specifications for amounts of
radiation considered harmful are given.  111-1/2:196.  Prohibits
exposure to ionizing radiation.  111-1/2:212.  Persons disposing
                             A-631
-------
of radioactive materials must keep records for Department of
Health.  Provides for leasing of lands, building and sites for
purposes of operating a site for concentrating radioactive wastes.
.111-1/2:230.4.  Responsibility to public for safety from radiation.
111-1/2:230.6.

Land Use

Use of lands for conserving water, soil, etc. must be put before
the voters in the form of a referendum.  Three-quarters approval
is necessary.  5:128.

Industrial Pollution Control

The State is authorized to acquire land as it sees necessary for
the construction of a pollution control facility.  PA 77-2159.
Methods of financing are outlined in this section.

Waste Disposal Districts

Power is vested in local government to dispose of solid wastes
in compliance with EPA regulations.  85:1654.

Water Pollution

The State code expressly forbids the discharge of polluting
materials into Lake Michigan.  19:61a.  Prohibits discharge of
pollutants directly or indirectly into natural waterways.  85:1706

Pollution Investigation

Power is vested in the attorney general to investigate any pol-
lution of air, water, or land.  14:12.

Sewage Disposal

Power is vested in the county to provide for the disposal of
sewage, refuse and other objectionable wastes within the borders
of the county.  34:3111.

Labeling

Hazardous substances must be labeled as such.  111-1/2:252-11.
If not, they are subject to seizure.  111-1/2:255.

Radioactive Wastes

The State government can purchase, lease, accept, or acquire
lands, building, and grounds where radioactive wastes can be
disposed.  127:55.34.
                             A-632
-------
Radiation

Registration of radioactive materials is required.  PA 77-210.

Sanitary Landfill

Disposal of refuse without creating hazards.   (EPA Act)  Must
file 10 day notice for operating.  PA 77-1948.

EPA Act

No emission is allowed which will cause air pollution.  PA
77-1684.  No emission is allowed which will cause water
pollution.  PA 77-1605.

EPA

Sets up standards for operation of disposal sites.  PA 77-1948

EPA Agency

Defines and implements environmental standards.  111-1/2:1005.

Refuse Disposal

No person shall conduct refuse disposal without permit.
111-1/2:1021.

Economic Poisons

Must be registered before they can be transported.  PA 77-2168.
                             A-633
-------
                           KANSAS

Through vague, ill-defined legislation, Kansas is currently
waiting for implementation of a national disposal system before
designing its own State organization to fit the Federal guide-
lines.  This is in contrast to other States which have forged
ahead with their own State regulations designed around local
or regional control.  However, Kansas has a study under way in
conjunction with Federal agencies to determine how best to pro-
cess, transport, and dispose of hazardous chemical wastes.

Kansas lacks regulations in land use and industrial safety;
there are no existing facilities for disposal of hazardous wastes,
nor are disposal facilities of any kind contemplated following
a serious failure in public relations in which the public became
aroused by misinformation  (or lack of information) regarding a
radioactive disposal site in an underground salt mine at Lyons,
Kansas.  The citizenry would definitely vote down any proposal
at the present time, according to officials.

Another potential stumbling block in the way of implementation
of a hazardous waste management system is a confusing overlap
of jurisdiction among the State agencies; e.g., the Department
of Health regulates disposal of radioactive wastes, while the
law gives similar authority to eight other agencies.

A change in the physical aspects normally presenting some con-
straint to implementation of a NDS has occurred with the wide-
spread development of surface water entrapment along river
valleys in central and southern Kansas.  Thus groundwater no
longer is the prime water source.  This should alleviate the
problem of disposal of wastes in landfills.

Cities and counties can enact their own regulations if these are
more stringent than State regulations; this is no surprise,
considering the traditional independence of the citizens of the
State, and it provides an insight into the public attitude
toward establishment of a national disposal system--such an
implementation would require that extensive groundwork be laid
in the public relations/information area before being readily
accepted.

                           Highlights

•  Agencies are waiting for EPA before establishing legislation,
   or conducting studies in conjunction with EPA or HUD  (co-
   operative/anticipative).

•  Salt mine disposal site for radioactive burial at Lyons
   caused public outcry.  There is a strong groundwater moni-
                             A-634
-------
   toring agency.   Surface water capacity increased with new
   systems of reservoirs so that groundwater  sources are no
   longer the prime water source.

•  No well defined regulations exist.   Very broad legislation
   provides basis  for regulation.  There are  no facilities and
   none are contemplated after Lyons.   State  authorizes  under-
   ground and surface storage and disposal, however.

•  Normal safety permitting and licensing by  State Highway
   Department.

•  There are large landowners in western portion of State.
   Farmers are noted for independence  and conservatism.   Local
   regulation is sanctioned if State standards are exceeded.

•  Transportation  regulations are not  fully developed.

•  Diversity of agencies causes some confusion in adminis-
   tration (overlap of responsibility).

•  Political structure could lead to jurisdictional disputes
   in area of radioactive disposal regulated  by Department of
   Health.  Eight  other agencies make  recommendations on legis-
   lation and administration.
                            A-635
-------



















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                            MAINE

The State Planning Office sees little likelihood that the
Maine Coastal region will support any sites for hazardous
waste disposal; the inclination of the State toward establish-
ment of a national disposal site appears to be firmly negative.

The Department of Environmental Protection is the key agency in
future legislation controlling hazardous waste disposal;  in it
are the Bureaus of Water Quality Control, Air Quality Control,
and Land Quality Control.  However, most of the effective
regulation that exists presently is administered through the
Public Utilities Commission via its licensing and permitting
activities.

The State has regulations on the transportation, disposal,
processing,  and storage of radioactive materials; however, no
facilities exist for disposing of radioactive or other hazard-
ous materials.  Lacking regulation are the licensing of solid
waste disposal sites, air and water quality emissions, pro-
cessing, and storage of pesticides.

The State may establish regulations via licensing that could
influence the movement of nuclear materials.

                          Highlights

•  Municipalities and counties can regulate the operation of
   all vehicles in public ways and even set licensing and rate
   requirements if these do not conflict with the Public Utili-
   ties Commission.

•  Public Utilities Commission governs licensing, permits,
   rates and extent of liability for carriers.

•  Licensing of all waste discharges is required by State, as
   well as location of solid waste disposal areas.

•  State regulations specify that all sites must be located at
   least 300 feet from the shore of any classified water body.

•  State regulations on employee welfare exist at processing
   plants and all working environments.

•  Coastal Zoning Plan is currently being developed.

•  State Planning Office sees little likelihood that the Maine
   Coastal region will support any sites for hazardous waste
   disposal.
                             A-637
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                                                      AGENCY  RESPONSI BILITY
          MAINE
DEPARTMENT OF PUBLIC SAFETY
                                        TRANSPORTATION
                             ISSUES AND ENFORCES RULES AND
                             REGULATIONS PERTAINING TO THE
                             TRANSPORTATION OF HAZARDOUS MATER-
                             IALS AND PARTICULARLY EXPLOSIVES
                             AND FLAMMABLES
                                                                               PROCESSING
                                                                                                               STORAGE/DISPOSAL
                                                                           ESTABLISHES RULES FOR THE STORAGE
                                                                           OF FUMMABLES AND EXPLOSIVES
PUBLIC UTILITIES COMMISSION
                             REQUIRES ALL INTRASTATE COMMON
                             CARRIERS TO PLACARD HAZARDOUS
                             CARGO AND TO HAVE A  BILL OF
                             LADING AVAILABLE AT ALL TIMES
                             DURING SHIPMENT. HAS NO CON-
                             TRa OVER  PRIVATE CARRIERS.

                             INTERSTATE CARRIERS MUST CON-
                             FORM TO ICC RULES AND REGULATIONS
DEPARTMENT OF HEALTH
AND WELFARE
REQUIRES LICENSING FOR ALL SOURCES
OF RADIATION AND MAY ESTABLISH
RULES AND REGULATIONS WHICH COULD
INFLUENCE THE MOVEMENT OF NUCLEAR OR
ATOMIC MATERIALS
ESTABLISHES RULES AND REGULATIONS
PERTAINING TO THE SAFETY AND HEALTH
OF WORKERS

HAS THE RESPONSIBILITY TO PROTECT
THE PUBLIC FROM THE HAZARDS OF
RADIATION  ESTABLISHES RULES
AND REGULATIONS AND LICENSES
SOURCES OF RADIATION.
DEPARTMENT OF AGRICULTURE
                             MAY INSPECT AND REQUIRE PLACARDING
                             OF THE INTRASTATE MOVEMENT OF
                             HAZARDOUS MATERIALS
                             REGISTERS ALL ECONOMIC POISON DELIVER-
                             ED FOR TRANSPORTATION     REQUIRES
                             PROPER LABELING
DEPARTMENT OF ENVIRONMENTAL
PROTECTION
                                      ESTABLISHES AMBIENT AIR QUALITY
                                      STANDARDS
                                      LICENSES SOURCES OF EMISSIONS
                                      AND ISSUES ORDERS TO ABATE

                                      ESTABLISHES STANDARDS FOR WATER
                                      QUALITY

                                      REGULATES THE LOCATION OF
                                      DEVELOPMENTS (INCLUDING
                                      INDUSTRIAL) COVERING MORE
                                      THAN20ACRES, OR WHICH WILL
                                      EXCAVATE NATURAL RESOURCES OR
                                      A STRUCTURE OR STRUCTURES IN
                                      EXCESS OF 60,000 SQUARE FEET
                                      GROUND COVERAGE
                                     ISSUES DISCHARGE PERMITS FOR WATER
                                     BORNE WASTES

                                     LICENSES SOURCES OF AIR EMISSION

                                     MAY REQUIRE SOLID WASTE DISPOSAL
                                     SITES TO BE LOCATED OR RELOCATED
                                     BECAUSE OF WATER QUALITY PROBLEMS
                                     (THIS INCLUDES THE REMOVAL OF ANY
                                     WASTE PREVIOUSLY PLACED!

                                     TAKE  ACTION ON ANY OIL DISCHARGED
                                     INTO THE STATE WATERS - NONE ALLOWED

                                     CONTROLS DISCHARGE OF MERCURY COM-
                                     POUNDS. NONE ALLOWED ABOVE NATURAL
                                     CONCENTRATION

                                     SITE LOCATION OF DEVELOPMENT LAW
                                     WOULD INCLUDE URGE PERMANENT
                                     STORAGE ON DISPOSAL SITES -
                                     REVIEWED BY DEP
LAND USE REGULATION
COMMISSION
                                      SETS LAND USE PATTERNS IN THE
                                      UNORGANIZED AND DEORGANIZED
                                      PORTIONS Of THE STATE

                                      COMMISSION REVIEW AND APPROVAL
                                      REQUIRED FOR ANY DEVELOPMENT
                                      DEVELOPING A COMPREHENSIVE LAND
                                      USE GUIDANCE  PLAN FOR THE UN-
                                      ORGANIZED AND DEORGANIZED POR-
                                      TIONS OF THE STATE
                                    SITE LOCATION REVIEW AND APPROVAL
                                    FOR ALL SUCH STORAGE OR DISPOSAL
                                    SITES IN UNORGANIZED OR DEORGANIZED
                                    PORT IONS OF THE STATE
STATE PLANNING OFFICE
MISCELLANEOUS
                                       DEVELOPING COASTAL PLAN FOR THE
                                       STATE BASED ON LAND CAPABILITY,
                                       WILL IMPLIMENT SHORELAND ZONING
                                       IN THOSE COMMUNITIES WHICH DO
                                       NOT ZONE THEIR OWN SHORELANDS
                                       BY JUNE 1973.  (IN CONJUNCTION
                                       WITH THE LAND USE REGULATION
                                       COMMISSION AND THE DEPARTMENT OF
                                       ENVIRONMENTAL PROTECTION!
                                                                   THERE IS NO TAXATION ON INDUSTRIAL
                                                                   WASTE DISPOSAL SYSTEMS WHICH DO NOT
                                                                   PRODUCE USABLE BY-PRODUCTS

                                                                   MUNICIPAL LICENSE REQUIRED FOR THE
                                                                   INSTALLATION OF A STATIONARY INTERNAL
                                                                   COMBUSTION OR STEAM ENGINE
                                                                           NO SOLID WATER DISPOSAL AREA SHALL
                                                                           BE CLOSER THAN 300 FEET TO ANY
                                                                           CLASSIFIED BODY OF WATER

                                                                           NO OUT-OF-STATE WASTE
                                                      A-638
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   All interstate movement is under jurisdiction of DOT ragula-
   u .; ^, „ „

   Too few people are qualified to handle accidents involving
   hazardous materials.

®  Certain explosive materials are not acceptable for transport
   within the State.

-3  State regulates keeping, disposing or transporting of explo-
   sives.

9  State requires licensing for all sources of radiation and
   may establish rules and regulations which could influence
   the movement of nuclear materials.

*  State licenses sources of air emissions.

                 Law Library Search Findings

Agriculture and Animals

The Department of Agriculture has charge of "economic poisons",
the term used for substances or mixtures intended for pest con-
trol.   To the extent to which this applies to hazardous mater-
ials,  the Commissioner of Agriculture will register such a sub-
stance if it is "...delivered for transportation or transported
in intrastate or interstate commerce..."  Such transport must
provide for the proper labeling of such a substance.   (7§581-591)

The Department of Agriculture is also responsible for the en-
forcement of the Hazardous Substances Labeling Act of 1965
(7§501-513)

Commerce and Trade:  Atomic Substances

Several departments and agencies within the State are directed
to pursue studies associated with nuclear materials which re-
flect their own special interests.  Included are:

   1.  Department of Health and Welfare—hazards to public
      health and safety;

   2.  Department of Labor and Industry--hazardous working
      conditions;

   3.  Industrial Accident Commission—time and character of
      injuries and resulting compensation;

   4.  Department of Transportation—transport of materials;
                             A-639
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   5. Public Utilities Commission—transport of materials and
      future uses;

   6. Department of Public Safety-insurance for hazards; and

   7. Department of Forestry, Fisheries, etc.--effect on natural
      resources of State.

However, only the Department of Health and Welfare has prac-
tical duties (10§103-104, rev. 1971)

A Maine Industrial Building Authority also exists which is
geared to financing for increased industrial activity in the
State.  One of its powers is to consult with municipalities
as to the "advisability of eligible projects".   (10§751 et seq.)

Conservation

At any disposal site, the local Soil Conservation District, if
existent, would be concerned with the soil conservation measures
of the development (12§1 et seq.)

Other agencies would be involved in the preparation of sites
for storage or processing facilities, e.g., the Forest Commis-
sioner would issue a permit for the clearing of an area by
burning  (12§1551) and would also grant permits  for such things
as the construction of roads on State lands  (12§514).

In terms of the selection of a site for either  processing or
disposal, the Park and Recreation Commission would control the
leasing of any State lands  (12§602).   Also, depending on the
area selected,  the new Maine Land Use Regulation Commission
could come into play  (12§681 et seq.).

Crimes

Under Chapter 91—Nuisances, Section 2701 states that "any
person injured in his comfort, property, or the enjoyment of
his estate by a common and public or a private  nuisance may
maintain against the offender a civil action for his damages,
unless otherwise specially provided".  Grounds  for injunctions
and other penalties are subsequently stated.  The two sections
which could be of interest to us deal with certain engines
(17§2795) and miscellaneous nuisances (17§2802).

Health and Welfare

Under this title the only direct impact on hazardous waste
management would be that the Department of Health and Welfare
is authorized and empowered to "make evaluations and deter-
                             A-640
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minations of environmental or other health hazards affecting
employees in any occupation and to establish appropriate stan-
dards related thereto"  (22§42-A).  Additional responsibility
in this area is vested in the Occupational Safety Rules and Re-
gulations Board.

Internal Security and Public Safety

A Department of Public Safety was created in 1971.  The Commis-
sioner of this department has the responsibility for "reasonable
rules and regulations for the keeping, possession, storage", or
transport of all explosives (25§2441).

Motor Vehicles

Section 3 of this title states that "highway use is authorized
by any vehicle unless specifically prohibited".   No prohibitions
presently exist which would significantly influence the trans-
port of hazardous materials.  The title itself deals with common
regulations, similar in most States.  Any specific regulations
would have to be addressed to the Secretary of State who over-
sees rules and regulations for Title 29.  29§903 empowers the
Department of Transportation to promulgate rules and regulations
for height, width, weight and length of vehicles and also their
equipment  (29§1652, 1701 et seq.).

Municipalities and Counties

Under Title 30, municipalities can regulate the operation of all
vehicles in public ways and even set licensing and rate require-
ments if not conflicting with Public Utilities Commission.
Zoning regulations are standard.

Public Utilities and Carriers

The Public Utilities Commission governs licensing, permits, rates,
and extent of liability for all carriers.  This commission must
be contacted for specific regulations  (35§91).

Waters and Navigation

This is the title of most interest to hazardous waste management.
The Department of Environmental Protection is the key agency and
within it are the Bureaus of Water Quality Control, Air Quality
Control, and Land Quality Control.

All waters of the State have been classified according to the
standard categories.  Regulation of water standards (38§361 et
seq.), requirements for waste discharge licensing  (385413),
the general enforcement section  (38§451), and the specific re-
                             A-641
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gulation for the location of solid waste disposal areas
(38§421) are applicable.

In the case of air quality,  38§581 et seq.  are applicable.

In terms of land quality, the new development site location
requirements are quite important (38§481).

Sanitation districts were encouraged by an enabling act
signed in 1965 (38§1061 et seq.).
                             A-642
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                           MICHIGAN

Michigan appears inclined toward accepting a national disposal
system for hazardous wastes, although its intrastate regulation
presently is spotty.  Lacking regulation are water quality and
explosives processing and storage.

Although there presently are no facilities for radioactive or
other hazardous material disposal, new legislation is in pro-
cess that will control and enforce disposal of radioactive
materials.  No such wastes are presently buried in the State,
but are shipped out of State to an AEC-approved site.

DOT regulations have not been adopted; however, State regula-
tions adequately cover transportation of radioactive materials,
pesticides, and explosives.  The primary area of regulation
regarding hazardous wastes appears to be workers' health and
safety, with rules oriented toward satisfying a strong labor
influence.  Local government has zoning powers over the disposal
of wastes that the State agencies do not possess.

An official of the Department of Commerce points out that some
300 major waste producing companies are being contacted by his
office in an attempt to establish communication toward develop-
ing a practical system for accommodation of the many diverse
waste streams produced.

The State presently has detailed guidelines limiting the siting
of hazardous wastes; these limitations exceed Federal guidelines
but would likely be included in a hazardous waste management
system for the State.

                          Highlights

•  Economic poisons must be registered for transport.

•  A county may zone any shore land and county land.

•  Discharge into State waters of any liquid or solid materials
   which render the water unsightly, noxious or unwholesome is
   prohibited.

•  The State presently has regulations concerning flammables,
   explosives, and radioactive materials.

•  Radioactive waste are handled according to AEC regulations,
   generally.

•  The following considerations relate to hazardous wastes:
   1) leachate testing, 2) finding of wastes for transport and
                             A-643
-------
   r torage, 3)  storage system design,  4)  transportation,  5)
   r"c~action of employees, and 6)  final  disposal.

   local units of government have zoning  powers which cannot
   be changed by State agencies.

   Enabling legislation is pending in  Michigan which involves
   radioactive waste disposal.  This will provide for 1)  con-
   trol of ionizing radiation emissions,  2)  certain contractual
   agreements with the Federal Government for licensing radio-
   active materials, 3)  designation of the Department of Public
   Health as the State radiation control  agency, 4)  establish-
   ment of a radiation advisory committee, 5) adoption of rules
   for implementation of this act,  and 6) prescription of
   penalties for violations.

                 Law Library Search Findings

The State code of Michigan was consulted  for laws relevant to
the disposal of hazardous wastes.  Key terms were located in
the index, alone with the number of the law related to the
term.  The specific laws were then reviewed for constraints on
the disposal of hazardous wastes.  Following is a list of the
terms used:

   1. Wastes
   2. Industrial Wastes
   3. Pollution of Waters
   4. Sanitation
   5. Economic Poisons
   6. Disposal
   7. Natural Resources
   8. Interstate Sanitation Commission
   9. Environment
  10. Environmental Protection Agency
  11. Department of Agriculture
  12. Ecology
  13. Air Pollution
  14. Chemicals
  15. Zoning
  16. Radioactive Materials
  17. Department of Highway
  18. Water Quality
  19. Garbage and Refuse
  20. Insecticides
  21. Pesticides
  22. Sewage
  23. Utilities
  24. Motor Vehicles
  25. Ionizing Radiation
                             A-644
-------
  26, Navigable Waters and Shoreline
  27. X-Ray Equipment
  28. Water
  29. Dangerous Substances
  30. Hazardous Substances
  31. Conservation
  32. Health
  33. Municipal Pollution Control
  34. Planning Commission
  35. State Land Use and Development
  36. Sanitary Landfills
  37. Soil Conservation

This list is by no means comprehensive or exhaustive, although
it does represent an initial effort at surveying the legislation,
It is perhaps likely that other terms would have revealed more
legislative constraints.  Although a thorough search was made
of the terms listed, this does not imply that other constraints
could not have been indexed under different terms in other
sections of the State code.

Following is a summary of the legislation thought to be relevant
to the disposal of hazardous wastes.  The number following the
law denotes the specific section of the State code where the
particular law may be found.  Recent legislation passed in 1971
and 1972 is referred to as a public act (PA) and has not yet
been incorporated into the State code.

Air Pollution

The Air Pollution Control Commission may control and abate air
pollution.  336.15 Sec. 5-B.  The commission may consider for
approval plans for air cleaning devices and inspect the instal-
lation for compliance with the plans.  336.15 Sec. 5-h.  The
commission cooperates with U.S. agencies with respect to air
pollution control.  336.15 Sec. 5-n.

Land Use

Cities, villages, townships, counties, boards of county road
commissions, and the State Highway Commission can purchase and
condemn property for the location, development, and construction
of a solid waste disposal system.  PA 220.

Planning

Plan and specifications for garbage disposal systems must be
submitted and approved by the State Commissioner of Health.
123.248 Sec. 8.  Provision is made for planning and conducting
refuse management systems, to license and regulate refuse dis-
                             A-645
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pcsai facilities and transporting units to regulate collection
centers.

Pollution Control

Municipalities are authorized to provide for the financing of
water and air pollution control equipment.  PA 75.

Shorelands Protection

The Department of Natural Resources shall recommend appropriate
use regulations necessary to protect an environmental area.
281.636 Sec. 6.

Transportation

Economic poisons  (insecticides, pesticides, etc.)  cannot be
transported into the State unless they have been registered.
286.163 Sec. 3a-l.  All trucks or vehicles used to transport
liquid industrial wastes shall have a license.  323.277 Sec. 5.
Carriers of hazardous substances engaged in intrastate commerce
shall permit the State Director of Agriculture to have access
to all records showing movement of hazardous substances in
intrastate commerce.  286.461 Sec. 11.

Conservation

It is the duty of the Department of Conservation to guard
against the pollution of lakes and streams.  299.3 Sec. 3.
The Department of Conservation determines if it is in the
public interest to grant a deed or lease to permit use and
improvement of the waters.  This department also determines the
amount of consideration to be paid to the State by the applicant
for the lease of unpatented lands.  322.705 Sec. 5.

Construction of Public Utilities

Construction of public utilities upon, over, or under a public
road or bridge requires the permission of the Board of County
Road Commissioners.  247.184 Sec. 14.  Construction of utilities
shall not interfere with public uses of roads, bridges, or
waters, nor shall trees or shrubs  (planted within highway
right of way) be destroyed in constructing such utility.
247.185 Sec. 15.  Construction of a utility is prohibited on
State land in a wilderness area.  PA 241.

Fire Prevention

All inflammable or explosive liquids, and other such commodities
shall be disposed of so as not to constitute a fire hazard.
                             A-646
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Hazardous Substance

It is prohibited to introduce any misbranded hazardous substance
into intrastate commerce.  286.454.

Industrial Wastes

A person shall not remove liquid industrial wastes from the
premises of another person unless he is licensed.  323.272
Sec. 2.  Every industrial or commercial entity which discharges
wastes into the water shall have waste treatment or control
facilities.  PA 129.

Water Resource Commission

The Water Resource Commission is authorized to enforce any and
all laws relating to the pollution of the waters of this State.
323.3 Sec. 3.  The commission has the right to investigate and
inspect conditions relating to the pollution of the waters of
the State.  323.4 Sec. 4.

The commission has the authority to expend funds for the exten-
sion or improvement of the State or interstate program for the
prevention and control of water pollution.  323.201 Sec. 1.

Zoning

A county may zone any shoreland and land which is in the county.
281.637 Sec. 7 (under Shorelands Protection and Management Act)

The above legislation contains not only constraints, but also
those laws encouraging the abatement of air and water pollution
and makes provision for the construction of facilities for this
purpose.  The major justification of this legislation is to
insure the public health and safety.

Many of the laws are concerned with authorizing various local
governments and administrators with the power to enforce anti-
pollution laws (including waste disposal legislation).  These
laws are general in nature; exceptions and particular cases of
legislative dispute are not the chief concerns of the State code,

Waste Disposal

Obstructing the navigation of any river or stream by putting
into any such river or stream waste materials is prohibited by
law.  230.4 Sec.  4.  If the water resource commission determines
that hazardous or nuisance conditions are resulting from the
handling or disposal of liquid industrial wastes it can take
action to prevent such conditions.  323. 279 Sec. 9.  Any public
                            A-647
-------
corporation is authorized to accept aid from the U.S. Government
or any agency thereof and from industries for the collection
and disposal of wastes from industry.  323.103 Sec. 3-a.  No
person shall dispose of any refuse at any place except a dis-
posal area licensed as provided in this act.  325.292.  A
license may be obtained from the State Health Commissioner.
325.293.  A person, partnership, corporation, governmental
unit or agency desiring a license to operate a disposal area
must apply to the State Health Commissioner.

Water Pollution

A person shall not discharge into the waters of the State any
liquid or solid materials which render the water unsightly,
noxious, or unwholesome.  323.33 Sec. 3-1; 323.6.  The council
(village) has the authority to provide by ordinance for the
preservation of the purity of the waters.  67.38 Sec. 38.  Any
person who discharges pollutants into State waters may be fined
up to $10,000 for each violation and up to $10,000 per day.
PA 159.  A fund has been established for the control of water
pollution (including treatment works used in treatment of
industrial wastes) to be used by counties, cities, villages,
townships, or other public bodies.  PA 215.
                             A-648
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                            NEVADA

The inclination of Nevada's residents and officials toward
acceptance of a national hazardous waste disposal site is in-
determinable at present but appears doubtful.  Local regulation
predominates, with State agencies mainly licensing and issuing
permits.

Regulation exists in regard to disposal, transportation,  pro-
cessing, and storage of radioactive materials and in regard to
air and water quality and land use, but some areas of environ-
mental control are not regulated; there are regulations on pes-
ticides disposal and storage but not on their transportation or
processing; on disposal and storage of explosives but not on
their transportation or processing; and regulations are totally
lacking on solid wastes and industrial safety.  There are no
existing facilities for disposal of nonradioactive hazardous
materials; however, DOT regulations have been adopted.

The key agency in establishing a hazardous waste management
system is the State Board of Health, which is charged with pre-
paring a Statewide solid waste disposal plan.  Municipalities
and counties will be required to develop local plans, which
are expected to be more strict than State regulations.

The Commission of Environmental Protection has established air
and water quality standards, but even in its own area of juris-
diction it has met with competition from other agencies,  e.g.,
the Lake Tahoe Regional Planning Agency which was established
to form a cooperative set of regulations with California in
regard to water and land use.  Regional planning commissions
are required to adopt a master land use plan, or local govern-
ment can adopt its own plan if not working in conjunction with
a regional commission.

                          Highlights

•  Municipalities, cities, counties and districts boards of
   health are required to develop local solid waste disposal
   plans.  Local disposal regulations can be more strict than
   State regulations.

•  Hazardous wastes are to be stored in water-tight, corrosion
   resistent, tightly covered and clearly labeled containers
   in a safe location inaccessible to the public.

•  Hazardous wastes cannot be deposited at a disposal site with-
   out approval by the health authority.

•  Cities and counties are authorized to abate air pollution as
   a public nuisance.
                            A-649
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          •t is required to discharge radioactive and toxic


151  Counties and cities are given power to regulate and restrict
   land use, with regional planning agencies power superior to
   local governments.

•  State can regulate licensing of persons to receive, process
   or transfer radioactive materials.

•  Storage of explosives or combustible material within any
   incorporated area can be prohibited by 10% of the residents.

•  A city council may regulate or prohibit the storage of any
   explosive, combustible, or inflammable material in or trans-
   ported through the city.

«  Nevada requires registration of pesticides but does not have
   specific regulation relating to transportation or disposal.

•  State can regulate surface transportation of hazardous
   materials.

•  Nevada has ambient and emission air quality standards with
   a permit required for discharge.

•  Water discharge permits are required.

                 Law Library Search Findings

Solid Waste Disposal

Statewide authority for regulation of solid waste disposal is
vested in the State Board of Health.  It is charged with
adopting regulations concerning solid waste management systems,
NRS 444.560.

Municipalities (counties and/or cities) and district boards of
health (one or more counties) are required to develop local
solid waste disposal plans, NRS 444.510.  Clark and Washoe,
the two most populated counties in the State, have begun their
plans.  Local disposal regulations can be more strict than
State regulations, NRS 444.580.

No statewide solid waste plan has been made.

The Bureau of Environmental Health within the State Board of
Health recently issued proposed solid waste regulations.  They
heve not been officially adopted.
                             A-650
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                                       AGENCY RESPONSIBILITY
   NEVADA
              I
PUBLIC
SERVICE
COMMISSION
                   TRANSPORTATION
 ADOPTS AND ADMINISTERS
 REGULATIONS FOR SURFACE
 TRANSPORTATION
 OF HAZARDOUS MATERIALS.
| DOT REGULATIONS HAVE
 BEEN ADOPTED.
STATE  BOARD
OF HEALTH
COMMISSION OF
ENVIRONMENTAL j
PROTECTION     i
MISCELLANEOUS
                                  PROCESSING
                          LICENSES PERSONS TO RECEIVE,
                          PROCESS, OR TRANSFER
                          RADIOACTIVE MATERIALS.
       STORAGE/DISPOSAL
                          HAS ESTABLISHED AMBIENT
                          AND EMISSION AIR QUALITY
                          STANDARDS.  A PERMIT IS
                          NECESSARY FOR AIR EMISSIONS2
                          THE COMMISSION  HAS PROPOSED
                          INTRASTATE WATER QUALITY
                          STANDARDS.  WATER  DISCHARGE
                          PERMITS WILL BE REQUIRED.  __

                          COUNTIES MAY REQUIRE
                          STRICTER AIR QUALITY
                          STANDARDS THAN  ADOPTED BY
                          THE COMMISSION.3

                          CITIES AND COUNTIES ARE
                          AUTHORIZED TO ABATE AIR
                          POLLUTION AS A  PUBLIC
                          NUISANCE.4
PREPARING A STATEWIDE SOLID
WASTE DISPOSAL PLAN.  PROPOSED
REGULATIONS FOR DISPOSAL OF
HAZARDOUS WASTES  REQUIRE SPECIAL
CONTAINERS AND PRIOR
BOARD APPROVAL.
COUNTIES AND CITIES ARE
AUTHORIZED TO ZONE 5

STORAGE OF EXPLOSIVE OR COMBUSTIBLE
MATERIALS WITHIN ANY INCORPORATED
AREA CAN BE PROHIBITED BY 10 PERCENT
OF THE RESIDENTS THEREIN.6 CITY
COUNCILS MAY REGULATE OR PROHIBIT
STORAGE  AND/OR TRANSPORTATION OF
ANY EXPLOSIVE, COMBUSTIBLE, OR IN-
FLAMMABLE MATERIAL7

NEVADA JOINED WITH CALIFORNI  IN
CREATING THE  TAHOE REGIONAL  PLANNING
AGENCY WHICH IS PREPARING A REGIONAL
LAND-USE PLAN FOR THE LAKE TAHOE AREA.
THE INTERIM PLAN MAY BE ENFORCED  BY
ORDINANCES.  COUNTIES AND CITIES
MUST ENFORCE THE PLAN.
                                        'THE COMMISSION HAS ADOPTED 49CFR m-ira,  177,  178,  390-397
                                        2NRS 445.491

                                        3NRS 445.546

                                        4NRS 268.410,  244,361

                                        5NRS 278.250
                                        ^RS 476.060

                                        7NRS 266.310
                                              A-651
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The proposed regulations  (1.4) define hazardous wastes as
"those wastes tha,:. can cause  injury, disease, or property
damage, including but not limited to, explosives, pathological
wastes, radioactive materials and chemicals".  Hazardous wastes
are to be "stored in water-tight, corrosion resistent, tightly
covered and clearly labeled containers in a safe location,
inaccessible to the public.   In addition, medical wastes shall
be stored in cleanable containers with liners approved by the
health authority," 3 3.4.  Hazardous wastes cannot be deposited
at a disposal site without approval by the health authority,
2.6.1  (a).

Air Pollution Controls

The Commission of Enviionmental Protection and its administra-
tive arm, the Bureau of Environmental Health, administer the
State air pollution law.s.  It has authority to "establish such
emission control requirements as may be necessary to prevent,
abate, or control air po'llution", NRS' 445. 461 (9) .  County air
pollution programs are a.lso required, NRS 445.546.  The counties
can apparently require stricter standards than State require-
ments, NRS 445.-46 (2) (a) .\ The Nevada statewide air pollution
implementation plan has nt,een approved by EPA.  A
permit is required to discharge radioactive and toxic wastes,
NRS 445.275.

Land Use Control

Counties and cities are given power to "regulate and restrict
the improvement of land and to control the location and sound-
ness of structures", NRS 278.020.  Regional planning agencies
are also authorized.  Their land use powers are superior to
those of local government bodies, NRS 27/c*.024, .025.  A Lake
                             A-652
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Tahoe Regional Planning Agency exists with California, NRS 278.
024.  A copy of the legislation and further discussion is in-
cluded with the California land use material.  Regional planning
commissions are required to adopt a master plan, NRS 278.150.
Cities and counties can adopt their own master plan if they do
not act in conjunction with a regional planning authority,
NRS 278.240.  Counties and cities are authroized to zone to
carry out the plan, NRS 278.250.  Special use permits are avail-
able, NRS 278.315.

Radiation Control

NRS 459.040 gives the State Board of Health power to regulate
licensing of persons to receive, process, or transfer radioactive
materials.  Records relating to receipt, storage, transfer, and
disposal of radioactive source materials, and also exposure of
personnel, are required, NRS 459.060.

Western Interstate Nuclear Compact

This is a body designed to encourage, assist, and guide develop-
ment of nuclear development in the western States.  The coordi-
nating agency, the Western Interstate Nuclear Board, has no
regulatory powers, NRS 459.200.

Explosives and Inflammable Materials

Storage of explosive or combustible materials within any incor-
porated area can be prohibited by 10 percent of the residents,
NRS 476.060.

A city council may "regulate or prohibit the storage of any
explosive, combustible, or inflammable material in or trans-
ported through the city", NRS 266.310.

Pesticides

Nevada requires registration of pesticides but does not have
specific regulations relating to transportation or disposal.

Transportation of Hazardous Materials

The Nevada Public Service Commission has adopted parts 171-173,
177, 178, and 390-397 of Title 49 of the Code of Federal Regu-
lations to regulate surface transportation of hazardous mate-
rials.

Nuisances

Nevada's nuisance statute is quite broad, NRS 40.140.  Any
person "whose property is injuriously affected or whose personal
                            A-653
-------
enjoyment is lessened by the nuisance" may bring an action for
abatement and damages.  A nuisance is defined as "anything which
is injurious to health, or indecent and offensive to the senses,
or an obstruction to the free use of property so as to inter-
fere with the comfortable enjoyment of life or property".

NRS 244.360 provides for a hearing before county commissioners
when a nuisance is alleged to exist.  If a nuisance is found to
exist, the cost of abatement can be assessed against the pro-
perty.

Public nuisances are defined by statute, NRS 202.450.  A
hazardous waste processing or disposal site would presumably
be "lawfully done" and hence would not fall within the terms
of the statute, NRS 202.450.
                             A-654
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                          NEW JERSEY

The State of New Jersey appears favorably inclined toward
acceptance of a hazardous waste management system through its
primary agency, the Department of Environmental Protection.
That agency sets standards of air and water quality,  issuing
permits for construction of pollution control apparatus and
construction and operation of incinerators; it also requires
a bill of lading for all shipments of waste chemicals and
handles other miscellaneous permits and licenses.

Land use is primarily regulated by municipalities via zoning
ordinances.  Lacking regulations are transportation,  processing
and storage of pesticides and also of air and water emissions;
industrial safety regulations are under development,  as are
State land use regulations.

One State official commented that a considerable amount of
illegal disposal exists which is very difficult to police and
control.  Most of the regulations in effect are enforced in-
directly by permitting and licensing activities of the DEP
rather than directly enforced by officials or their agents.

                          Highlights

•  State requires bill of lading before any industrial wastes
   can be transported or disposed of.

•  Any processing facility would have to meet water and air
   quality control standards.

«  State requires placarding of dangerous materials in confor-
   mance with I.C.C. standards.

•  State sets standards and issues permits for the construction
   and operation of incinerators.

•  Municipalities can regulate land use.

•  State requires registration for all solid waste collectors
   and handlers.

»  State requires permit for liquid storage tanks over 10,000
   gallons.

•  State requires registration of all sources of radiation.
                             A-655
-------
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                                                A-656
-------
                           NEW YORK

Any State which will be considering steps to take in order to
best assimilate a national hazardous waste disposal system into
its existing legislative structure would be wise to follow the
lead of the State of New York.  With an eye to later adopting
a national hazardous waste disposal system, New York in the
fall of 1972 consolidated all its existing regulations pertain-
ing to environmental protection, vesting them in the newly
created Department of Environmental Conservation.  This depart-
ment emphasizes consideration of the impact of disposal of all
types of wastes on water quality and directs all activities to
conform to its standards; these are expected to become even
more stringent.

Areas in which regulation is lacking include the transportation,
processing, and storage of pesticides, water and air emissions,
and statewide land use zoning which is under development.   There
are existing facilities for both radioactive and other hazardous
waste materials; New York presently is burying low-level radio-
active and other hazardous waste materials but storing high-
level wastes.

Specific exceptions to the location of sites for hazardous
waste disposal are the mountain resort areas of the Adirondacks
and the Catskills.

                          Highlights

•  State sets standards and is responsible for issuing permits
   and monitoring discharges for air and water quality.

•  State Regulates control and labeling of pesticides.

•  City, village, thruway authority, county park commission,
   bridge authority, Department of Parks and Recreation, and
   Department of Environmental Conservation may regulate trans-
   portation of hazardous material under its jurisdiction.

•  State requires bill of lading for shipment of all hazardous
   materials.

•  Unconsolidated laws state that no person shall transport any
   hazardous substance which is likely to endanger any person
   or property.

•  New York is presently burying low-level radioactive wastes
   and storing high-level wastes.

•  The forest preserves in the Adirondacks and in the Catskills
   will not be acceptable for hazardous waste disposal.
                             A-657
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AGENCY RESPONSIBILITY
NEW YORK
DEPARTMENT OF
ENVIRONMENTAL
OBSERVATION


















DEPARTMENT OF
TRANSPORTATION



DEPARTMENT OF
MOTOR VEHICLES





DEPARTMENT OF
LABOR



DEPARTMENT OF
PUBLIC SERVICES
MISCELLANEOUS)
COMMENTS






















TRANSPORTATION
ISSUES PERMITS FOR PIPE-
LINE CONSTRUCTION
REQUIRES REGISTRATION
OF PESTICIDES FOR
SHIPPING
REQUIRES BILL OF LADING
FOR ALL HAZARDOUS
MATERIALS IN SHIPMENT
DEVELOPING PERMIT AND
PLACARDING SYSTEM FOR
VEHICLES HAULING MAT-
ERIALS HAZARDOUS TO THE
ENVIRONMENT

REQUIRES REGISTRATION
Of ALL VEHICLES USED BY
WASTE SCAVENGERS








PLANS AND ADMINISTERS
PUBLIC SAFETY PROGRAM
FOR RAIL AND MOTOR
CARRIERS IN INTRASTATE
COMMERCE
REQUIRES CONSPICUOUS
PLACARD ING OF ALL HIGH-
WAY VEHICLES CARRYING
DANGEROUS MATER IALS
REGULATIONS FOR THE
CONSTRUCTION AND
EQUIPPING OF SUCH VEHIC
REQUIRES A LICENSE FOR
TRANSPORTING EXPLOSIVES
NOT MOVING UNDER FEDERAL
REGULATIONS



NAVIGATION LAWS PROHIBIT
CARRYING EXPLOSIVES AND
BURNING FLUIDS OR ANY
DANGEROUS ARTICLES ON
SHIPS CARRYING PASSEN-
GERS
GENERAL BUSINESS LAWS
PROHIBIT THE TRANSPORT
OF DANGEROUS ARTICLES IN
AIRCRAFT EXCEPT AS IN
CONFORMANT WITH FEDERAL
REGULATIONS
VEHICLE AND TRAFFIC LAWS
"THE TRANSPORTATION Of
COMBUSTIBLES, CHEMICALS.
EXPLOSIVES . OR OTHER
DANGEROUS MATERIALS MAY
BE REGULATED BY ANY CITY,
VILLAGE, THRUWAY AUTH-
ORITY, BRIDGE AUTHORITY
ON ANY HIGHWAY IN ITS
JURISDICTION
UNCONSOLIDATEDLAWS -
PROVIDES THAT NO PERSON
SHALL TRANSPORT ANY OF
NUMEROUS HAZARDOUS SUB-
STANCES AT SUCH TIMES OR
IN SUCH A MANNER OR CON-
DITION AS TO ENDANGER
UNREASONABLE OR TO BE
LIKELY TO PERSONS OR
PROPERTY








PROCESSING
ESTABLISHES, ENFORCES
WATER QUALITY STNOS
ESTABLISHES, ENFORCES
AIR QUALITY STNDS
ISSUES AND MONITORS
DISCHARGE PERMITS FOR
MAINTAINING WATER QUALITY
ASSISTS LOCALITIES IN
DEVELOPING PLANS FOR
LAND USE


























RESPONSIBLE FOR THE HEALTH
AND SAFETY OF ALL EMPLOY-
EES IN FACTORIES
IN HANDLING STORAGE AND
MANUFACTURE OF EXPLOSIVES
SUPERVISES OPERATION OF
UTILITIES FOR SAFETY
NUCLEAR FUEL SERVICES
INC HAS A NUCLEAR RE
PROCESSING PLANT AT THE
N.Y. ATOMIC AND SPACE
DEVELOPMENT AUTHORITY -
WESTERN N.Y NUCLEAR
SERVICE CENTER, WEST
VALLEY 13300 ACRE
NUCLEAR INDUSTRIAL
RESERVATION)
ENVIRONMENTAL SYSTEMS IS
A COMPANY IN SYRACUSE
THAT IS GOING TO HANDLE
PETROLEUM WASTES IIT
MOVED IN FROM BOSTON!
CHEM-TROL POLLUTION
SERVICES. INC IS PRO-
CESS ING A LARGE VARIETY
OF INDUSTRIAL WASTES AND
HAVE »E£N USED TO DISPOSE
OF SELECTED WASTE PEST-
ICIDES. THEY ARE IM-
PORTING WASTES (ETCHING
WASTES) FROM AS FAR AWAY
AS THE STATE Of WASH
PRS SYSTEMS, INC HAS
DESIGNED A PORTABLE HIGH
TEMPERATURE INCINERATOR
FOR DISPOSAL OFTOXIC
WASTES. N Y. STATE AND
PRS HAVE A JOINT PRO-
POSAL INTO EPA FOR A
PI LOT OPERATION TO
APPLY IT* TECHNOLOGY
IN GENERAL, THE DISPOSAL
OF INDUSTRIAL WASTES IN
N.Y IS BEING FOCUSSED
UPON PRIVATE, ECONOMIC
ACTIVITY IN RECYCLING,
PROCESSING AND DISPOSAL
DISPOSAL/STORAGE
ISSUES PERMITS AND MON-
ITORS DISCHARGES INTO
THE AIR AND WATER AND
INTO ANY LAND AREA WHICH
MAY AFFECT THE GROUND OR
SURFACE WATERS
REGULATE STORAGE AND
DISCHARGE OF MATERIAL
"HAZARDOUS TO THE ENV-
IRONMENT' (LISTING OF
SUBSTANCES NOT COMPLETE
AT THIS TIME)
PROVIDE GRANTS FOR
STUDY AND PLANNING TO
ASSIST LOCAL COMMUNITIES
IN DESIGN AND LOCATION
OF SOLID WASTE DISPOSAL.
REGULATE ACTIVITIES OF
WASTE SCAVENGERS - ALL
DISPOSAL MUST BE IN SITES
APPROVED «Y THE 0£PT
ISSUE PERMITS AND REG-'
ULATES LEASING OF UNDER-
GROUND STORAGE SITES
(GAS STORAGE)



















NY HAS A SITE IN USE FOR
BURYING LOW LEVEL RADIO-
ACTIVE WASTE AND IS
STORING HIGH LEVEL WASTE
THERE IS A LARGE AMOUNT
BANNED OR DEFECTIVE
PESTICIDES BEING HELD
BY INDIVIDUALS IN ANTIC-
IPATION Of THE DEVELOP
MENT OF STATE DISPOSAL
FACILITIES
WASTES AFFECTING FISH
OR FINFISH SHALL NOT BL
ALLOWED INTO THE WATERS
Of THE MARINE DISTRICT
THE FOREST PRESERVES IN
THE ADIRONDACK AND IN
THE CATSKILLS WILL NOT
BE ACCEPTABLE AREAS
FOR ESTABLISHING ANY
DISPOSAL ACTIVITY
















MISCELLANEOUS COMMENTS
OUTSIDE OF THE SAFETY
ASPECTS OF TRANSPORTATION
AND MANUFACTURE THE OEPT.
Of ENVIRONMENTAL CONS. IS
RESPONSIBLE FOR ALL THE
ESSENTIAL ELEMENTS"* ANY
HAZARDOUS WASTE DISPOSAL
SYSTEM
DEC APPEARS FAVORABLY
INCLINED TOWARD A NATIONAL
SYSTEM FOR THOSE MATERIALS
WHICH DON'T LEND THEMSELVES
TO EASY HANDLING OR RECOVERY.































NEW YORK HAS ONE Of
THE MOST ADVANCED
PESTICIDE CONTROL
LAWS IN THE COUNTRY
ICOPY ENCLOSED)













'





      A-658
-------
                     Library Search Findings

Environmental Conservation Law

The Environmental Conservation Law took effect September 1,
1972.  This law consolidates various regulations scattered
throughout the State statutes and transfers them to the Depart-
ment of Environmental Conservation (DEC).  The Department sets
water standards and is responsible for the issuing and monitor-
ing of discharge permits.  Discharges are prohibited and require-
ments for permits for new discharges are discussed in §17-0501,
0503, 0505, 0507, 0509, 0511, and 0701.  The Department also
has responsibility for sales and regulations applying to the
storage of liquids likely to pollute waters, including regula-
tions on construction, maintenance, diking, etc.  §17-0303.

The Department of Environmental Conservation also establishes
rules and regulations for controlling, preventing, and prohib-
iting air pollution (standards included), and regulates the
leasing of underground storage areas for gas.  §23-1301, 1303,
1305, 1307.  Article 27 of the Environmental Conservation Law
deals, in part, with solid industrial wastes and industrial
waste scavangers.  The DEC has several regulations concerning
the control and labeling of pesticides.  Recently added respon-
sibilities of DEC are in regard to hazardous substances.  §320.

Navigation Law

Passenger-carrying ships are prohibited from carrying "explosive
burning fluids or dangerous articles".  §66.

General Business Law

Transportation of explosives and other dangerous articles pro-
hibited in aircraft except when in conformance with Federal
regulations.  §245.

Vehicle and Traffic Law

Definition of dangerous articles, including hazardous substances,
Amendment also recorded and attached.  §380.  Requires that
vehicles carrying explosive substances of flammable liquids
-top at railroad crossings.  29§1171.

""he "transportation of combustibles,  chemicals, explosives,
vr*f lammables, or other dangerous substances, articles, compounds
-;r mixtures" may be regulated by any city, village (Article 39-
§1642), thruway authority, county park commission, bridge
authority, the Department of Parks and Recreation, or the Depart-
ment of Environmental Conservation on any highway under its
                             A-659
-------
jurisdiction (Article 38-§1630).

Unconsolidated Law

Provides that no person shall transport any of numerous hazard-
ous substances "at such time or  place or in such a manner or
condition as to endanger unreasonably or so as to be likely to
endanger unreasonably persons or property".  Title 17-§6808.

Labor Law

The Department of Labor requires a license for transporting
explosives not already being moved under Federal regulation.
                             A-660
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                            OREGON

The inclination of the residents and officials of Oregon to
embrace a national hazardous waste disposal system is difficult
to determine at present, due to the strong influence of local
environmental control.  For example, the Board of County Commis-
sioners in any county is authorized to regulate disposal of
solid wastes; cities and counties are authorized to regulate
land use by zoning and to create planning commissions; and
regional air pollution control authorities may set standards
for air quality.  However, all hazardous disposal sites must
be deeded to the State, and most licensing and permitting re-
sponsibilities are placed in the jurisdiction of the State.

The key hazardous waste management implementation agency for
Oregon is the Department of Environmental Quality, which has
set discharge and ambient air and water quality standards and
has specified regulations for processing and disposal of hazard-
ous materials.  It stipulates that wastes generated outside
Oregon cannot be processed within the State without its specific
approval.

Lacking regulations presently are the processing of pesticides;
the transportation, processing, and storage of radioactive
materials; the processing of explosives; and the handling of
hazardous materials from an industrial safety aspect.  There
are no existing facilities for disposal of radioactive or other
hazardous wastes.  However, the Oregon Nuclear and Thermal
Energy Council has been authorized to "regulate the transporta-
tion process for all radioactive material derived from or des-
tined for nuclear installations", but has not as yet adopted any
regulations.  This authority appears to be in conflict with that
granted to the Public Utility Commission which has adopted DOT
regulations in this area.

Although there is no specific shoreline land use regulation,
the State Highway Commission's approval must be obtained before
instituting improvements on ocean shorelines or on land within
one-quarter of a mile of scenic waterways.

Oregon is the only State surveyed in the West which has legis-
lation dealing specifically with hazardous waste disposal.
Another unique feature of Oregon's legislative structure is
that the Governor is authorized to regulate land use that is
not otherwise regulated by a State or local agency.
                             A-661
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                          Highlights

^  Disposal of hazardous wastes requires DEQ or health depart-
   ment permission.

•  Hazardous waste containers must be adequately identified.

•  Board of County Commissioners in any county is authorized
   to regulate and abate solid wastes.

•  A license from DEQ is required to operate a disposal site
   for hazardous materials.

•  All hazardous disposal sites must be deeded to State.

•  State authorized to require permits for sources of air
   contaminants.

•  Regional Air Pollution Control Authorities are authorized
   to set standards for water quality and purity.

•  A permit is required to discharge any waste into waters of
   the State.

•  Discharge and ambient air and water quality standards have
   been adopted.  Permits are required to discharge.

•  Cities and counties are authorized to regulate land use.

•  Governor is authorized to regulate land use which is not
   regulated by other agencies.

•  Oregon has recently adopted innovative legislation on hazard-
   ous wastes disposal.

•  Oregon's Nuclear and Thermal Energy Council has authority
   to assess environmental issues in this area.

                 Law Library Search Findings

Solid Waste Disposal

Statewide solid waste disposal activities are administered by
the Environmental Quality Commission and the Department of
Environmental Quality  (DEQ).  ORS 459.025.  The Commission is
authorized to adopt "regulations governing the accumulation,
storage, collection, transportation and disposal of solid
wastes..."  ORS 459.045(a).

Hazardous wastes are defined in the regulations as being danger-
ous materials not including environmentally hazardous wastes
                             A-662
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AGENCY RESPONSIBILITY
OREGON
PUBLIC
UTILITIES
COMMISSION
DEPARTMENT
OF
ENVIRON-
MENTAL
QUALITY
STATE FIRE
MARSHALL
NUCLEAR AND
THERMAL
ENERGY
COUNCIL
MISCELLANEOUS
TRANSPORTATION
DOT REGULATIONS FOR
TRANSPORTATION OF
HAZARDOUS MATERIALS
ARE IN THE PROCESS
OF BEING ADOPTED1

HAS ADOPTED
REGULATIONS FOR THE
STORAGE AND
TRANSPORTATION OF
EXPLOSIVES AND
FLAMMABLE MATERIALS
AUTHORIZED TO REGULATE
TRANSPORTATION OF
RADIOACTIVE MATERIAL
TO AND FROM ANY
NUCLEAR INSTALLATION

PROCESSING

DISCHARGE AND AMBIENT AIR AND
WATER QUALITY STANDARDS HAVE
BEEN ADOPTED. PERMITS ARE
REQUIRED FOR DISCHARGE INTO
WATER. AIR EMISSION STANDARDS
HAVE BEEN ESTABLISHED FOR A
VARIETY OF POLLUTANTS. UNLESS
A VARIANCE IS GRANTED, THE
HIGHEST AND BEST POSSIBLE
POLLUTION CONTROL IS REQUIRED.
DISCHARGE OF TOXIC WASTES INTO
PUBLIC WATERS IS PROHIBITED.



STORAGE/DISPOSAL

THE DEPARTMENT HAS ADOPTED SPECIFIC
REGULATIONS FOR THE PROCESSING AND
DISPOSAL OF HAZARDOUS MATERIALS.
ALL HAZARDOUS MATERIAL MUST BE
DECONTAMINATED OR DISPOSED OF ON
STATE-OWNED LAND BY AN OPERATOR
LICENSED BY THE STATE. WASTES
GENERATED OUTSIDE OREGON CANNOT BE
PROCESSED WITHOUT SPECIFIC APPROVAL
FROM THE DEPARTMENT 2


COUNTIES AND CITIES ARE AUTHORIZED
TO ZONE. THE GOVERNOR 1 S
AUTHORIZED TO REGULATE LAND USE
IN AREAS NOT REGULATED BY CITIES
OR COUNTIES.3
IMPROVEMENTS ON OCEAN SHORELINES
OR WITHIN ONE-QUARTER MILE OF
SCENIC WATERWAYS MUST BE APPROVED
BY THE STATE HIGHWAY COMMISSION.*
1
  49CFR 177,  390-393,  395-397
2ORS 459.-410 - 459.690
3,
 ORS 215.505
4ORS 390.640,  390.845
       A-663
-------
p^ defined in ORS 459.410(6), 61-010(7).   Disposal of hazardous
wastes requires DEQ or health department permission.  61-060(2),
Hazardous waste containers must be adequately identified.
61-07-(5), (6).

The board of county commissioners in any county is authorized
to regulate and abate solid waste on private property in
unincorporated areas as a public nuisance.  ORS 495.120,
459.150.

Permits for waste disposal sites must be obtained from the
Department of Environmental Quality.  ORS 459.205.

Hazardous Wastes

Oregon is the only western State which has legislation dealing
specifically with hazardous waste disposal.   ORS 62 (copy
attached).

Defined environmentally hazardous wastes include pesticides,
radioactive material, toxic materials, and containers for any
of these materials.  ORS 459.410(6), 62-010(6).

The Department of Environmental Quality is given broad powers
to regulate disposal of hazardous wastes.  ORS 459.430,  .440.

A license from DEQ is required to operate a disposal site for
environmentally hazardous wastes.  ORS 459.510.  Detailed
application forms must be completed and public hearings held.
62-025, 62-035.  The license is issued after approval by the
Environmental Quality Commission.  "As a condition of issuance
of the license, the licensee must deed the disposal site to the
State, title to be taken in the name of the State of Oregon."
ORS 459.590(1).

Air Pollution

The Department of Environmental Quality administers air
pollution control law on a statewide basis.   It is authorized
to require permits for sources of air contaminants, ORS  449.
727(1), and monitoring of air discharges, ORS 449.702.   It is
also authorized to establish air purity standards in appro-
priate portions of the State, ORS 449.785.  Regional air
quality control authorities are authorized by ORS 449.855.
Regional standards cannot be less strict than standards
adopted by the DEQ.  ORS 449.855(2).

Prior to the recent non-degradation court case, Oregon's
clean air implementation plan had been fully approved by EPA.
                            A-664
-------
 : -;ri-"t air pollution standards apply to areas designated as
••7i.".darness areas by the U.S. Congress.  13-020.

7
-------
Ownership of ocean beaches in Oregon up to the ordinary high
tide line is vested in the State.  ORS 390.615.  Improvements
on the ocean shoreline up to the line of vegetation must be
approved by the State Highway Engineer.  ORS 390.640.

Oregon has designated certain river segments as scenic water-
ways.  ORS 390.825.  Improvements within one-fourth mile of
scenic waterways must be approved by the State Highway Commis-
sion.  ORS 390.845.

The Oregon Coastal Conservation and Development Commission was
created in 1971.  ORS 191.120.   Its primary mission is to pre-
pare a comprehensive plan "for the preservation and develop-
ment of the natural resources of the coastal zone".  ORS 191.
140(2).  Further information is in the Study Design prepared
for the Commission.

Nuisances

Persons adversely affected by private nuisances are given a
statutory right to bring an action for damages and abatement.
ORS 105.505.

Pollution of State waters, discharges into waters thereby
reducing quality below applicable standards, and violation of
a waste discharge permit are designated as public nuisances.
ORS 459.079.

Explosives

The Oregon State Fire Marshall has adopted regulations appli-
cable to the storage and transportation of explosives and
flammable materials.  ORS 480.050, .060 prohibits transporta-
tion of certain explosives by common carriers engaged in
carrying passengers.

Radiation

The Oregon Nuclear and Thermal Energy Council is authorized to
"regulate the transportation process for all radioactive
material derived from or destined for any nuclear installation",
ORS 453.535.  Regulations have not yet been adopted.  The
authority granted the Council appears to conflict with author-
ity granted the Public Utility Commission, according to the
Council's coordinator.

Pesticides

The Department of Agriculture "is authorized to take all
measures or to make any seizure or embargo necessary and proper
                             A-666
-------
uo protect property,  or  the health or life of animals or humans,
from the  incorrect sale, storage, handling, transporting, dis-
posal,  (other  than as provided in the solid waste legislation,
ORS 459)  or use of pesticides, residues from the manufacture
of pesticides  or  other dangerous chemicals".  ORS 634.350.

Transportation of  Hazardous Materials

Oregon  is in the  process of adopting 49 CFR 177, 390-393, and
395-397 relating  to transportation of Hazardous material.

Industrial Regulations

Minimal regulations exist for protecting workers from hazardous
materials with which they may come in contact.  CH. 333, 22-038,
-040.

Oregon Legislation Specifically Dealing with Hazardous Waste
Disposal

CH 340, 62-005,-045.

   "62-010 PURPOSE.   The purpose of these regulations is to
   prescribe uniform procedures for obtaining licenses from
   the  Department  of Environmental Quality for establishing
   and  operating  environmentally hazardous waste disposal
   sites  and facilities  as prescribed by ORS 495.410-459.690."

   "62-010 DEFINITIONS.   As used in these regulations unless
   otherwise required by context:

       (1) "Commission" means the Environmental Quality Commission
       (2) "Department" means the Department of Environmental
          Quality.
       (3) "Director"  means the Director of the Department of
          Environmental  Quality.
       (4) "Dispose" or "Disposal" means the discarding,  treat-
          ment, recycling or decontamination of environmentally
          hazardous wastes or their collection, maintenance or
          storage  at a disposal site.
       (5) "Disposal Site" means a geographical site in or upon
          which environmentally hazardous wastes are stored or
          otherwise disposed of in accordance with the provi-
          sions of ORS 459.410-459.690.
       (6) "Environmentally Hazardous Wastes" means Environmen-
          tally Hazardous Wastes as defined by ORS 459.410,
          which includes discarded, useless or unwanted  pesti-
          cides or pesticide residues, low-level radioactive
          wastes  and receptacles and containers used therefor,
          that, because  of their high concentration and/or per-
          sistence of toxic elements or other hazardous  proper-
                             A-667
-------
       ties,  and which have not  been detoxified or  cannot
       be detoxified by any practical means, may be classi-
       fied  by  the Environmental  Quality Commission as
       Environmentally Hazardous  Wastes pursuant to ORS
       459.410,  but shall not  include Environmentally
       Hazardous Wastes which  have  been detoxified  by
       treatment,  reduction in concentration of the toxic
       element  or  by any other means and formally declassi-
       fied  by  the Environmental  Quality Commission as no
       longer hazardous to the environment.
   (7) "License" means a written  license issued by  the
       Commission, bearing the signature of the Director,
       which  by  and pursuant to  its conditions authorizes
       the licensee to construct, install, modify or
       operate  specified facilities or conduct specified
       activities  for disposal of environmentally hazardous
       wastes.
   (8) "Person"  means the United  States and agencies
       thereof,  any state, any individual, public or private
       corporation, political  subdivision, governmental
       agency,  municipality, industry, copartnership,
       association, firm, trust,  estate or any other legal
       entity whatsoever."

"62-015 LICENSE  REQUIRED.

   (1) No person shall dispose of environmentally hazardous
       wastes upon any land in the  state other than real
       property  owned by the State  of Oregon and designated
       as a  disposal site pursuant  to the provisions or
       ORS 459.410-459.690 and these regulations.
   (2) No person shall establish  or operate a disposal
       site  without a license  therefor issued by the
       Commission  pursuant to  ORS 459.410-459.690 and these
       regulations.
   (3) Licenses  issued by the  Department shall establish
       minimum  requirements for  the disposal of environ-
       mentally  hazardous wastes, limits as to types and
       quantities  or materials to be disposed, minimum
       requirements for operation,  maintenance, monitoring
       and reporting and supervision of disposal sites, and
       shall  be  properly conditioned to ensure compliance
       with  pertinent local, state  and federal standards
       and other requirements  and to adequately protect
       life,  property and the  environment.
   (4) Licenses  shall be issued  to  the applicant for the
       activities, operations, emissions or discharges of
       record,  and shall be terminated automatically upon
       issuance  of a new or modified license for  the same
       operation.  "
                           A-668
-------
" 52-07,0 NECESSITY FOR A DISPOSAL SITE.  Any person  proposing
to establish  or obtain a license for a disposal  site for
Environmentally Hazardous Wastes shall prepare and  submit to
the Department a detailed report with supporting information,
justifying  the necessity for  a  disposal site as  proposed,
including anticipated sources of wastes and types and quanti-
ties of wastes to be disposed.   Environmentally  Hazardous
Wastes generated outside the  State of Oregon and proposed to
be imported  for disposal in Oregon shall receive specific
approval by  the Environmental Quality Commission prior to
said disposal."

"62-025 APPLICATION FOR LICENSE.

   (1) Any person wishing to  obtain a new modified  or renewal
       license from the Department shall submit  a minimum of
       eight  (8) copies of a  written application on forms
       provided by the Department.  All application forms
       must  be completed in full, signed by the  applicant or
       his authorized representative and shall be accompanied
       by a  minimum of eight  (8) copies of all required
       exhibits.
   (2) An application for a license shall contain but not be
       limited to:
       (a) The name and address of the applicant and person
       or persons to be directly responsible for the opera-
       tion  of the disposal site.
       (b) A  statement of financial condition of the appli-
       cant,  prepared by a certified public accountant and
       including assets, liabilities and net worth.
       (c) The experience of  the applicant in construction,
       management supervision or development of  disposal
       sites  for environmentally hazardous wastes and in
       the handling of such substances.
       (d) The management program for the operation of the
       disposal site, including the person or persons to be
       responsible for the operation of the disposal site
       and a  resume of his qualifications, the proposed
       method  of disposal, the  proposed method of pretreat-
       ment  or decontamination  upon the disposal site, if
       any,  and the proposed  emergency measures  and safe-
       guards  to be provided  for the protection  of  the
       natural resources, the public and the employees at
       the disposal site.
       (e) A  schedule and description of sources, types and
       quantities of material to be disposed and detailed
       procedures for handling  and disposal of each.
       (f) A  description of the size and type of facilities
       to be  constructed upon the disposal site, including
       the height and type of fencing to be used, the size
       and construction of structures or buildings,  warning
                            A-669
-------
    signs, notices  and alarms to be  used,  the type of
    drainage and  waste treatment facilities and maximum
    capacity of such facilities, the  location and source
    of each water supply to be used  and  the location and
    the type of fire control facilities  to be provided at
    such site.
    (g) A preliminary engineering sketch and flow chart
    showing porposed plans and specifications for the con-
    struction and development of the  site  and the waste
    treatment and water supply facilities, if any, to be
    used at such  site.
    (h) The exact location and place  where the applicant
    proposes to operate and maintain  the disposal site,
    including the legal description  of  the lands included
    within such site.
    (i) A preliminary geologist's survey report indicating
    land formation,  location of water resources and direc-
    tions of the  flows thereof and his  opinion relating  to
    possible sources of contamination of such water resources
    (j) A proposed  program for continuous  monitoring and
    surveillance  of the disposal site and  for regular
    reporting to  the Department.
(3)  License applications must contain or be accompanied
    by the following:
    (a) A nonrefundable fee of $5,000 which shall be con-
    tinuously appropriated to the Department for adminis-
    trative expenses.
    (b) A proposal  and supporting information justifying
    the amounts of  liability insurance  proposed to protect
    the environment and the health,  safety and welfare of
    the people of this state, including  the names and
    addresses of  the applicant's current or proposed in-
    surance carriers and copies of insurance policies then
    in effect.
    (c) A proposal  and supporting information justifying
    the amount of a cash bond proposed  to  be posted by the
    licensee and  deemed to be sufficient to cover any costs
    of closing the  site and monitoring  it  or providing for
    its security  after closure and to secure performance  or
    license requirements.
    (d) A proposal  and supporting information justifying  the
    proposed fees to be paid to the  Department based either
    on the quantity and type of material accepted at the
    disposal site or a percentage of the fee collected for
    disposal or both, in amounts estimated to produce ov^r
    the period of use of the site for disposal a sum suf-
    ficient to provide for any monitoring  or protection  of
    the site after  closure.
(4)  The Department  may require the submission of such other
    information as  it deems necessary to make a decision  on
                           A-670
-------
       granting,  modifying or  denying a. license.
    (5) Applications which are  incomplete, unsigned  or which
       do  not contain the required exhibits, clearly  identi-
       fied,  may  be excluded from consideration  by  the
       Department at is  [sic]  discretion and the applicant
       shall  be notified in writing of the deficiencies."

"62-030 ENGINEERING PLANS REQUIRED.   Before a disposal site
or operation  may  be established,  constructed, maintained or
substantially modified,  an applicant or licensee must submit
to the Department final  detailed  engineering plans  and speci-
fications,  prepared by a registered professional  engineer,
covering construction and operation of the disposal site and
all related facilities and receive written approval of such
final plans from  the Department."

"62-035 HEARINGS  AND ISSUANCE  OR  DENIAL OF A LICENSE.

    (1) Upon receipt of an application, the Department shall
       cause  copies of the application to be sent to  affected
       state  agencies, including  the State Health Division,
       the  Public Utility Commissioner, the Fish Commission
       of  the State of Oregon,  the State Game Commission and
       the  State  Engineer and  to  such other agencies  or
       persons that the  Department deems appropriate.  ORS
       459.410-459.690 provides  that each agency shall re-
       spond  by making a recommendation as to whether the
       license application should be granted.  If the State
       Health Division recommends against granting  the
       license, the Commission  must deny the license.
    (2) After  determination that  an application for  a  license
       is  complete, the  Department will notify the  applicant
       of  its intent to  schedule  a hearing or hearings and
       the  timetable and procedures to be followed.  The
       Commission shall  conduct  hearings at such other places
       as  the Department considers suitable.  At the  hearing
       the  applicant may present  his application and  the
       public may appear or be  represented in support of or
       in  opposition of  the application.
    (3) Prior  to holding  hearings  on the license  application,
       the  Commission shall cause notice to be given  in the
       county or  counties where  the proposed disposal site
       is  located, in a  manner  reasonably calculated  to
       notify interested and affected persons of the  license
       application.
    (4) The  Department shall make  such investigation as it
       considers  necessary and  following public  hearings make
       a recommendation  to the  Commission as to  whether or
       not  a  license should be  issued.  The recommendations
       of  the Department, including proposed license  provi-
                           A-671
-------
        sions  and conditions  if the Department  recommends
        issuance of a license,  shall be forwarded  to the
        applicant, to members  of the Commission and, at the
        discretion of the Department, to other  interested
        persons for comment.   All comments must be submitted
        in  writing within fourteen (14) days  after mailing
        of  the Department's recommendations if  such comments
        are to receive consideration prior to final action
        on  the application.
   (5)  After  fourteen (14) days have elapsed since the date
        of  mailing of the Department's recommendations and
        after  reviewing the Department's recommendations the
        Commission shall decide whether to issue the license
        or  not.   It shall cause notice of its decision to be
        given  to the applicant  by certified mail at the
        address designated by  him in his application.
   (6)  If  the Commission refuses to issue a  license, it
        shall  afford the license applicant an opportunity
        for hearing after reasonable notice,  served person-
        ally or by registered  or certified mail.  The notice
        shall  contain:
        (a)  A  statement of the party's right  to hearing or
        a statement of the time and place of  the hearing.
        (b)  A  statement of the authority and  jurisdiction
        under  which the hearing is to be held.
        (c)  A  reference to the particular sections of the
        statutes and rules involved.
        (c)  A  short and plain  statement of the  matters
        asserted or charged."

"62-040 RENEWAL, MODIFICATION, TERMIANTION OR  EXPIRATION
OF LICENSE.

   (1)  An  application for renewal, modification or termi-
        nation of a license or to allow a license to expire
        shall  be filed in a timely manner, but  not less than
        ninety (90) days prior to the expiration date of
        the license.  Procedures for issuance of a license
        shall  apply to renewal, modification, termination
        or  expiration of a license except that  public
        hearings will not be  held unless desired by the
        Commission.  A license shall remain in  effect until
        final  action has been  taken by the Commission on
        any appropriately submitted and complete application
        pending before the Commission.
   (2)  In  the event that the  Commission finds  it necessary
        to  modify a license due to changed conditions or
        standards, receipt of  additional information or any
        reason it deems would  threaten public health and
        safety, the Department shall notify the licensee
        or  his authorized representative by certified mail
                           A-672
-------
       of  the  Commission's intent  to  modify the license.
       Such notification shall include  the proposed modifi-
       cation  and the reasons for  modification.  The modi-
       fication  shall become effective  twenty (20) days
       from the  date of mailing of such  notice unless with-
       in  that time the licensee requests  a hearing before
       the Commission.   Such a request  for hearing shall be
       made in writing and shall include the reasons for
       such hearing.  At the conclusion  of any such hearing
       the Commission may affirm,  modify or reverse the pro-
       posed modification."

"62-045 SUSPENSION OR REVOCATION OF A LICENSE.

   (1) Whenever,  in the judgment of the  Department from the
       results of monitoring or surveillance of operation
       of  any  disposal  site, there is reasonable cause to
       believe that a clear and immediate  danger to the
       public  health and safety exists  from the continued
       operation  of the site, without hearing or prior
       notice,  the Department shall order  the operation of
       the site  halted by service  of  the order on the site
       superintendent.
   (2) Within  twenty-four (24) hours  after such order is
       served,  the Department will  appear  in the appropriate
       circuit court to petition for  such  equitable relief
       as  is required to protect the  public health and
       safety  and may commence proceedings for the revocation
       of  the  license of the disposal site if grounds there-
       fore exist.
   (3) In  the  event that it becomes necessary for the
       Commission to suspend or revoke  a license due to
       violation  of any providiosn of ORS  459.410-459.690,
       non-compliance with these rules  or  the terms of the
       license,  the threat of degradation  of a natural re-
       source,  unapproved changes  in  operation, false infor-
       mation  submitted in the application or any other
       cause the  Department shall  schedule a public hearing
       and notify the licensee by  certified mail of the
       Commission's intent to suspend or revoke the license
       and the timetable and procedures  to be followed.  Any
       hearing held shall be conducted  pursuant to the
       regulations of the Department."
                           A-673
-------
                        SOUTH CAROLINA

The State of South Carolina appears favorably inclined toward
establishment of a hazardous waste management system,  although
much of its environmental legislation is incomplete at present.
Areas in which legislation is lacking include the transporta-
tion and processing of radioactive materials; disposal, pro-
cessing, and storage of explosives; and discharge permitting
of air emissions.  Still lacking regulation but under  develop-
ment are the disposal, transportation, processing, and storage
of pesticides; water discharge permitting;  and statewide land
use zoning.  There are existing facilities  for radioactive
material disposal, and facilities for disposal of other
hazardous wastes are being developed.

High-level radioactive wastes may not be disposed of within
the State, but low-level disposal is permissible.  Unique
features of South Carolina environmental regulation include
the requirement that wastewater receive at  least three levels
of treatment and even then not be discharged on the coastline;
also, all State permits (which are required)  for processing
and disposal of wastes must be accompanied  by facility and
process designs prepared by a registered professional  engineer
or geologist.

There appears to be no key agency to handle implementation of
a hazardous waste management system as existing controls are
widely dispersed among several agencies, although responsibi-
lities appear clearly defined.  A State Planning Agency (with
no regulatory power) has,  as in many of the other States
surveyed, overall responsibility to coordinate and review plans
of other State agencies.  Groundwater pollution from landfills
is the responsibility of the Water Resources Commission, where-
as the Pollution Control Authority is responsible for  issuing
air, water, and solid waste disposal permits.  The Department
of Health controls garbage and sewage and also radioactive
material disposal.  Land use is controlled  by local agencies
except for the shoreline.

The PCA supervised the design and construction of a new waste
treatment plant that officials hoped would  be included among
plants envisioned under Section 212 of PL-91-512.

                          Highlights

•  Legislation is currently being drawn up  which would regulate
   toxic pesticide wastes.

•  Current regulation requires secondary and tertiary  treatment
   and prohibits discharge of wastewater on coastline.
                             A-674
-------
o  High-level radioactive wastes may not be disposed of within
   the State although disposal of low-level wastes is permitted,

®  State issues permits for processing and disposal of wastes.
   All permits must be accompanied by facility and process
   design prepared by a registered professional engineer or
   geologist.
                             A-675
-------
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                                  A-676
-------
                            TEXAS

The most distinctive barriers to Texas'  acceptance of a national
hazardous waste management system are that State's strongly
independent attitude (which precludes any inclination toward
establishment of such a system) and the existence of the Texas
Railway Commission and its sphere of influence.  The character-
istic Texas independence would necessitate a public relations
education program of major proportions for the citizenry to
accept a Federally designated site; the Commission's powerful
presence makes Texas probably the only State in the nation in
which the Interstate Commerce Commission is not the ultimate
agency in regard to regulation of transportation.  The Commission
regulates the transportation, processing, storage, and disposal
of the vast amount of waste that is generated as a result of
the activities of the petroleum industry and it also regulates
the disposition of saltwater and brines associated with oil
production.  Although DOT regulations are adopted for trans-
portation, the Commission is the chief adminstrator of these.

Specifically lacking regulation  in Texas are the disposal and
transportation of pesticides, shoreline land use, safety re-
gulations for the handling of hazardous materials, and the
disposal, transportation, processing, and storage of explosives.
The last of these is surprising, in view of the widespread use
of explosives in the State's prime industry, petroleum.

The State Department of Health's Divisions of Air, Water, Solid
Waste, and Radiation regulate indirectly on broad authorizations,
some of which are overlapping.  Responsibility appears to be
based more on tradition and politics than on rational function-
ality-^.g., the Water Quality Board has responsibility for
regulating all sources of water pollution with the exception
of those regulated by the Railroad Commission, and the WQB has
control over industrial solid waste disposal if the industries'
own property is being used; however, if public lands are being
utilized, the State Highway Department has control.  Although
any municipality, county, or private contractor can go into
the solid waste disposal business, no area can be required to
implement a solid waste treatment system.

Texas follows AEC regulations and guidelines for radioactive
wastes, but disposal must be on State or Federal land; the
State Land Office, which approves the use of all land in the
State, will not allow any land to be used as a burial ground
for radioactive material, especially high-level material.
                             A-677
-------
                          Highlights

•  Legislation now exists for the manufacture and use but not
   for the treatment and disposal of hazardous wastes.

•  The Railroad Commission is the political and administrative
   power for the regulation and enforcement of policy concerning
   transportation, processing,  disposal,  and storage of-oil
   and gas, including deep well injection,  a common practice
   in Texas.

•  At present no area can be forced to initiate a hazardous
   waste disposal system.

•  Texas follows AEC guidelines on the handling of nuclear
   wastes; however, they must be handled on State or Federal
   land.

•  Air quality is regulated through the issuance of permits
   for new or modified facilities.
                             A-678
-------
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                               VERMONT

Vermont is probably the most unregulated State of any studied,
partially because of its traditional independent conservatism
but mostly because it is not heavily industrialized and hence
little hazardous waste is generated.

Vermont appears to be disinclined toward establishment of a
national hazardous waste disposal site,  but would welcome
technological assistance in developing ways to dispose of
hazardous materials.

The State has few actual regulations, controlling environmental
pollution mainly through establishment of guidelines and co-
operation among those generating wastes.  Most industrial wastes
now are shipped to New Jersey for processing and disposal and
wastes from out of State would not be accepted; however,
Vermont would welcome a site and plan for disposal of its own
industrial wastes.

Areas in which regulation is in effect include requirements of
ambient air and water quality standards and discharge permits
for these; the disposal, transportation, processing, and
storage of radioactive materials and explosives; the disposal
of pesticides; shoreline regulation and city, county, and State
zoning for land use; and transportation, in which DOT regula-
tions have been adopted.  An area not yet clearly defined but
under development is the handling of hazardous materials to
meet industrial safety standards.

There is no effective regulation at present of disposal or
licensing of sites for solid waste disposal, emissions of air
and water, or the transportation, processing, and storage of
pesticides.  No facilities presently exist for disposal of
radioactive or other hazardous waste materials.

The key agency in any implementation of a national hazardous
waste disposal site would be the Agency of Environmental
Conservation which is developing a plan for the operation of
Statewide waste recycling and is also establishing land use
planning through the Regional Environmental Commissions and
the State Environmental Commissions.  This Agency sets the air,
water, and solid waste standards and assists the Regional
Environmental Commissions in land use decisions.

There is a potent local input into land use planning and a
strong impact from local citizens is felt on decisions.  Plan-
ning is geared to selected growth compatible with environmental
goals.
                            A-680
-------
03HA regulations are being adopted by the Department of Health
which regulates the storage and disposal of radioactive wastes
and administers the licensing of all radioactive material
handlers.

A unique problem receiving concentrated attention is the pollu-
tion of Lake Champlain in the vicinity of the oil port of
Burlington by spills from barges traveling from Albany.  New
England Interstate Water Pollution Control Federation oil regu-
lations are to be used as a guide in developing legislation.

                          Highlights

^  Popular and political opinion is against a national disposal
   site and any hazardous material storage in Vermont, although
   the State would welcome guidelines for handling hazardous
   wastes.

o  Regulations stipulate that hazardous waste disposal sites
   would require special approval.

«  There are no regulations, only guidelines.

o  Licensing of all radioactive material for transport is
   required.

*  Rules and regulations, where applicable, conform to Inter-
   state Commerce Commission rules.

&  It is unlawful to transport wastes from out of the State
   into Vermont for disposal.

o  Regulations pertaining to handling of hazardous materials
   and OSHA regulations have been recently adopted.
                            A-681
-------
                                                           AGENCY  RESPONSIBILITY
    VERMONT
  DEPARTMENT OF
  AGRICULTURE
  DEPARTMENT
  OF HEALTH
I  AGENCY OF
(  ENVIRONMENTAL
  CONSERVATION
                               TRANSPORTATION
                  SETS STANDARDS FOR SHIPMENT OF PESTICIDES
REQUIRES LICENSING TO TRANSPORT RADIOACTIVE
MATERIAL
                                                                            PROCESSING
REQUIRES ALL PROCESSING AND MANUFACTURING
PUNTS TO COMPLY WITH OSHA REGULATIONS FOR
OCCUPATIONAL HEALTH AND SAFETY

REQUIRES LICENSE FOR USF OR PROCESSING OF
ANY RADIOACTIVE MATERIAL
HAS AUTHORITY TO DETERMINE THAT A SOURCE OF
POLLUTION EXISTS AS A HAZARD TO THE PUBLIC
HEALTH
CAN FORCE POLLUTION ABATEMENT
                                           ALLOW OPEN BURNING (UPON APPROVAL) IN
                                           REMOTE AREAS TO DISPOSE OF "HIGHLY
                                           EXPLOSIVE" OR UNUSED MATERIALS FOR WHICH
                                           THERE IS NO OTHER FEASIBLE METHOD OF
                                           DISPOSAL

                                           EVALUATES HAZARDOUS PARTICULAR
                                           EMMISSIONS ON A CASE BY CASE BASIS.
                                           CONTROLS ODOR EMMISSIONS FROM INDUSTRIAL
                                           PROCESSES

                                           DEVELOPING STATE PLAN FOR THE DEVELOPMENT
                                           AND OPERATION OF WASTE RECYCLING
                                           THROUGHOUT THE STATE.  CENTERS TO BE USED
                                           FOR STORAGE,  PROCESSING AND SALE OR
                                           DIS POSAL Of ALL SOLI D WASTE

                                           ESTABLISHING LAND USE PLANNING THROUGH THE
                                           REGIONAL ENVIRONMENTAL COMMISSIONS  AND
                                           THE STATE ENVIRONMENTAL COMMISSIONS

                                           SETS WATER QUALITY STANDARDS INCLUDING
                                           TOXIC, CHEMICALAND RADIOLOGICAL MATTER
                                           DEVELOPED A PLAN FOR ABATEMENT AND CONTROL
                                           OF AIR POLLUTION

                                           ESTABLISHED AIR STANDARDS BASED ON
                                           NATIONAL CRITERIA
                                                                                                                  STORAGE/DISPOSAL
                                                                                    HAS NOT COLLECTED BANNED PESTICIDES BECAUSE
                                                                                    CURRENT DISPOSAL TECHNOLOGY IS NOT ADEQUATE

                                                                                    SPECIFIES PROCEDURES FOR DISPOSAL OF
                                                                                    PESTICIDES

                                                                                    PESTICIDE BARRELS ARE USUALLY SENT OUT OF
                                                                                    STATE FOR REPROCESS ING
REGULATES STORAGE AND DISPOSAL OF SOURCE Of
IONIZING RADIATION

REQUIRES LICENSING OF ALL RADIOACTIVE
MATERIAL HANDLERS
                                          REQUIRES DISCHARGE PERMITS FOR DISPOSAL
                                          INTO WATER OR AIR

                                          ADVISES COMMUNITIES IN THE LOCATION AND
                                          DESIGN OF LANDFILLS

                                          ASSISTS THE REGIONAL ENVIRONMENTAL
                                          COMMISSIONS IN LAND USE DECISIONS BASED ON
                                          LAND CAPABILITY AND ON IMPACTS ON AIR AND
                                          WATER QUALITY
                                          EXPECT TO DEVELOP A SOLID WASTE BILL FOR THE
                                          LEGISLATURE IN THE NEAR FUTURE
  DEPARTMENT OF
  PUBLIC SAFETY
PROMULGATES RULES TO PREVENT EXPLOSION AND
FIRE AND MAINTAIN PUBLIC SAFETY IN THE
TRANSPORT OF EXPLOSIVES, FLAMMABLES,
HAZARDOUS MATERIALS AND PETROLEUM
PRODUCTS

MAY PRESCRIBE LOCATION AND MATERIALS USED
FOR HANDLING SUCH MATERIAL

RULES AND REGULATIONS CONFORM TO THOSE OF
THE INTERSTATE COMMERCE COMMISSION

SAFETY STANDARDS FOR VEHICLES CONFORM TO
STANDARDS FOR TANK VEHICLES FOR FLAMMABLE
AND COMBUSTIBLE LIQUIDS OF THE NATIONAL
FIRE PROTECTION STANDARD
DEVELOP RULES FOR PREVENTION OF EXPLOSION
AND FIRE IN THE USE AND MANUFACTURE

PRESCRIBE LOCATION, MATERIAL AND TYPE Of
CONSTRUCTION
  MISCELLANEOUS
                 MOST INDUSTRIAL WASTES ARE NOW SHIPPED
                 OUT TO NEW JERSEY

                 UNLAWFUL TO DISPOSE OF COMMERCIAL OR
                 RESIDENTIAL AASTES TRANSPORTED IN FROM
                 OUTS IDE THE STATE
                                           THERE IS A VERY STRONG LOCAL INPUT INTO THE
                                           LANDUSEPLAN. LOCAL CITIZENS HAVE A
                                           STRONG IMPACT ON DECISIONS
                                           THE LEVEL OF INDUSTRY IN THE STATE IS NOT
                                           HIGH- FEW HAZARDOUS WASTES ARE GENERATED

                                           MOST INDUSTRIAL WASTES ARE NOW PROCESSED
                                           IN NEW JERSEY

                                           PLANNING IS GEARED TO SELECTED GROWTH
                                           WHICH IS COMPATIBLE WITH ENVIRONMENTAL
                                           GOALS
                                          THE STATE WOULD WELCOME ASSISTANCE IN
                                          DEVELOPING WAYS TO DISPOSE OF HAZARDOUS
                                          MATERIALS
                                                                  A-682
-------
                           VIRGINIA

The most significant factor in Virginia's eventual acceptance of
a national site is the fact that determination of its land use
policies is scattered through so many State and local agencies.
This circumstance correlates with the resistance of the citizenry
and local government to "outside" regulation of the affairs of
their particular locale.  State officials feel that one of their
major problems is public response to the disposal of waste
materials, including a particularly strong resistance to im-
porting wastes, not only from other States but even from other
communities.

The Department of Health is apparently the key State agency in
any implementation of a national hazardous waste disposal site;
it currently regulates solid radioactive waste disposal and
generally controls the disposal of those hazardous materials
that are regulated.  The State Air Quality Control Board and
the State Water Control Board set standards and have limited
authority.  Since there are less than 100 major industrial
firms in the State and these firms practice good procedures,
there is little waste to dispose of in Virginia waters.

Pesticides have been a problem but a disposal site is under
development which is expected to alleviate this.  There is no
radioactive disposal site at present.

Among the areas of environmental control not regulated are the
transportation, processing, and storage of pesticides; air
and water emissions; licensing of solid waste disposal sites;
safe handling of hazardous materials (under development); and
statewide land and shoreline use zoning.

More than half the counties of Virginia have zoning power but
use it ineffectively.  However, the very strong role played by
local government in deciding upon land use precludes the develop-
ment of a statewide policy.  An official of the Office of State
Planning noted the lack of "muscle" in its authority to ade-
quately establish plans for the State;  the OSP has little legis-
lation or regulative authority, but apparently is intended to
fulfill an advisory role.   Development of a stronger State
land use plan would be imperative for eventual acceptance of a
national disposal site.

                          Highlights

*  Water Control Board must evaluate and approve all disposal
   sites if they influence surface or ground water.

•  Ineffective zoning power held by 60 percent of counties.
                             A-683
-------
Land use policies are scattered through many State agencies
and should be consolidated.

Air and water quality standards are set.

Regulations exist for transporting explosives and other
dangerous materials, registration of pesticides,  discharge
permits for waste disposal, and disposal of radioactive
material.
                         A-684
-------
AGENCY RESPONSIBLITY
VIRGINIA
STATE
CORPORATION
COMMISSION
DEPARTMENT
OF
AGRICULTURE
1
PLANNING AND
COMMUNITY
AFFAIRS
STATE AIR
QUALITY
CONTROL
BOARD
STATE
WATER
CONTROL
BOARD
DEPARTMENT
OF HEALTH
MISCELLANEOUS
i
TRANSPORTATION
REGULATES PIPELINE
CONSTRUCTION
REGULATES TRANSPORTATION
OF EXPLOSIVES AND OTHER
DANGEROUS MATERIALS.
(RULES CONFORM TO
ICC RULES.)
REGISTERS PESTICIDES FOR
TRANSPORT IN INTRA STATE
MOVEMENT
REQUIRES LABELING OF
HAZARDOUS MATERIALS




PROCESSING


IDENTIFYING CRITICAL
ENVIRONMENTAL AREAS TO
BE PROTECTED
DEVELOPS A PROGRAM FOR
ABATEMENT AND CONTROL
OF AIR POLLUTION
MAY REQUIRE CONTROL DEVICES
ON ANY OR ALL SOURCES
MAY GRANT VARIANCES TO THE
STANDARDS IF DEEMED,
WARRANTED
SETS WATER QUALITY
STANDARDS
EVALUATES ALL NEW FIRMS AND
FIRMS USING NEW PROCESSES
TO DETERMINE WASTE
DISPOSAL REQUIREMENTS.
CONTROLS SEWAGE TREATMENT
FACILITIES JOINTLY WITH
STATE WATER CONTROL BOARD

DISPOSAL/STORAGE

COOPERATES WITH OTHER STATE
AGENCIES IN THE DEVELOPMENT
OF DISPOSAL PRACTICES FOR
PESTICIDES
SITE SELECTION WILL BE
INFLUENCED BY THE CRITICAL
ENVIRONMENTAL AREAS STUDY

ISSUES DISCHARGE PERMITS
FOR WASTE DISPOSAL INTO
THE STATE WATERS
ASSIST IN THE EVALUATION OF
DISPOSAL SITES FROM A WATER
QUALITY STANDPOINT
PARTICIPATED IN SELECTION OF
PESTICIDE DISPOSAL SITE
REGULATES AND PLANS FOR
SOLID WASTE DISPOSAL
CONTROLS DISPOSAL OF
HAZARDOUS MATERIALS IN A
MANNER APPROVED BY THE
HEALTH COMMISSIONER
REGULATES DISPOSAL OF
RADIOACTIVE MATERIALS
DIFFICULT TO GET PUBLIC
APPROVAL OF LANDFILL SITES
A SITE HAS BEEN SELECTED FOR
THE BURIAL OF WASTE AND
BANNED PESTICIDES
THE SITE MAY BE USED FOR
OTHER HAZARDOUS WASTES
IN THE FUTURE.
Ml SCELLANEOUS 1
i

HAi/E LITTLE LEGISLATIVE AUTHORITY
OP REGULATORS POWER
. . . .. _ - 	
n
MAINTAIN A TEAM ON A 24-HOUR BASIS
TO INVESTIGATE REPORTED POLLUTION
INCIDENTS
FEW HAZARDOUS WASTE PROBLEMS IN
VIRGINIA WATERS
HAS A MAJOR, IF NOT THE MAJOR ROLE
IN CONTROLLING HAZARDOUS PROCESSES
AND MATERIALS
LAND USE PLANNING AND ZONING IS
GENERALLY NOT VERY EFFECTIVE
LAND JSE POLICIES ARE SCATTtKtiJ
THROUGHOUT A NUMBER OF AGENCIES
     A-685
-------
                          WASHINGTON

Environmental factors are well regulated in Washington by
legislation enacted in the 1970's, including an Environmental
Policy Act (1971) modeled after the National Environmental
Protection Act.  Implementation of a national hazardous waste
disposal site would therefore not meet great opposition
although several areas would need more thorough regulation.

The Department of Ecology is the key agency in environmental
affairs, regulating air and water quality through a comprehen-
sive classification system as well as solid waste disposal.
This agency is also presently responsible for what little
regulation exists of radioactive materials (mainly disposal).
A State Radiation Control Agency is being created by new
legislation.   Meanwhile the transportation, processing, and
storage of radioactive materials is unregulated.  Also not
regulated are the transportation, processing, and storage of
pesticides.  The Department of Agriculture regulates pesticide
disposal.  Facilities exist for both radioactive and other
hazardous material disposal.

Two other areas not regulated include the processing of ex-
plosives and statewide land use zoning.  The cities and
counties are authorized to form land use planning commissions
and the latter are charged with developing a "master program
for regulation of uses of the shorelines of the State" by the
passage in the fall of 1972 of the Shoreline Management Act,
which requires them to inventory their shorelines by January
of 1973.  Shorelines are defined as the area between low and
high water.

One of the more significant facets of the State EPA is its
requirement of all branches of the government that they
"include in every recommendation...and action significantly
affecting the environment...the environmental impact of the
proposed action."  This requirement alone if adequately moni-
tored by the Department of Ecology should prevent or resolve
any potential or current problems involving the environment.

Washington's geographical position is particularly important
from an interstate perspective, so the approval that has been
given by the EPA on its air and water quality standards
significantly aids implementation of a national site in the
Pacific Northwest.
                          A-686
-------
                          Highlights

o  Washington presently has emission and ambient air and water
   quality standards with permits required for discharge.

"  Regional air quality authorities may adopt more stringent
   standards than those of the State and authorize variances.

«  Washington presently regulates the transporting, storage,
   and disposal of explosives.

f  Washington regulates the disposal of solid waste, hazardous
   materials and pesticides.

e  Counties and cities have authority to regulate land use
   with special regulations for shoreline limitation.

*  Hazardous wastes are defined as explosives and medical,
   radioactive, and harmful chemical wastes.

®  Water quality standards have been established and classi-
   fied into four categories with strict limitations on dis-
   charge of toxic, radioactive, and deleterious metals.

0  Washington passed by referendum a shoreline management act
   which requires all counties to inventory and develop guide-
   lines to the master plan regulation for shoreline use.

                 Law Library Search Findings

Environmental Policy Act

Washington passed an environmental policy act in 1971 which is
similar to the National Environmental Policy Act.  In particular,
all branches of State government are directed to "include in
every recommendation...and actions significantly affecting the
quality of the environment...(1) the environmental impact of
the proposed action..." RCW 43.21.

Solid Waste Disposal

The Department of Ecology administers Washington solid waste
law.  All counties are now in the process of preparing long
term comprehensive solid waste disposal plans for submission
"-.o the Department.  RCW 70.95.080.

Applications for solid waste disposal sites must be approved
by the Department.  RCW 70.95.180.  Applications must include
an environmental impact statement.  WAC 173-301-181.  The
Department has approved minimum functional standards for solid
                            A-687
-------
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A-688
-------
v---4"? 'randiing.  The regulations became effective on November
"•i. 1972-

T^ctep. defined as hazardous include explosives and medical,
•??dinactive, and harmful chemical wastes.  WAG 173-301-110(11).
Hazardous wastes must be properly labeled and stored so as to
:~e inaccessible to the public.  WAC 173-301-123.  The distance
separating hazardous wastes and the bottom of a sanitary land-
fill is determined on a case by case basis.  WAC 173-301-302.

.Aj r poi lution

Statewide air pollution authority is vested in the Department
of Ecology.  Air pollution is declared to be unlawful except
a.~. specified in a variance permit.  RCW 70.94.040.

Each county has an air pollution control authority.  Many
counties have joined to form regional authorities pursuant to
RCW 70.94.057.  Authorities may classify air contaminant sources
and require reporting of emissions.  RCW 70.94.151, .152.  The
regional authorities and the Department of Ecology are author-
ized to grant variances.  RCW 70.94.181.  Rules of regional
authorities supersede local rules.  RCW 70.94.230.

The Department of Ecology is directed to adopt minimum ambient
and emission standards throughout the State.  Regional author-
ities may adopt more stringent standards.  RCW 70.94.331(6).
The Department may adopt statewide standards for particular
emissions or particular industrial processes.  RCW 70.94.395.
The Department has adopted regulations for several chemicals
and for several industrial processes.

Washington's air quality implementation plan was fully approved
by EPA prior to the recent nondegradation court case.

Water Pollution

The Washington Department of Ecology is authorized to control
^nd prevent pollution of State waters and to promulgate regula-
tions to accomplish this purpose, RCW 90.48.030, .035.  A per-
mit from the Department must be obtained before discharging
any liquid or solid wastes into State waters.  RCW 90.48.160.
The Department can order a halt to discharge when necessary.
t"~V 90.48.240.

Interstate water quality standards have been fully approved by
F.PA and the following intrastate classifications have been
established:  class AA, extraordinary; class A, excellent;
class B, good; and class C, fair.  All State waters fall into
o~e of these classifications.  Water quality criteria have been
                             A-689
-------
established for each classification.   One criterion is toxic,
radioactive, or deleterious material  concentration.  A
similar classification scheme exists  for interstate waters.

Land Use

Washington has a State land planning  commission.   RCW 43.287.
The commission's primary function is  to present a model land
use code to the forty-third session of the State Legislature
(1973) .

County Planning

The board of commissioners in any county may create a planning
commission or department.  RCW 36.70.030, .040.  Counties and
cities may also create regional planning commissions.  RCW
36.70.060.

Each planning agency is directed to prepare a comprehensive
plan.  RCW 36.70.320.  Wide flexibility is permitted in plan
elements.  RCW 36.70.330-.350.   A public hearing, RCW 36.70.
380, must precede approval by the board.  Zoning is permitted
if the plan contains a land use element.  RCW 36.70.720.

City Planning

Cities are authorized to form planning commissions and zone in
much the same manner as counties.  RCW 35.63.  Alternatively
cities may cooperate with counties and form regional planning
commissions.  RCW 35.36.070.

Washington voters approved a shoreline management act as a
referendum in the November 7, 1972 election.  The act requires
all counties in the State to inventory the shorelines  (the
areas between high and low water) of  major bodies of water by
January 1, 1973.  RCW 90.58.080(1).  Counties are also required
to develop "a master program for regulation of uses of the
shorelines of the State" consistent with guidelines issued by
the Department of Ecology.  RCW 90.58.080(2).  A permit is
required for substantial shoreline developments.  RCW 90.58.140.

Nuisances

A nuisance is defined in general terms in RCW 7.48.120.  Public
nuisance is defined in RCW 9.66.010 and specific public nuisances
enumerated in RCW 7.48.140.
                            A-690
-------
I'h'-j Washington State Explosives Act was passed in 1971.  It
authorizes the department of labor and industries to issue
regulations concerning the "...use, transportation, storage,
and disposal of explosives."  The statute gives detailed
criteria for storage of explosives.  Explosive containers must
be clearly marked.  RCW 70.74.300.  Transportation of less
than 50 pounds is permitted in passenger vehicles; transporta-
tion in excess of 50 pounds must be in accordance with Depart-
ment of Transportation rules.

Pesticides

Authority for regulation of pesticide use is vested in the
Department of Agriculture.  The Department has issued regula-
tions stating that pesticides must be disposed of in a non-
polluting manner and without endangering persons or food
supplies.  WAC 16-222-150, 16-235-020(2).  Requirements are
also specified for unattended pesticides and their containers.
WAC 16-235-020(4).

Radiation

Legislation creating a State radiation control agency is in-
cluded.  Nothing in the legislation specifically bears on
transportation or disposal of radioactive material.

Transportation of Hazardous Materials

The Washington State Patrol has been given authority to regu-
late the highway transportation of hazardous materials.  RCW
46.48.170.  Washington has also adopted 49 CFR 171-178 and
390-397.

Industrial Safety

RCW 49.16.030 is a general statute imposing a duty on employers
to maintain a safe working environment for employees.  The
Director of Labor and Industries is required to promulgate
safety standards.  RCW 49.16.050.  The Division of Safety with-
in the Department of Labor and Industries is directed to in-
spect the work environment of employees engaged in extra-
hazardous work at least once a year.  RCW 49.16.120.
                            A-691
-------
A-692
-------
                          APPENDIX O
         POTENTIAL RADIOLOGICAL TOXICITIES ASSOCIATED
                    WITH RADIOACTIVE WASTES
Most of the potential toxicity from radioactive wastes arises
from radioactive decay rather than from chemical toxicity;
therefore waste toxicities vary significantly according to
storage time and comparisons of curies in radioactive wastes
at the time of disposal is meaningless in terms of long-term
radiological safety.

The toxicity of radioactive wastes can be typified by those of
wastes from the nuclear power fuel cycle, which will most
likely provide the largest source of radioactive wastes by the
year 2000.

The nuclear fuel cycle can be subdivided into seven major com-
ponents (exclusive of radioactive waste management and trans-
portation) :  mining, milling, uranium hexafluoride production,
enrichment, fuel fabrication, nuclear reactors, and irradiated
fuel reprocessing.  Each of these components generates its own
associated radioactive wastes.  To help develop a perspective
on the potential hazards associated with wastes from irradi-
ated fuels, wastes from the fuel reprocessing and refabrication
plants are compared here with the wastes from the uranium min-
ing and milling industry.

Projections through the year 1980 indicate that about 8,500
metric tons of irradiated fuel will be discharged from the
nuclear power economy, mostly from light water reactors with
uranium fuel slightly enriched in U-235. The bulk of the plan-
ning being fostered by the AEC is being made for wastes from a
nuclear economy through the year 2000.  By that time a total of
167,600 metric tons, or 20 times the amount discharged through
1980, will have been discharged.  At least 838,000 metric tons
of uranium would have to be mined, milled, converted to UFg
and fed to the enrichment plants to produce enough slightly
enriched uranium for charging the reactors.  But more effici<=^t
alternative sources of fissionable material will become avail-
able, and it is projected that only 70 percent of the accumu-
lated discharge of fuel will come from reactors with slightly
enriched U-235 fuel; the remainder will be from plutonium re-
cycle reactors (4.3 percent),U-233-thorium-fueled gas cooled
reactors  (10.1 percent), and fast breeder reactors  (15.2 per-
cent) .  Distributions of the radioactive actinide elements in
the wastes from these reactors are different from those of
current uranium-fueled light water reactors.
                              A-693
-------
Rao.-cnuclide concentration guides (RCG's)  for radionuclides in
drinking water and air are provided in 10  CFR 20.  However,
these numbers alone do not give any estimate of the total dose
to man because of the various environmental pathways and con-
centration of some nuclides in food chains leading to ultimate
human ingestion.  Estimation of the total  dose to man requires
a complex analysis of specific waste release situations and the
specific pathways to man.  A model has been developed by Bat-
telle-Northwest for estimating the total dose to man from given
release modes and rates to the environment.      This model has
been useful in preparing environmental impact statements for
nuclear reactors.  An idea of the complexity involved can be
obtained from Figure A-21.A"67Clearly, inhalation and drinking
water are only two of the many pathways to ingestion.  To pro-
vide rates of release to man's environment requires analyses of
the rate of release from the facility and the rate of travel
from the facility (e.g., through the lithosphere to surface
water, if the radionuclides are buried).

A method for estimating the order of magnitude of potential
toxicity associated with radioactive wastes  is to calculate the
amount of water required for dilution to bring the waste con-
centration down to the RCG for drinking water.A~67 Results  of
these calculations are presented in Figure A-22 for the accumu-
lated high level wastes from the nuclear economy's fuel repro-
cessing plants through the year 2000 if the wastes are stored
for periods from one year to one billion years.  Magnification
via food chains would be expected to change the relative tox-
icity of the various radionuclides.

The potential drinking water toxicity due  to  838,000 metric
tons  of aged natural uranium equivalent to the fuel charged to
the reactors is also shown in Figure A-23.   It is important to
note  that the relative toxixity of the total  of  the fission
products  (versus the actinide products) decays to an equivalent
of  the original uranium in less than 1,000 years.  The 1-129
potential hazard is smaller than the natural  uranium hazard
associated with uranium mining and milling.


 Similar calculations have been made for various  fractions  of
 the waste constituents from nuclear fuel  reprocessing such as
 the transplutonium nuclides,  the 0.5 percent fraction of plu-
 tonium lost  to the waste,  the fuel  element cladding,  and the
 0.5 percent  fraction of uranium-thorium fuel in  the waste.
 The results  presented in Figure A-23  indicate that  various
 fractions of the wastes may be controlling at different cool-
 ing times.

 The above treatment is far from complete.   Potential  drinking
 water toxicities do not include inhalation and an analysis of
                              A-694
-------
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the environmental pathways via food chains nor do they include
the protection afforded by containment and isolation.  In ad-
dition, no comparison with normal chemical toxicities of the
wastes has been made here.  The mechanism and rate of release
to man's environment are not included.  More complete analysis
of causes and effects would produce a better perspective of
high-level and low-level radioactive wastes and the potential
risk to man.
                              A-698
-------
                          APPENDIX P
           DETAILED INVENTORY OF A SELECTED AEC SITE
                      HANFORD, WASHINGTON


The Hanford Reservation was selected as an example of the com-
plex interactions involved in radioactive waste management at
an AEC site.  The Reservation occupies 600 square miles of an
arid plateau near the Columbia River in Southeastern Washington
and is fully integrated, containing nine reactors, fuel pro-
cessing plants and research and development laboratories.

The Atlantic Richfield Hanford Company, which operates the
fuel reprocessing plants (known as the 200 Areas), also handles
the bulk waste disposal for the other AEC contractors which are
Battelle-Northwest (laboratories for several AEC divisions),
Westinghouse Hanford Company  (laboratories for AEC's Division
of Reactor Development and Technology), and United Nuclear In-
dustries (reactors and fuel fabrication).  Eight of the reactors
have been deactivated during the past ten years and the ninth
reactor will probably be closed within five years.  The residual
radioactive structural materials associated with the reactors
remains in place.

Developments on the site and being planned include an existing
commercial radioactive waste burial ground, at least  two com-
mercial nuclear power reactors, a large sodium-cooled test re-
actor, and 300,000 gallons of radioactive sodium shipped  from
the Hallam reactor in Nebraska.

The effluents from the fuel processing plants are summarized
yearly by a computerized data organization system  68-A~?o
with samples on a monthly basis.  The statistics for 1971
are summarized in Table A-95.

For gaseous wastes the sampling points mainly included stacks
and vault storage off-gas emissions.  A total of 52 separate
identifiable release points to the atmosphere were monitored.

The liquid wastes are discharged into ponds and ditches,  cribs
(specially designed French drains), and specific retention
sites.  Pond discharges have low radioactivities, those to
cribs are somewhat higher, and specific retention sites have
the highest activity but the wastes are considered to be  con-
fined.  Seventeen distinct discharge points to ponds, ditches
and cribs are identified, and 19 specific retention sites are
used.  Total accumulative amounts of liquids discharged through
1971 are given in Table A-96.   High-level liquid wastes are
                              A-699
-------
                            TABLE A-95
        RADIOACTIVE WASTE DISCHARGES FROM THE 200 AREAS
               OF THE HANFORD PLANT DURING 1971
Gageous Wastes Discharged to Atmosphere
     Total Volume of Gases

     Radioactivity

          Alpha (assumed source - Pu)
          Alpha (assumed source - U)
          Beta
          Iodine-131

Liquid Wastes Discharged to Ground

     Total Volume of Liquids

          To ponds and ditches
          To cribs
          To specific retention sites
                  4.33 x 1012 cubic feet
                             4.17 x 10""^ Ci
                             1.25 x 10   Ci
     Radioactivity

          Pu
          Beta
          Sr-90
          Ru-106
          Cs-137
          Co-60
          U
          U-233

Solid Waste Burials
 6771 grams
 5700 Ci
   60 Ci
 3300 Ci
<1170 Ci
< 9.5 Ci
< 140 Ci
< 117 Ci
     Volume of Solid Wastes Buried

     Land Surface Area Used for Burial

     Radioactivity
                             1.33
                             0.204
                      6.49 x 10  gallons

                      6.29 x 10^ gallons
                      2.01 x lo" gallons
                      2.34 x 10  gallons
Ci
Ci
                       1.55 x 10  cubic feet
                       2.08 x 10  square feet
          Uranium
          Plutonium
          Other radioactivity
               1.12 x 103 grams
               3.8  x 10^ grams
              <1.48 x 104 Ci
                              A-700
-------
              TABLE A-96

     ACCUMULATED LOW-LEVEL LIQUID AND
 SOLID RADIOACTIVE WASTES IN THE HANFORD
         200 AREAS THROUGH 1971
Liquid Wastes Discharged

     Volume

     Radioactivity

          Plutonium

          Beta

          Sr-90

          Ru-106

          Cs-137

          Co-60

          Uranium

          U-233
 1.32 x 10
          11
gallons
 286,330 grams

 3.21 x 106 Ci

 4.51 x 104 Ci

 5.57 x 105 Ci

 5.01 x 105 Ci

 <7.3 x 103 Ci

1.173 x 105 kg

    < 967 grams
Solid Wastes in Burial Grounds

     Volume

     Acres of Land Area

     Uranium

     Plutonium

     Other Radioactivity
 5.19 x 10  cubic feet*
        149 acres
          Q
 5.86 x 10  grams

 3.64 x 10  grams
 8.67 x 10  Ci
*This does not include a much larger volume
(^ 1.5 x 108 cubic feet) of soil contaminated
by liquid discharges.
                   A-701
-------
treated separately by tank storage.  Additional liquid wastes
have been discharged by United Nuclear Industries at the reactor
sites.

Solid wastes are placed in burial grounds, formerly by direct
burial or in caissons and now in 55 gallon drums.  Approximately
20 burial areas located mainly in two burial gardens are iden-
tified.  Appreciable contaminated equipment is also stored in
underground railroad tunnels.  Additional burial grounds exist
in reactor areas.  The accumulated solid waste burials are given
in Table A-96'.

Preliminary estimates of the costs of removing the radioactive
materials from the Hanford site have been made.     Reduction of
the plutonium levels to values suitable for uncontrolled access
could cost billions of dollars and take several decades to com-
plete.   Clearly, decommissioning of the site would be a major
undertaking, and its designation as a national repository would
seem very likely.  A comparable situation exists at the Savannah
River,  South Carolina, site;, while the magnitude of the radio-
active inventories at ORNL and Idaho are substantial, but appre-
ciably smaller.

The total underground tank  storage capacity projected  for 1980 at
Hanford is 98 million gallons in 153 tanks .A~ 7 2 The working
capacity of these tanks is  72 million gallons  because  none
of them can be completely filled under normal operating condi-
tions.   The current  (end of FY 1972)  inventory of wastes stored
in these tanks is 65.5 million gallons ,A~73of which 21.7 million
gallons are solid and 43.8 million gallons are liquid.A-7*  A11
tanks contain both solid sludge and liquid supernates simultane-
ously.

The principal long-lived radioisotopes in these tanks are Sr-90,
Cs-137, and Pu-239.  Depending upon the exposure to neutrons in the
reactors, the plutonium will also contain varying amounts of
Pu-240, Pu-241, Am-241, Pu-242, Am-243, Cm-244 and their decay
products.  Estimates of the total quantities of radionuclides
are available.A-7i    The radionuclide concentrations vary widely
from tank to tank but the maximum values are on the order of tens
of millions of curies of Sr-90 and Cs-137 per  tank.  The pluton-
ium contents of the tanks are quite variable,  ranging up to
kilogram quantities in some tanks, but the total is only a small
fraction of the plutonium buried in the ground.

A waste solidification program is underway to  reduce the volume
of the liquid wastes to less than three million gallons by the
end of 1980.A~70 At that time the solid waste  volume in the
                              A-702
-------
tanks  (including wastes to be generated in the interim at a
rate of about seven million gallons of liquid waste per year
through FY 1976) will be 47 million gallons (or 6.3 million
cubic  feet) but it will still be distributed throughout 153
tanks.  The bulk of the solids will be NaNC>3 with significant
quantities of NaN02, NaOH, NaAlC^f Na2C03 and ferric iron,
sulfate, and phosphate.

In addition, separations of the bulk of the heat-generating
Sr-90  and Cs-137 from the tank stored wastes are being con-
ducted.  These separated fission products will be stored sepa-
rately in small capsules as solid SrF_ and CsCl in high-inte-
grity, cooled facilities, with a total salt volume less than
250 cubic feet.  Estimates of the total quantities of Sr-90 and
Cs-137 to be stored in this way are available .A~7 5 After sepa-
ration, the Sr-90 and Cs-137 capsules can be considered high-
level wastes because of their high heat generation rates,
while  the solidified wastes remaining in the tanks are low-
level wastes because no cooling is required.  As an environ-
mental hazard, the Sr-90 and Cs-137 in the high-level wastes
will decay to insignificant levels within three or four hundred
years, but the plutonium in the low-level wastes may require
isolation from man's environment for hundreds of thousands of
years.
                              A-703
-------
                          APPENDIX Q
             CLASSIFICATION OF RADIOACTIVE WASTES
            FOR TRANSPORTATION REGULATORY PURPOSES
For transportation regulatory purposes each radioactive nuclide
is classed as a member of one of seven transport groups.*
Generally, Group I includes the most radiotoxic materials.  A
special class is provided for "special form" materials, which
are massive and solid or encapsulated so as to present little
hazard of radiotoxicity.  For each transport group five cate-
gories of shipments are specified in terms of limits on the
quantity or concentration of radioactivity.  Each shipment
category, in turn, requires a different specified level of
assurance of containment integrity.A~  6

The radioactivity limits for transport of Group I materials are
given in the following discussion of these categories.  The
other groups generally have higher limits.

     e  "Small quantities"  (less than .001 millicuries
        per package for Group I) are exempt from most
        of the packaging requirements and need basically
        only tight packages.

     •  "Low specific activity" (LSA)  materials  (less
        than 0.0001 millicuries per gram for Group I)
        are dilute materials which may be either pack-
        aged or in bulk and are exempt from many pack-
        aging requirements, especially when the vehicle
        is dedicated to the sole use of the consignor.
        In general only strong, tight packaging is
        needed.  Bulk liquids must be transported in
        specification tank cars.

     «  "Type A quantities" (less than 0.001 curies for
        Group I) must be shipped in packages which can
        maintain their integrity under normal environ-
        mental and handling conditions of transporta-
        tion.  The packages must pass specified func-
        tional tests but do not require official approval
        by DOT or AEC.
*The concept of transport groups may be eliminated in future
revisions of the regulations.  In that case limits would be
specified for each radioactive nuclide,^~77
                             A-705
-------
     •  "Large quantities"  (greater than 20 curies for Group
        I)  must be shipped in packages which meet both type
        B requirements and special additional structural
        requirements of the AEC^~78  It is frequently neces-
        sary to make special provision for dissipating heat.
        These packages need approval by both AEC and DOT.

Special regulations of both DOT and AEC apply to fissile mater-
ial, three classes of which are superimposed on the general cate-
gories described above.

Virtually all shipments of high-level wastes will fall into the
"large quantities" category and will thus have to pass severe
accident and structure*! tests as well as meet a host of lesser
requirements.  Shipments of low-level wastes will probably fall
in all categories except "small quantities."  Types A and B
quantities are probably most common for miscellaneous wastes
and alpha wastes, with occasional bulk shipments of LSA materials.

Prevention of accidents is the primary purpose of the packaging
and transportation regulations.  The major burden falls on the
shipper who is required to provide a safe package, his safety
efforts depending upon the degree of hazard of the contents.

In addition to general regulations applicable to all packages
of hazardous materials, there are many specifically applicable
only to radioactive materials.  All packages must be strong and
tight enough to contain the contents, must have a noncontaminated
surface and a specified marking or label, and must not emit
excessive radiation.  Pyrophoric materials must be placed in
special inner containers.  Radioactive liquids must be packaged
in leak-resistant and corrosion-resistant inner containers.  A
package containing liquids must survive a 30 foot drop test or
contain a specified amount of absorbent material.  If the pack-
age contains a type A quantity, it must maintain its integrity
at 130°F and -40°F, at reduced  (one-half) atmospheric pressure,
under normal vibration conditions, after a 30 minute water spray,
after a drop of four feet, after one foot drops on each corner
of the package, after impact with a specified steel cylinder,
and after a specified 24 hour compression test.

In addition to type A requirements, a type B package must main-
tain its integrity under the following severe accident condi-
tions:  a free drop of 30 feet, a free drop of 40 inches onto
a six-inch diameter steel pin, exposure to a 1475°F fire for 30
minutes, and  (for fissile materials only) immersion in water for
eight hours.  In addition, a package containing  "large quantities"
of radioactive material must dissipate heat safely, have a pos-
itive closure and strong lifting and tie-down devices and must
                              A-706
-------
 -rj-cnstand a specified static  load along any major  axis  and
an external pressure of 25 psig.

All packages for fissile material must have a positive closure,
strong lifting and tie-down devices, and must remain subcritical
neutronically under a variety of specified conditions involving
neutron moderation by water and interaction with other packages
of fissile material.

Besides supplying a safe package, a shipper of radioactive
materials must follow other procedures intended to prevent
accidents.  Prior to each shipment of fissile materials the
shipper must notify the consignee of the dates of shipment and
expected arrival.  He must also notify each consignee of any
special loading/unloading instructions prior to his first
shipment.  He must supply shipping papers, including an accurate
and quantitative description of the contents of the shipment
and a signed certificate of compliance with the applicable DOT
regulations.

The DOT regulations require the carrier to take certain measures
designed to prevent accidents.  In addition to general regula-
tions applicable to all hazardous materials, there are several
specifically applicable to radioactive materials.  Minimum
weights are specified for containers to be loaded on flat cars
or in gondola cars, and packages must be blocked and braced to
prevent movement under normal conditions.

The number of packages in any vehicle or storage location must
be limited to prevent neutron criticality of fissile material
or excessive radiation levels due to ordinary radioactive
materials.  This is done by limiting the sum of transport
index numbers (marked on each package by the shipper) to 50.*
Packages bearing certain radioactivity labels must not be
placed closer than three feet to an area occupied by people or
animals.  If more than one such package is present, the dis-
tance must be increased according to the total transport number
of the group.

Radioactive materials may not be stored or loaded with certain
types of explosives.  Vehicles must be marked or placarded on
the outside with an appropriate standard warning sign.  Vehicles
used for carload or truckload shipments of LSA materials must
*The transport index is the greater of the following two
numbers:  (1) the highest dose rate in millirems per hour at
three feet from the surface of the package, and  (2) for Fissile
Class II packages only, the number calculated by dividing the
number "50" by the number of similar packages that may be
transported together.
                              A-707
-------
be surveyed and cleaned to specified levels, unless the
vehicles are marked as reserved for radioactive materials,
                            A-708
-------
                          APPENDIX  R
              METHODS AND EQUIPMENT FOR HANDLING
               SMALL RADIOACTIVE WASTE ACCIDENTS
           AND FOR DECONTAMINATING TRANSPORT SYSTEMS
METHODS AND EQUIPMENT FOR HANDLING SMALL RADIOACTIVE WASTE
ACCIDENTS

The stringent containment required by regulations for large
quantities of radioactive materials is expected to reduce to
an alrrost negligible level the probability of a large accident
in the transportation system.  Since the detection of radio-
activity requires trained and equipped personnel, it is
usually impossible to determine immediately the size of an
accident.  Furthermore, it is not at all clear that the handling
of a large accident is qualitatively different from that of a
small one; the procedures involved will be the same, though o~\
a larger scale.  For these reasons the following account is
independent of the size of the accident and the type of red;r-
active waste involved.

The DOT regulations stipulate that the carrier must notify DOT
by telephone at the earliest occurrence of fire, breakage,
spillage, or suspected radioactive contamination involving
shipment of radioactive material.  This report must include
specific information which will permit an effective emergency
response.  In addition, the shipper must be notified as quickly
as possible.  The regulations also recommend that the carrier
contact the AEC for radiological advice or assistance, and that
he follow the recommended practices of the Bureau of Explo-
sives. A-79

The various Federal agencies concerned with radioactive mate.ri^,1 -
(AEC, Department of Defense  [DOD] , Public Health Service, Depart-
ment of Transportation) have developed the Interagency Radio-
logical Assistance Plan (IRAP)  for coping with accidents
involving radioactive materials. A~8° Both the AEC and DOD have
well developed plans and trained emergency teams available ?.-".-
various locations throughout the United States.  Other Federal
agencies that may be contacted include the Office of Civil
Defense, Public Health Service, and the Food and Drug Adminis-
tration.  A number of States have organized radiological emer-
gency monitoring teams which can be dispatched to the scene c:T
an accident, a practice that would be highly desirable for
every State.
                             A-709
-------
The handling of transportation accidents involving radioactive
waste materials divides naturally into two parts, the emergency
phase and the cleanup phase.  In the emergency phase -the major
concerns are personnel safety, control of exposure, and con-
tainment of contamination.  Hopefully, transportation personnel
or knowledgeable bystanders will initiate proper emergency pro-
cedures immediately.  However, in unfortunate cases, such as
serious highway accidents, local police or firefighters may be
the first to recognize the potential radioactivity hazard.

In any case, once the hazard is recognized it is important that
the following procedures be carried out:

     1.  keep everyone except rescuers and other authorized
         persons from the accident scene;

     2.  notify AEC and local police and fire departments;

     3.  stay out of smoke or vapors;

     4.  try to hold for radiological monitoring anyone
         who may have been exposed;

     5.  leave firefighting to experts; and
                                           A- 8 °
     6.  do not permit taking of souvenirs.

After the public safety personnel arrive in force, it should be
possible to maintain these procedures until the radiological
assistance team arrives.  This team will monitor potentially
contaminated people, initiate personnel decontamination, and
monitor the accident area to determine the extent of contami-
nation of the vehicle and its surroundings.  Their findings
will make it possible to establish a realistic perimeter around
a restricted zone for subsequent cleanup activity.

The major concerns of the cleanup phase are decontamination and
restoration of the vehicle and surroundings to normal service
as safely and economically as possible.  Fortunately, a book
summarizing the results of worldwide research and operational
experience with decontamination has been recently published.A"~
Despite the fact that it i£3 generally easier to remove fresh
contamination, experience has shown that it is not wise to
begin decontamination operations until careful planning has
taken place.  It is especially important to avoid the inadvertent
spread of contamination and costly delays that can arise from a
variety of deficiencies.  It is imperative that the operation be
controlled by one person, preferably a decontamination specialist.
The complex selection of personnel, procedures, techniques,
equipment, and supplies may depend on the details of the partic-
ular accident.
                                A-710
-------
        FOR_ DE_o:..ifTAMIHATION OF VEHICLES OR TRANSPORT
        OfiCTlVE" WASTES
The conventional procedures for decontaminating transpor^.ar".^
equipment, such as vehicles or packaging, depend on contact
with a chemical agent (soaking or spraying) or mechanical
action (vacuum cleaning, high-pressure steam or water, or
abrasive techniques) .A-8 1 Since these methods may produce a
substantial volume of radioactive waste it is preferable to
perform the cleaning in a decontamination facility such as a
nuclear plant or waste disposal site where handling of such
wastes is a routine matter.  In order to transport the contam-
inated equipment safely it is necessary to pack or wrap it or
otherwise immobilize the contamination.  If field decontami-
nation is required, methods that minimize the volume of radio-
active waste are desirable.

Since transportation accidents generally occur out of doorr
some decontamination has to be done under field conditions ,
and techniques for decontaminating roadways, vehicles, buil^i - '
exteriors and land have been developed. A    Unfortunately, mar,y
of these involve sweeping, flushing, or otherwise displacing
the material without actually collecting it.  Among the few
collection methods are vacuum cleaning, vacuum sandblasting or
grinding of hard surfaces, grinding or planing of wood surfaces,
and scraping and removal of soil.  Flame decontamination, which
uses special equipment incorporating a burner, brush, and
vacuum pickup, has been successfully done on concrete, wood,
and asphalt; it is reported to be an effective method for small
areas of wood and asphalt.     In many cases, it will be most
economical simply to remove and replace the contaminated surface
component.  It should be noted that extensive development has
been done on methods for decontaminating under cold weather
conditions.-^"   In addition, several pieces of highly special-
ized equipment have been developed  which might be particularly
useful in a large accident, including:

     •  a remotely controlled portable manipulator system;

        a power-driven, truck-carried spray decontami-
        nating apparatus;

     <•  a multiple-trailer mobile command post and
        clothing change facility; and

     «  aerial monitoring equipment in light aircraft or
        helicopters .
                             A-711
-------
Since transportation accidents may also occur in facilities
such as freight terminals, it is necessary to consider the
decontamination of building interiors and exteriors.   A variety
of methods have been used successfully for this purpose,
including:

     1.  washing with detergent and water or steam,-

     2.  swabbing with water or decontaminating agents?

     3.  blasting with wet abrasives,- and

                                            A-8 1
     4.  vacuum blasting with dry abrasives.

Steam cleaning and swabbing have the advantage of producing
relatively small amounts of waste.  However, for porous surfaces
such as wood and concrete it is frequently necessary  to resort
to mechanical removal of an appreciable layer of surface mater-
ial.  Specialized machines for swabbing and blasting  are avail-
able commercially.
                              A-712
-------
                          APPENDIX S
            UNIT OPERATIONS AND OPERATING COSTS FOR
            STORAGE OF HIGH-LEVEL  RADIOACTIVE WASTES
UNIT OPERATIONS FOR STORAGE OF HIGH-LEVEL RADIOACTIVE WASTES-
RECEIVING AND HANDLING

Procedures to be followed in the operation of the Retrievable
Surface Storage Facility  (RSSF) are dependent upon the design
concept chosen.  The following account is consistent with t>.^
preliminary design concept discussed in the main body of fh*?.
report but will change as the design concept is changed.

High-l^vel radioactive waste canisters will be received at  tl~
RSSF in shipping casks from the fuel reprocessing plants.
These -hipping casks provide shielding, cooling and impact
protection for the canisters during transportation.  The ca~~~
receiving area at the RSSF consists of a totally enclosed.
building with an air lock for contamination control into whic
a cask will be moved on either truck or railroad car,  Insic^
this receiving area the cask and transporter are cleaned and
surveyed for radioactive contamination.

The cleaned cask is removed from its transporter and cocJ ed .\
the receiving area to minimize thermal shock to the cask and
canister and to reduce the quantity of steam generated when
the cask is submerged in the water in the unloading basin.
The unloading basin is a large concrete vault filled with ^h
to provide cooling and shielding.  While under water, waste
canisters are removed from their casks in the unloading bar.ir
which is equipped with an underwater window for visual irspe-~
tion .  After a canister has been determined acceptable for
storage, it is moved from the unloading basin to the storrcr-.
area by means of a movable hoist on rails.
The storage area consists of a number of modular basins
the wastes are stored under water for radioactive shippi~j
purposes.  The design concept for receiving and handling high
level waste canisters at the Retrievable Surface Storage.
Facility is illustrated in Figure A-24.A~82  The flow dicvrr-^
for unit operations of this receiving and handling faci.l.i.,y  .'
shown in Figure A-25,
                             A-713
-------
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                                            A-715
-------
                Repackaging and Decontamination

When a canister is removed from its cask in the unloading basin
and found to be contaminated it is moved to the transfer lock
area of the basin, remotely raised out of the water and allowed
to dry in the transfer cell (a concrete-shielded "hot cell"
facility for remote operation).  The dried canister is then
placed in a transfer cask and moved into the transfer corridor
leading to either the repackaging cell or to the canister de-
contamination cell.

The canister cladding is repaired by welding in the repackaging
cell when the failure is minor.  Complete removal of the waste
from its failed canister and repackaging it, or placing the
waste plus the failed canister into another container known as
an overpack, is done when the original canister cannot be
repaired acceptably.  The repaired canister or the canister
inside an overpack is then replaced in a transfer cask and
moved through the transfer corridor to the decontamination cell.
Both the waste canister and the transfer cask are sprayed with
high pressure water and steam and decontaminated in an ultra-
sonic bath to remove any external radioactive contamination.
After decontamination the transfer cask is moved to the trans-
fer cell for reuse and the waste canister is moved through the
unloading basin and transfer aisle into the storage area of the
RSSF.

                        Operating Cost

Costs for operation of the Retrievable Surface Storage Facility
for high-level radioactive wastes (in 1973 dollars)  result
primarily from operating manpower, utilities, material consump-
tion, and equipment replacement.  The operating cost is expected
to increase as more waste storage capacity is used, so that the
values developed here are nominal ones for a time about ten years
after the facility begins operation.  Some of these costs are
highly unpredictable  (such as the cost of recovery from an acci-
dent) while other costs, such as manpower, can be estimated more
easily.  Recognizing the uncertainties involved in many cost
components, the total annual operating cost for the RSSF was
estimated at about $3 million.  Long-term amortization costs
would add about 0.3 million per year.  The components of cost
considered in this estimate are given in Table A-97,A~92

The primary operations performed at the RSSF are waste receiv-
ing, waste storage, and associated waste handling functions.
It is assumed that the facility is Federally owned and operated
by a contractor,  independent of other facilities that may  exist
in the same general area.  Maintenance required for safe opera-
tion of the facility would be performed by the plant work  force.
                             A-716
-------
                          TABLE  A-9 7

 OVERALL OPERATING COSTS, RETRIEVABLE SURFACE STORAGE FACILITY
               FOR HIGH-LEVEL RADIOACTIVE WASTES
                 ITEM
Operating Manpower (minimum
                    requirements)

Miscellaneous Materials & Service
(includes shared technical and
administrative services)

Accident and Incident Recovery

Electricity and Water Consumption

Container Repackaging

Processing and Disposal of Wastes
Generated

                                   Total
ANNUAL COST,
  DOLLARS
$1.4 million
$1.0 million

$0.1 million

$0.2 million

$0.1 million


$0.2 million

$3.0 million
                             A-717
-------
Operating cost savings may be realized if the facility is lo-
cated at an existing plant site where many miscellaneous
services such as occupational health care, fire protection,
plant security, utilities, general maintenance, and procurement
of spare parts, equipment and supplies could be obtained at
increased efficiency since other similar facilities have
similar requirements for these services.

Estimates of the minimum operating manpower were based on the
requirements for surveillance, maintenance, operations (contain-
er handling and repackaging), and technical support of the
high-level waste facility with six storage modules that will
hold a total of 3,000 waste containers.  This facility would
be operated continuously with approximately ten people per
eight-hour work shift.  Although the detailed organization
might vary from that shown for each shift in Figure A-26/ it
is believed that the total working crew requirements for all
shifts would be about five times those shown.  Four shifts are
required for around-the-clock operation, and the fifth shift
is always on the day shift.   (It is typical for plants oper-
ating continuously to need an additional working crew approx-
imately equivalent to a fifth shift  which performs scheduled
maintenance and special operations during the day-time shift
and provides a work force reservoir for vacation and holiday
relief.)  The shift supervisor for each crew would report to
the operations manager and be responsible for safe and efficient
operation of the plant.  If an adequate reservoir of technical
and administrative support personnel were available on an
existing plant site, manpower requirements for a minimum support
capability for administration, planning, engineering, and
safety at the facility would be reduced to those shown in
Figure A-27.  if the capability for administrative and technical
support at the facility were  required  to  be  completely  independent,
the manpower requirements would be about twice those shown in
Figure A-27.

Salaries and benefits were estimated at $15,000 annually per
person.  An equal amount was estimated to cover miscellaneous
services, overhead, and an allowance for replacement of capital
equipment.  Indirect manpower requirements, such as security
patrolmen, firemen, doctors,  nurses, utility linemen, stores
warehousemen, and truck drivers were included in miscellaneous
services and overhead costs.   The minimum direct manpower
required for the high-level waste storage facility  (the sum of
those indicated in Figures A-26 and A-27) is expected to range
from 70 to 90 people.  A small number of the waste canisters
may require repackaging upon receipt from the fuel reprocessing
plants.  An allowance for repackaging these and other contain-
ers which may fail during storage was included in the estimate.
                             A-718
-------













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                                                  A-720
-------
Consumption of electrical power contributes about seven percent
of the total operating costA~ 3due to a significant number of
large water pumps in the high-level waste storage facility.
The average rate of electrical consumption was estimated to
be about two megawatts.  The cost of electrical power in 1972
dollars was estimated at the rate of $0.01 per kilowatt hour.

Wastes generated in the RSSF will be primarily those assoc-
iated with contaminated water and ventilation filtration.
Ion exchange and filtration equipment will be used to remove
radioactive contamination from the water in the facility.  The
liquid radioactive wastes will be concentrated by evaporation.
The costs of the disposal for these wastes is a minor fraction
of the operating cost, and a small allowance was made for it
accordingly.  The solid wastes (spent ion exchange resins and
filters)  will be packaged and transported to the national
disposal site for low-level wastes.
                            A-721
-------
                          APPENDIX T
           UNIT OPERATIONS FOR STORAGE OF LOW-LEVEL
                      RADIOACTIVE WASTES
Unit operations at the disposal site for low-level radioactive
wastes will involve:  1)  receiving, sorting, and handling;
2) decontamination of transportation devices, work areas, and
equipment; 3)  concentration, conversion to solid, and canning
(e.g., incineration of solid wastes and evaporation of liquid
wastes); and 4) storage for an extended period.

RECEIVING AND HANDLING

Low-level radioactive wastes will be hauled to the receiving
facility by rail cars and trucks of various sizes.  The receiv-
ing facility must be fully enclosed and sealed to insure that
any spill of radioactive material during transfer operations
from the common carrier to the facility is contained within the
facility and does not enter the environment.  The receiving
area within the handling and transfer area should be designed
for easy decontamination (e.g., with nonporous surfaces and a
minimum of crevices and other obstructions).  As with the rest
of the treatment facility, ventilation air should flow from
this area to the next higher potential area for contamination.
All outside access to the receiving facility should be air-
locked (separated from the outside by sealed doors)  to prevent
radioactive contamination from moving within or outside of the
facility.

The facility must be capable of handling all shipping canisters
approved by the Department of Transportation for both liquid
and solid radioactive wastes.  High capacity (50,000 pound)
cranes and forklift trucks are required to handle the canisters-
The facility must have handling and unloading provisions for
low-level radioactive liquids shipped by truck or rail in
drums and large tanks.

Facilities must be capable of removing wastes from bulk transfer
canisters, decontaminating the canisters and returning them to
the common carrier.

Normally, the  key characteristics of the wastes  (form, chemical
content, physical properties, and radioactivity level) will
have been previously defined for each waste shipment.  However,
occasional characterizations will be necessary at the disposal
site to assure that the wastes are treated and stored with like
materials.
                             A-723
-------
     a shipment of low-level radioactive wastes is received at
the disposal site the records of its contents are checked, the
external surfaces are checked for contamination, and the radi-
ation levels are measured.  The disposition of the wastes through
the site is determined from this information.

All materials are handled within secondary enclosures such as
hoods, glove boxes, plastic-covered pipes, or pseudo-hot cells.
Materials with high radiation doses are handled semi-remotely
behind concrete shielding using shielded viewing windows, manip-
ulation, and cranes.  Other materials are handled more directly
without shielding or with portable shielding on the transport
devices.

Transport of heavy packages or packages with high radiation dose
rates is done by remotely-controlled cranes, including final
placing in the storage warehouse.  Other materials are handled
by forklift trucks, by cranes, and by other conventional tech-
niques.

The facility must have the capability of sorting the liquids and
solids into combustible and noncombustible fractions and for
storing each fraction for processing prior to disposal.

It is anticipated that the chemical composition of the liquid
wastes will have been determined and certified before shipment
to the disposal facility.  To insure that noncompatible liquid
wastes are not mixed together, the receiving facility has tankage
for segregation of the liquid wastes until chemical analysis of
each can be verified.  Capabilities for sampling and chemical
analysis are required at the disposal site to support this and
the many other chemical operations which are used.

The solid wastes must be segregated or sorted manually into com-
bustible and noncombustible fractions before processing.  Limited
automatic equipment is available for dry sorting of the various
solid fractions.  Most ferrous materials can be extracted from
the solid waste stream by magnetic separation.  Some success has
been achieved with air classifiers in the separation of paper,
plastics, and other combustibles from heavy materials such as
glass, ceramics and metals.  Due to the present state-of-the-art
it is anticipated that the solid materials will be separated by
hand in a glove box or shielded facility, depending on the radi-
ation dose level.

DECONTAMINATION

Decontamination is discussed in detail in Appendix Q.  Decontam-
ination at a processing and storage facility xatilizes essentially
the same techniques, the major difference being that any contam-
                              A-724
-------
ination or spills will be kept within the facility and will be
prevented from spreading beyond the facility by the building
ventilation system which is complemented by administrative
controls.

The receiving areas for the trucks and rail cars have provisions
for cleaning modest amounts of external contamination by spray-
ing with steam or water.  These reusable equipment pieces must
be decontaminated to nonsmearable levels.  Packages of radio-
active wastes with large amounts of external contamination are
taken into a decontamination  "hot cell" where external contami-
nation is removed remotely.  In more severe cases the packages
are enclosed in a temporary secondary wrapping (such as plastic)
and taken to an adjacent "hot cell" facility where the entire
original package is put into a permanent second steel container
and sealed.  This package is then taken to the storage warehouse
via the conventional handling techniques for waste packages.
Highly contaminated waste packages with similar external radio-
active contamination levels are handled in the same way but the
work is done principally by manual control through thin walls
of hoods or glove boxes.

Decontamination of work areas is handled as described in
Appendix Q, using combinations of chemicals (steam, detergents,
acids, bases, oxidants, etc.), elevated temperatures, and
mechanical assistance  (scrubbing, pressure blasting with liquids
or solids such as ice or sand, or ultrasonic agitation for
parts which can be removed and placed in ultrasonic baths).  In
some cases materials are physically removed (such as concrete,
paint, etc.) or covered with shielding (such as paint, concrete,
or metal).  A frequently used, convenient technique  for
clean-up of contaminated areas is to coat all surfaces with a
plastic film which can then be stripped away after a contami-
nation spill.  Techniques for decontamination have been studied
extensively and are summarized in the literature . A-84-A-86

Equipment decontamination is done similarly.  Small equipment
may be soaked in baths of decontaminating solutions.  Large
equipment is usually decontaminated internally in place as
fully as possible, then externally cleaned by manual techniques.
If the equipment is to be discarded it may be cut into smaller
pieces and packaged for storage in a storage warehouse.

Special care must be taken in the selection of chemicals and
materials for use in decontamination operations.  These mater-
ials eventually become wastes and must be processed within the
facility.  Therefore, they must be compatible with the waste
processing and storage system at the facility.
                          A-725
-------
VOLUME REDUCTION, CONVERSION TO SOLID, AND CANNING

For aqueous liquid wastes the choice of volume reduction tech-
nique is dependent on the amount and nature of the solids con-
tent of the wastes and to some extent on the corrosiveness of
the wastes. If trace ionic components are the only solids present,
ion exchange is suitable; if trace nonionic components are also
present, dewatering might be accomplished by a process such as
reverse osmosis.  If the solids content is high both of these
methods fail and evaporation and precipitation become favored
candidates.  However, precipitation is chemically specific and
many compounds are too soluble to be precipitated with common
industrial chemicals..

For all aqueous systems, evaporation concentration is the only
multipurpose method which will achieve volume reduction and con-
version of liquids to a solid.  The evaporator system must be
corrosion resistant under a wide variety of conditions, there
must be a sludge removal and drying system, the water vapor and
the off-gas must be treated to remove radioactive entrainment
and harmful volatile gases, the water vapor must be condensed,
and the water must be retciined until it is sampled to determine
whether it can be released to the environment.  (Alternatively,
the water vapor could be released directly to the air).  AEC
sites such as Hanford and Savannah River have large evaporators
for high-level wastes and separate evaporators for low-level
wastes.  Commercial fuel reprocessing plants also have evap-
orators for high-level wastes.  In general, these plants attempt
to recycle evaporated water and nitric acid for reuse rather
than to dispose of it.

A wiped film evaporator was selected because this type can pro-
vide  complete  dryness  to a powdered  product  and generally has
low sensitivity to foaming materials.  This type of evaporator
uses mechanically rotated blades to keep the scale concentrate
off the walls and to force the solid product through the dis-
charge pipe.  With proper but conventional designs entrainment
of aerosols into the vapor stream from the evaporator amounts
to less than one part in 100,000, so the vapor stream has low
levels of radioactivity.  The high efficiency glass fibered
mist eliminator on the evaporator vapor stream further reduces
entrainment and the final stage cleanup with a water scrubber
removes vapors of volatile constituents.

The product from the evaporator, which can vary from a dry
 powder  to  a sludge with  the  consistency  of tooth  paste,  is
routed to a small dryer for final removal of water.  This dryer
is indirectly heated and mechanically agitated to force the dry
powder out of the discharge end.  The dryer vents to the same
off-gas de-entraining and scrubbing system as the evaporator
vapors.
                                 A-726
-------
The dried waste from the dryer is metered into the standard
steel cans.  The full cans are then welded shut, monitored,
labeled, decontaminated if necessary, and sent to the storage
area.

Volume reduction of solid wastes again depends on the form of
the wastes.  Mechanical compaction can usually achieve volume
reductions of ten to one.A~87 However, if combustible wastes
are compacted a danger of fire hazard is always present in the
stored wastes.  In this design concept all combustible wastes
are incinerated before storage and incineration causes signif-
icant volume reductions without compaction.  Thus, compaction
was not selected for use in the disposal site.

Chemical leaching (such as acid digestion) of solid wastes can
convert the combustible materials to their combustion products
in an aqueous system and achieve volume reductions of fifty to
one.A~    The potential advantages of the acid digestion pro-
cess are a possible reduction in the off-gas treatment problem,
a relatively low temperature process  (250 to 270°C)  that is
easier to control than combustion, and very little need for
sorting before its application.  On the other hand,  the result-
ing liquid sludge must be treated for removal of radioactivity
and recycle and the  solid residue must be dewatered^ -  Hue to-the
cost of the undeveloped state-of-the-art of acid digestion of
combustible solid wastes this process was not selected for use
here, but it could have potential for future use.

Pyrolysis^-89 is essentially incineration at low temperatures
(up to about 800°C)  under less oxidizing conditions, with the
potential production of useful, combustible off-gases.  Pyrol-
ysis was considered for combustion of radioactive wastes because
of its low off-gas volume, its relatively low temperature, and
the good characteristics of its residue.  However, it has not
yet been extensively investigated for radioactive wastes and
its state of development is similar to that of acid digestion
for the application here.  Therefore, it was not selected for
use in this instance  but it could have future application.

IncinerationA~86 is currently used for some wastes at several
AEG facilities and is the method selected for the disposal site.
Of the many types of commercial incinerators only the rotary
kiln and the ordinary fire-box incinerator, which was selected
for use here, appear to be readily adaptable to burning radio-
active wastes.  The ordinary incinerator has the disadvantage
of incomplete combustion due to liquefying plastics dropping
through the grate into the ash box, but this is usually more
than offset by the high maintenance costs of rotary kilns.  For
radioactive wastes,  off-gas cleaning is a significant problem
because the off-gas  equipment must be remotely operable,
                             A-727
-------
designed geometrically to be critically safe at all times, and
able to remove submicron-size dust and corrosive and contami-
nated gases.  Thus the large volume of off-gas must be treated
to achieve radioactive decontamination factors of up to 10^ for
fly ash.  A low efficiency-high capacity filter system, a wet-
scrubbing system, and a high-efficiency filter make the off-gas
treatment auxiliaries the most expensive part of the incinerator
system.

Combustible organic liquids such as tributylphosphate and di-2
ethylhexyl phosphoric acid in kerosene must be incinerated
because of their unreleasable chemical compositions.  They often
present special problems in an incinerator designed only for
solids because of the unusual combustion products which some-
times include high concentrations of aerosols.  In this con-
ceptual design for the disposal site combustible liquids will
be fed to the same incinerator simultaneously with the combus-
tible solids.

The ashes from the remotely operated incinerator will be con-
veyed to the incinerator loading station.  Here  the ashes will
be metered into standard steel cans.  The cans are welded shut,
monitored, labeled, decontaminated if necessary, and sent to
the storage area.

Alternative methods for solidification or immobilization of
radioactive wastes without volume reduction, such as mixing with
concrete or asphalt, are being used in Europe.A-89  These tech-
niques were not selected here because of the lack of volume
reduction; in fact, a significant increase in waste volume
generally results from the use of such procedures.

STORAGE OF LOW-LEVEL RADIOACTIVE WASTES

The encapsulated and solidified low-level radioactive wastes
will be stored as previously described in two types of ware-
houses.  One type will include up to three feet of concrete
shielding (including removable cover blocks) to allow for
storage of wastes with high radiation dose rates; the other will
have essentially no shielding for wastes with very low radiation
dose rates.  The wastes in either case will be stored in rec-
tangular, sealed steel canisters 4 feet by 6 feet by 6 feet
high arranged in three layers.

Transfer of wastes to the shielded warehouses is done semi-
remotely by crane whereas transfer to the unshielded warehouses
is done directly by forklift truck.  Ventilation requirements
for the warehouses were described previously under the storage
concept.
                             A-728
-------
The wastes will remain in the warehouses untouched unless they
must, be removed for recanning due to leakage or until they ar?>
to be transferred to other disposal facilities.  Routine visual
inspection will be made of each canister and continual moni-
toring of the exhaust ventilation air from each of the compart-
ments in the warehouses will be maintained.
                              A-729
-------
                          APPENDIX U

                       COST ESTIMATES FOR
                 LOW-LEVEL WASTE DISPOSAL SITE
The capital and operating costs for facilities with incinera-
tion capacities of up to 500 pounds per hour have been esti-
mated, but no data on actual operating or capital costs for
facilities of the size required to meet the total production
rate in 1980 were available.A~9°  Therefore, a capital and
operating cost estimate was made for a facility with the
capability of concentrating an average of 3500 gallons of
liquid radioactive waste and incinerating an average of 1400
pounds of solid radioactive waste per hour  (these are average
hourly production values comparable to the annual rates pre-
viously described).  The capital and operating costs of remote
radioactive processing facilities are highly dependent on the
design criteria and operational procedures established for the
facility.  These are high-spot estimates.

CAPITAL COSTS

The estimated capital cost for the processing facility is
rounded to $19,000,000 as shown in Table A-98.  The high-spot
capital cost for the storage facility is $23,600,000 as shown
in Table A-99.

The storage warehouse will occupy a space of about five acres
The processing facility will be smaller, about 0.5 acres.  To
provide added protection for the public, a controlled plant
area will be needed around the plant and warehouse.  A 0.5-
mile exclusion distance should be adequate for low-level wastes,
Assuming the cost of land is $1,000 per acre, the acquisition
of land is about $800,000.  Access roads on the plant site for
both truck and rail car add another $2,000,000 to the total
capital cost.

Costs were established on the basis of buildings able to with-
stand tornadoes and earthquakes, with use of the present state-
of-the-art practice for contamination control, shielding, ar-r
remote handling.  Storage capital is also dependent on the
height to which the canisters are stacked.  The standard 4 f«et
by 6 feet by 6 feet high canisters can be stored from one to
five high and satisfy technical requirements for storage.  If
containers are stacked three high, the capital cost for a
storage facility is $8.19 per cubic foot of material stored.
                             A-731
-------
                           TABLE A-98

    CAPITAL COSTS FOR LOW-LEVEL WASTE PROCESSING FACILITY


            Item                            Estimated Cost

Head-End Material Handling                          $4,100,000
    (Includes:  solid and liquid receiving;
    storage for 1 week's production, decon-
    tamination system, segregation and fuel
    preparation systems, instrumentation,
    60 feet x 200 feet section of building
    with some shielded areas)

Incineration Area
    (Includes:  incinerator, gas cleaning            1,900,000
    equipment, vent system, 35 feet x 60
    feet section of building with some
    shielded areas)

Evaporation Area                                     1,600,000
    (Includes:  evaporator, dryer, condenser,
    retention pond, instrumentation, 25 feet
    x 60 feet section of building with some
    shielded areas)

Waste Packaging Area                                   640,000
    (Includes:  compaction, handling, decon-
    tamination equipment, and 30 feet x 60
    feet section of building)

Auxiliaries                                            900,000
    (Includes:  utility supply and auxiliary
    equipment, site preparation, paving and
    landscaping)

    Total Direct and Indirect Capital Cost           9,140,000

    Facility Design, Engineering, Quality            6,860,000
    Assurance Fee and Contingencies  (75%
    of Direct and Indirect Capital Cost)

    Land Acquisition Cost                              800,000

    Access Roads for Truck and Rail                  2,000,000

    Total Capital Cost for Processing Facility     $18,800,000

Bases:  Capacity is 3500 gallons of liquid waste per hour and
        1400 Ibs. of solid waste per hour, both of which are
        average at 80% operating efficiency.

                           A-732
-------
                          TABLE A-99

                CAPITAL COSTS FOR FACILITY FOR
           STORAGE OF LOW-LEVEL RADIOACTIVE WASTES
             Item

2 Shielded Buildings, 100,000 Square Feet
    at $100 per Square Foot

3 Unshielded Buildings, 150,000 Square Feet
    at $50 per Cubic Foot

    Total Direct and Indirect Capital Cost

    Facility Design, Engineering, Quality
    Assurance Fee and Contingencies  (35%
    of Direct and Indirect Capital Cost)

    Total Storage Facility Cost

    Capital Cost per Cubic Foot of Storage
    Space

    Total Capital Cost for Storage Space
    for 4850 Canisters (1980 Production
    rate)

    Total Complex Capital Cost (Processing
    and Storage Facility)
Estimated Cost

  $10,000,000


    7,500,000


   17,500,000

    6,100,000



   23,600,000

    8.19 per
    cubic foot

    5,700,000



  $42,400,000
Bases:  Containers are 4 feet by 6 feet by 6 feet, stacked
        three high.  The $23,600,000 facility is capable of
        housing 20,000 canisters.  Maximum production rate in
        1980 will be 4850 canisters per year.
                               A-733
-------
OPERATING COSTS

Operating costs were developed using the capital costs as the
primary basis.  Other assumptions used in the development of the
operating costs were:

  «  continuous processing at 80 percent efficiency on a seven-
     day-per-week, 24-hour-per-day basis;

  •  equal distribution of unit costs between liquid wastes and
     solid wastes on the basis of the amount of solids generated;

  *  capacity of the plant estimated to be 2.5 x 10  cubic feet
     solid waste and 30 x 10  gallons of liquid waste per year; and

  •  minimum operating crew.

Total operating costs were estimated to be $10.00 per cubic foot
of solids stored or $1.00 per cubic foot of solid waste as re-
ceived and $0.11 per gallon of liquid as received, as shown in
Table A-100  Storage operating costs for the year 1980 were esti-
mated co oe $2.40 per cubic foot per year, as shown in Table A-101
The operating costs are dependent primarily on capital costs and
operating efficiency.  It is felt that the capital and operating
costs are good high-spot costs for the capacities and assumptions
used.  This study shows that processing will be the major cost
item and storage the minor cost item per year, but the storage
costs are accumulative over a period of years.

In view of the extremely high total costs, a detailed cost/benefit
study (which is beyond the scope of this inquiry) on alternative
concepts and needs for storage/disposal of low-level radioactive
wastes is certainly warranted.

DESIGN AND CONSTRUCTION SCHEDULE

The major elements involved in implementing a radioactive proces-
sing and storage facility include:  overall hazard and concept
analysis, design, construction, acceptance testing, and environ-
mental impact and licensing activities.  The length of time re-
quired for impact statement and licensing activities is difficult
to estimate, as no precedent has been set.  If the disposal site
is built and operated by a firm with experience in the handling
and disposal of radioactive wastes, safety analysis and environ-
mental impact activity can probably be completed in two to three
years.  Assuming that detail is not started until all licensing
and environmental impact work is completed, an additional
three and one-half years would be required before the
                              A-734
-------
                          TABLE A-100


             OPERATING COST FOR PROCESSING LIQUID
            AND SOLID LOW-LEVEL RADIOACTIVE WASTES
          Item

Amortization and Interest at 6 Percent,
  15 Year Plant Life
Maintenance at 5 Percent of Capital Cost
Taxes and Insurance at 3 Percent of Facility
  Cost
Direct Operating Labor and Supervision
Overhead at 120 Percent of Direct Labor
Supplies and Services at 20 Percent of
  Maintenance
Storage Canisters 4850 at $50 Per Canister
Steam and Powers and Utilities

      Total Annual Operating Cost
      Operating Cost Per Cubic Feet of
        Stored Solids
      Operating Cost Per Cubic Feet of
        Received Solids
      Operating Cost Per Cubic Feet of
        Received Liquid
      Operating Cost Per Gallon of
        Received Liquid
   Cost, Dollars

     1,900,000

       940,000
       560,000

       520,000
       620,000
       190,000

       240,000
       600,000
     5,570,000


10.00 per cubic feet

 1.00 per cubic feet

 1.06 per cubic feet

 0.14 per gallon
Bases:  24 hour per day operation, 365 days per year operation,.
        2.5 x 10° cubic feet of solid waste processed per yearf
        30 x 10° gallon liquid waste processed per year,  80
        percent operating efficiency.
                                A-735
-------
                          TABLE A-101


          ANNUAL STORAGE COST FOR STORAGE OF LOW-LEVEL
          RADIOACTIVE WASTE, ONE YEARS PRODUCTION-1980
         Item

Amortization and Interest at 6 Percent,
  50 Year Plant Life
Maintenance at 2.5 Per Cent of Capital Cost
Taxes and Insurance at 3 Percent of Capital
  Cost
Direct Operating Labor and Supervision
Overhead at 120 Percent of Direct Labor
Supplies and Services at 15 Percent
  Maintenance

        Total Annual Storage Cost

        Storage Cost Per Cubic Feet
          Stored Solids
Estimated Cost,
   Dollars	

   340,000

   140,000
   165,000

   300,000
   360,000
    27,000
 1,332,000

 2.40 Per Cubic
 Feet Per Year
Bases:  Life of storage facility is 50 years.  Storage facility
        is built as required.  Based on annual processing rate
        of 2.5 x 10^ cubic feet of solid waste per year and
        30 x 10^ gallons of liquid waste per year.  Solid waste
        is stored in 4 foot x 6 foot x 6 foot high canisters
        stacked 3 high.  Total quantity of solid waste stored
        per year is 7 x 10^ cubic feet.
                             A-736
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plant could be operable at full capacity.  Thus, the total time
requirement would be about six years.  If the environmental
impact and licensing work can be conducted in parallel with
some design and construction, the facility might be fully op-
erational in a minimum of approximately five years.
                            A-737
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                          APPENDIX V
                  FINANCING CONSIDERATIONS
PUBLIC SECTOR FINANCE

This section provides a survey of the present and potential
mechanisms for State and local financing of solid and hazardous
waste disposal facilities.  It includes a discussion of gen-
eral categories of financing meghanisms and their relative
merits and a tabular presentation of specific examples of State
and local solid and/or hazardous waste disposal facilities.
A discussion of the most viable alternatives will be developed
later based on the information presented here.

                  State and Local Agencies

Historically, the burden of solid waste disposal has been the
responsibility of local governments or private firms.  System-
atic hazardous waste disposal has been handled both by private
firms and by public organizations.  The increasing magnitude
and complexity of local waste disposal, combined with the dif-
ficulty of financing sophisticated, large-scale facilities,
have prompted investigation of a means of obtaining additional
financial resources.  Present sources vary from area to area
but include direct financing from various tax sources, general
obligation bonds, and revenue bonds.  Financing by local au-
thorities or State utilities is a potential technique and in
several cases has been tried.  Each of these mechanisms is
discussed below.  Examples will be found in Table A-102

Not all existing mechanisms for solid waste disposal will be
relevant to the complexities inherent in disposal of hazardous
wastes.  Presentation of characteristics of existing mechanisms
is important, however, for assessing actual cases and for eval-
uating the potentials of proposed financing mechanisms.

                  Direct Revenue Financing

Income taxes, property taxes, and various types of special-
use taxes are potential sources of direct municipal revenue.
Use of these sources to finance new facilities requires an
initial budget surplus or payment of costs as they are incurred,
The advantages are the flexibility and low cost associated with
use of such funds.  These sources are likely to be more reli-
able than other forms of local finance, since voter approval
is generally not required.  On the other hand, financing of
                            A-739
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                              A-741
-------
capital facilities from accumulated funds may not place a fair
burden on future citizens of the community.   In terms of the
ability of the source to provide adequate funds for large-scale
facilities, it does not seem particularly promising at the local
]evel.

                    General Obligation Bonds

These bonds are backed by the full faith and credit of the
issuing municipality or community.  As such, they represent the
most widely used debt instrument for financing State and local
capital expenditures.  Advantages of this source include the
reduction of present financing requirements  from general reve-
nue and lower interest costs due to the lower investor risk and
exemption from Federal income tax.  In many  cases, the infor-
mation requirements for issuing general obligation bonds are
already available from other general bond issues.  This also
helps to reduce financing costs.  Disadvantages include the
reduction of municipal debt capacity and reluctance of the elec-
torate to increase its taxes to service the  debt.  Interest
costs for small communities are generally higher than for larger
ones.

                         Revenue Bonds

These bonds are secured completely by the charges of revenue of
an income-earning facility or project.  The  revenue bonds do
not generally require voter approval and may be issued by
municipalities, counties, authorities, and commissions.  Use of
this source may result in several advantages.  Most important,
revenue bonds do not reduce the bond indebtedness limitations
of local governments.  A second advantage is the independence
from voter rejection which can be achieved.   The final advan-
tage to this method is that only those who use the facilities
are required to pay for them.  Disadvantages often include
higher interest costs, depending on the credit rating of the
issuing municipality.  Extensive reliance on debt financing
will also reduce a municipality's credit quality.  Use of reve-
nue bonds may also involve overly restrictive agreements
against diversion of revenues and mismanagement.

                   Special Assessment Bonds

This vehicle involves the levying of a specified rate and a
flat sum charge for each type of property.  The advantage is
that those who benefit, also pay for the services.  Disadvantages
are  similar to those of the general obligation bond in that a
local government's debt capacity is reduced.  For the most part,
this approach would be inapplicable for large-scale facilities.
                           A-742
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                   Industrial Revenue Bonds

In all but a few States legislation formerly existed which per-
mitted cities and counties to issue bonds for financing con-
struction or acquisition of industrial facilities.  A $5,000,000
ceiling on the bonds placed by Congress in 1968 caused the mar-
ket to dry up.  At the same time, Congress exempted bonds for
pollution control facilities from the ceiling.  Thus local com-
munities can use pollution control bonds to finance industrial
facilities.  In this sense these vehicles are different from
general obligation bonds in that the local government's debt
capacity is not reduced.  However, this debt may affect the
credit rating of the community.  Drawbacks include the effect
on local government credit and its capacity to finance other
capital expenditures,^~92 The public subsidization of industrial
abatement cost is another major issue in this approach.

                     Authority Financing

In many States it is possible under existing State corporation
laws for local governments to create nonprofit corporations
(authorities) which can issue revenue bonds.  A deficit in
the operations of the authority does not result in a lien
against the local government.  Also, the marketability of the
revenue bonds is independent of the municipality's credit rating,
If the authority fails, there is no credit effect on the
municipality ,-^~   If the loan provides for purchase of the facil-
ity at the end of the period IRS treats it as an industry
debt, resulting in a deduction for interest and depreciation.
The alternative is to deduct payments as operating expenses.
Since the term of memberbhip of the governing board generally
outlasts the administration of the local government, a degree
of political independence is also achieved through this
mechanism.

Loss of political control may be a disadvantage from the point
of view of elected officials of local government.  The New York
Port Authority is one case in which an authority has gained
significant independent powers.  Some opinion holds that the
Port Authority lacks the constraints to make it responsive to
public wants.

                            Leasing

In some cases local governments can meet their needs for the
financing of facilities through leasing from the private sector.
The major advantage here is that no bond issues or accumulation
of excess revenues are required.  This method also provides a
certain additional flexibility in planning, since no elections
are required.  The major disadvantage is the cost.  Since the
private sector must recover full costs plus profits, rental fees


                                A-743
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are generally greater than the interest cost that would be
incurred through debt financing.  In the State of Ohio leasing
of facilities is being interpreted as the creation of debt,
thus requiring all the constraints of a regular debt issue.

                        Lease/Purchase

The only difference between lease/purchase and direct leasing
is that the ownership of the facility reverts to the munici-
pality after the private investor has recovered his costs,
interests, and profits, usually within a specified number of
years.  Advantages to this approach are the flexibility it
provides as well as the creation of equity at the close of the
lease period.  Disadvantages include the higher costs.

It is possible is some States to arrange for lease/purchase
from a nonprofit corporation.  Thfis arrangement is similar to
authority financing in that a nonprofit corporation is created
with the authority to issue revenue bonds.  The bonds are
secured by the lease agreement, and interest earned by inves-
tors is tax-exempt.  At. the end of the lease period, the
facility is transferred to the local government.  This method
of financing reduces cost and permits construction of facili-
ties to desired specifications by competitive bidding.-^"92

                             Loans

In a few instances, bank loans have been used for financing
local capital development programs.  Generally this method is
expensive due to high interest rates.

                  Existing State Mechanisms

Direct State financing of major solid waste disposal facilities
is not presently practiced.  State governments, however, could
play a significant role in solid or hazardous waste management
by creating public corporations or authorities for that pur-
pose.  As in the case of local authorities, State authorities
are granted the power to issue revenue bonds with interest
accrued through user charges.  A major advantage of this
approach is the potential for creation of regional solutions
to problems.  Creation of a nonprofit corporate body or a
utility under State authority permits cost-effective solutions
to interregional problems through realization of scale economies
For large scale and widespread waste management problems this
approach is not only more efficient economically but is likely
to be more workable politically.
                          A-744
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>~het>er the management agency is set up as a nonprofit p-.zb I
corporation or as a State regulated utility, several advant
are apparent.  Major cost savings are usually involved in
ing large packages of bonds.  Per unit overhead costs necesBc.-ry
to prepare the issue are lower, and the involvement of the
State generally creates more favorable market terms.  If the
agency or authority is set up as a public body, added capital
financing advantages are obtained through the tax free provi-
sion on income from such bonds.  In many cases creation of a
waste disposal service utility will reduce disposal costs of
industries with particularly difficult waste disposal probl^^p
requiring special equipment and processes.  Such equipment
would generally be too expensive for individual industries to
purchase.

The one major disadvantage to State control of utilities or
authorities is a loss of local autonomy.  The nature of th«
waste disposal problem, its costs, and the method by which
diverse viewpoints are incorporated in the decision procesr
will determine the degree of political opposition this arrange-
ment can be expected to face.

FEDERAL FINANCING

Federal financing of a National hazardous waste disposal system
conceivably could be developed along many different linen,' Thi
could include complete Government operation, either subsidi:.~"
by the public sector or operated as a revenue-generating sy-  rr
to cover complete costs.  Another possibility would be Govern-
ment financing and construction with provisions for leasing L-.O
the private sector.  Again, this could be operated as a lul."1
cost recovery setup or could be envisioned as a partial or
complete subsidy to the private sector.  Other means of direct
Federal involvement in a hazardous wastes disposal system world
include guaranteed loans and the regulatory policies which
guide the private sector in its provision of hazardous war,t---~
disposal services.  Examples of Federal financing prograns
include the following.

                 United States Postal Service

The U. S. Postal Service is a Government-owned corporation
operated on a self-supporting basis.  It was created as c-n  "-.•"-•
pendent establishment of the Executive Branch by Section IT -'
the Postal Reorganization Act of August 1970, and commenced
operations in July of 1971.  It is set up with a Board of
Directors empowered to set rates and as a corporation with .f;i."i..1
control over postal revenues and expenditures.  As such it ir
empowered to borrow from the public with an upper limit of
$2 billion in bonds and debentures per year, up to a total of
                            A-745
-------
$10 billion.  To date it has $250 million in debt financing.
During the transition period some subsidies have been required,
but subsidization will be completely phased out by 1984.   Its
employees receive benefits similar to those of Civil Service,
though they are not subject to the same system of raises  and
are empowered to negotiate for their own pay scales.  The
Board of Directors is appointed by the President on a staggered
basis and this Board of Directors then selects the Postmaster
General and his assistant.

       National Railroad Passenger Corporation (Amtrak)

The National Railroad Passenger Corporation was created by the
Rail Passenger Service Act of 1971.  This is a corporation
similar to the U. S. Postal Service with the express purpose
of providing passenger services to selected areas of the
United States on a profit basis.  As originally envisioned,
the public was to be offered a chance at ownership through
convertible preferred stock issues paying 6 percent dividends.
To date, no preferred stock has been issued because the
corporation has shown a substantial loss and no market for its
securities presently exists.  Fiscal 1972 operating revenue
was approximately $152 million while expenses of $306 million
were incurred.  These expenses include capital expenditures
in terms of refurbishment of equipment as well as operating
costs.  The deficit is made up from a guaranteed Federal
loan of over $100 million, a $40 million transfer, and a
$300 million buy-out fee from railroads, as well as other
Federal sources.  Railroads which contribute to the operation
are given options on electing a portion of the Board of
Directors and receive stock for their portions of the financing.

                  Tennessee Valley Authority

The Tennessee Valley Authority was established as a corporation
by Congress on May 18, 1933.  TVA was created to develop and
operate a program of resource conservation and development in
the Tennessee Valley area thus inducing economic growth.   The
Authority operates a system of interrelated dams on the
Tennessee River and its larger tributaries.  The dams provide
a variety of benefits, including flood protection, navigation,
recreation, and, most important, production on electricity.
According to the provisions of the TVA Act, the Authority
is to promote the widest, possible use of electricity and to
assist in the Tennessee Valley area's regional economic devel-
opment.  As such, the power production is the only financially
self-sufficient activity.  TVA has the authority to issue bonds
and, over the long run, under the interest criterion established,
has been self-liquidating.  It is in the process of repaying
all initial Federal appropriations.  On the other hand, the
                            A-746
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navxcration, recreation, flood control, and related activities
all receive annual appropriations from the Federal Government.

The Tennessee Valley Authority also operates a fertilizer
research center in Muscle Shoals, Alabama, to promote the devel-
opment and application of new fertilizer technologies and vari-
eties.  Some revenue is generated through the sale of relatively
small amounts of fertilizer produced at this research laboratory.
In general, no State contributions are involved in the overall
TVA operations.  On the other hand, there is State participa-
tion in local projects in which benefits accruing to local
communities can be identified, such as water supply projects.
For fiscal year 1971 Federal appropriations for the overall TVA
operation were $56 million.  Operating revenue from its electri-
cal facilities totaled $642 million for fiscal '72.  Total
investment in TVA is several billion dollars.

              Federal National Mortgage Association
         and Government National Mortgage Association

Since the great depression of the  1930s the Federal Government
has attempted to both stimulate and stabilize housing and gen-
eral construction activity through creation of secondary mar-
kets for mortgage securities which assure a reasonable degree
of liquidity for such securities.  Through various legislative
acts, the Government has created secondary mortgage markets for
Government-insured or guaranteed  (FHA and GI) mortgages.  The
Federal National Mortgage Association represents the major
attempt in this direction.  In 1968 the FNMA was divided into
two parts, the original Federal National Mortgage Association
and the new Government National Mortgage Association.

Federal National Mortgage Association

After earlier attempts to create a secondary mortgage market in
the 1930's had proved unsuccessful, the Reconstruction Finance
Corporation was ordered to establish a national mortgage asso-
ciation under provisions of its enabling legislation, and the
resulting organization became known as the Federal National
Mortgage Association.  Essentially it was organized as an
emergency measure to provide liquidity for mortgage loans
insured by the Government at high loan-to-value ratios and low
rates of interest.  It was also intended to provide money to
stimulate new construction by purchasing FHA 100 percent guaran-
teed mortgage obligations.  Under this arrangement only Govern-
ment guaranteed and insured mortgages were eligible for purchase
by FNMA.  Emphasis was on new construction and current mortgage
lending.  By the middle 60's several apparent problems had
materialized in the FNMA setup.  As it actually operated, the
majority of FNMA activities seemed to concentrate in those States
                                A-747
-------
where lending risks constrained the availability of private
mortgage funds.  By indirectly lending at below-market rates
of interest in areas where risks would normally require a
higher interest rate, the Federal Government constituted an
implicit subsidy to the private sector in these areas.

Due to these problems and the need to create greater stability
and availability of liquidity in the mortgage and housing
market, the Federal National Mortgage Association was split
into two distinct corporations under the Housing Act of 1968.
The new Federal National Mortgage Association operates as a
private corporation with privately held stock, but it is
regulated by the Federal Government through the Department
of Housing and Urban Development.  The Housing Act provided
a mechanism for a secondary market in conventional mortgages
in order to broaden FNMA's secondary mortgage operations in
the private sector.  Under this arrangement both conventional
and Government-backed loans are held by FNMA until amortized
as scheduled.  The purpose of this arrangement is to provide
a supply of new money to the home industry above amounts
normally generated through private market sources.  Since
FNMA is an investor-owned secondary market corporation, it
must earn on its outstanding capital an overall return that
provides a profitable return for its own capital investors.

Government National Mortgage Association

The GNMA retains many of the activities of the pre-1968 Federal
National Mortgage Association.  It is a Government agency and
remains a part of the Department of Housing and Urban Develop-
ment.  As such it is a corporation without capital stock and
is designed to handle special assistance management and related
financial functions which were formerly part of the old FNMA.
Under provisions of the 1970 Housing Act, GNMA and FNMA may
work together for purchase of mortgages of lower income
families.  Under this arrangement, GNMA commits itself to low
yield mortgages at their market value and then sells to the
Federal National Mortgage Association at the going market rate.
The GNMA absorbs the difference in price; the GNMA securities
are backed by mortgage pools of the Federal Housing Administra-
tion and Veterans Administration which are secured by the credit
of the United States Government.

PRIVATE SECTOR FINANCE

This section covers the preliminary identification and analysis
completed on private sector financing mechanisms in the hazard-
ous wastes disposal field.  The report outlines the financing
mechanisms available either presently or potentially to the
private sector.  Information collected on substantially all  the
financing mechanisms available to the private sector interest
today is reported here.

                          A-748
-------
Ths objective of this effort was to define and analyze the
alternative mechanisms for financing a national system for
hazardous wastes management.  This objective has been developed
in a succession of stages or phases:

     •  Identification of Financing Mechanisms
     •  Analysis of Financing Mechanisms
     »  Development of New Financing Mechanisms

Substantially all of the work has been completed on the first
two phases and is presented here.  In addition, a section on
system configuration has been added due to its importance in
relation to the second phase.

           Identification of Financing Instruments

The various financial instruments for supplying funds for capi-
tal and operating expenditures derive from both the private and
public sectors.  These include the following:

     Bonds

        Regular
        Industrial Revenue
        Pollution Control
        General Obligation
        Revenue
        Convertible

     EquityInterests

     •  Common, Preferred, and Lettered Stock
     •  Full and Limited Partnerships

     Internal Corporate Sources

     •  Retained Earnings

     Public Sources

     •  User Taxes/Charges
     •  General Taxes (income, sales)
     •  Special Taxes (ad valorem, earmarked)
     •  Special Assessments

     Loans

     •  Banks/Financial Intermediaries
     •  Insurance Company
     •  Subdivision, State, Federal
                               A-749
-------
     Leasing

     •  Lonq-term

     Tax Credits

     •  Special Investment Credit

Variations in each instrument can be used separately or in
combination with other instruments for financing a system.  In
some cases a combination may achieve the most economical
financing.  Furthermore, specific operating cost financing
schemes may be changed from time to time allowing a degree of
freedom which does not exist for capital cost financing.  Each
major category of financing instrument is discussed briefly
below.

Bonds

This financing mechanism is a product of the market mechanism
for obtaining capital resources.  The two sources issuing bonds
are private corporations and public organizations  (municipali-
ties, regional authorities, and the Federal Government).

Private corporate bond issues,  (i.e., straight bonds) which
have taxable yields as well as taxable capital gains, if any,
are sold to the public through investment bankers.  The invest-
ment banker together with the issuer jointly considers the
intended use of the proceeds, the history of financial success
of the issuing company, and relevant market factors such as
prevailing interest rates in determing the size of the bond
issue, its degree of risk, and its coupon rate.

Convertible bonds, also issued by private corporations, have
many of the features of straight bonds.  However, this security
can be exchanged  (or converted) into an equity position (to
common or preferred stock) under conditions noted in the inden-
ture defining the terms of conversion.  Convertible bonds offer
the investor the right to change from holding a debt security
to holding an equity position in the corporation.

The four remaining bond types are issued by public bodies, such
as school districts, authorities, counties, and other political
subdivisions.

Industrial revenue bonds  (IRBs) are issued by political sub-
divisions; pollution control bonds, a special type of IRB,
are usually also issued by political subdivisions.  These
mechanisms offer potential sources of financing for a system
of hazardous waste disposal facilities, other pollution-
related financing needs  (e.g., solid waste disposal facilities,


                          A-750
-------
industrial pollution control equipment, and various air and
water pollution facilities for private companies or political
subdivisions),  and other facilities used by or for the public
welfare.

The interest payable on each of the publicly issued bonds is
exempt from Federal income taxes under existing statutes,
regulations, and court decisions.  In addition, depending upon
the State regulations on issuing bonds from political sub-
divisions or authorities, the income  (excluding capital gains)
to the bondholder derived from selling the security may be
exempt from State, county, and municipal taxes.

It should be noted that industrial revenue bond (IRB) financ-
ing is totally exempt from taxes on interest regardless of the
use of funds for issues less than $5 million.  For IRB
financing in excess of this figure, restrictive covenants
determine the use of funds to obtain tax-exempt status.  There
is no indication that capital gains on IRB or other bonds are
tax-exempt by the Federal Government.

Industrial revenue bonds are used to finance industrial plants,
equipment, or facilities.  These assets in turn are sold or
leased to a private corporation by the public body which issued
the bonds.  Lease payments must be sufficient to cover the
interest and principal of the bond issue.  Industrial revenue
bonds are secured by the lease or sale agreement with the pri-
vate corporation using the assets rather than the taxing power
of the issuer;  essentially, the corporation obtains long term
capital generated through a tax-exempt security, thereby
reducing the corporation's cost of capital.  The political
subdivision or authority issuing the IRB acts only as a conduit
between bondholders and the private company.  The credit rating
of the corporation entering into the lease or sale agreement is
the usual credit rating of the issued IRB; the political sub-
division issuing the IRB is transparent for purposes of the bond
credit rating.  IRBs have no effect on the credit rating of
their issuer or his debt capacity.

Pollution control bonds (PCBs) represent the result of a 196F
Treasury Department decision to limit the tax-exempt status of
IRBs used to finance general industrial expansion to issues cf
less than $5 million.  Issues greater than that amount would
be tax-exempt only if the proceeds of the bond issue are used
to provide certain exempt facilities, including air or water
pollution control facilities.  PCBs are special IRBs which m.?.v
be issued in any amount and retain their tax-exempt status.
In summary, tax-exempt IRBs may be issued:
                            A-751
-------
     (1)   in any amount to finance pollution control or other
          exempt facilities or assets (these are called PCBs);
          or

     (2)   to finance any facilities or assets, provided that
          the $5 million limit is not exceeded.

General obligation and revenue bonds are tax-exempt issues used
to provide financing for exempt persons as defined in Section
103 (c)  (3) of the Internal Revenue Code; exempt persons include
governmental units and certain nonprofit organizations.  The
proceeds of these issues can be used for any purpose desig-
nated by the issuer.  Typical examples of GO and revenue bond
financing include construction of public auditoriums, hotels,
parks,  and certain office buildings.  General obligation bonds
provide for a guaranteed payment of principal and interest
through the taxing power of the issuing political subdivision;
revenue bond interest payments are not guaranteed by the issuer
but are supported through the revenues generated by the pro-
jects financed by these bonds.

Equity Interests

The equity interests which are potential finance mechanisms
include common, preferred, and lettered stock and partnership
arrangements.  The stock mechanism is typical of any private
sector ownership in which the business risk is borne by the
shareholder.  Preferred stock, as the name implies, has privi-
leges usually related to the order of payment of dividends or,
in case of bankruptcy, in dissolution of the company's assets.
Preferred stock is the most senior security in the equity class.

Common stockholders are the residual owners of the private
enterprise after all other senior securities have been serviced.
Common stock is more risky to hold than preferred stock and has
the greatest potential for profit or loss of any of the typical
financing mechanisms used to provide funds to a private corpo-
ration .

Another class of stock, lettered stock, is infrequently used to
provide funds to a private corporation.  This stock is usually
employed in business situations which are highly risky and
potentially very profitable for their owners.  Often this stock
has little liquidity  (is not readily marketable).

Partnership arrangements to provide financing are of two
principal varieties, full and limited partnerships.  As their
names imply, the risk and,, consequently, the potential rewards
for full partnership arrangements are greater than in  limited
partnerships.  Full partnership financing arrangements carry
                            A-752
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with them unlimited liabilities if the business fails; that is,
a full partner risks all his personal capital as well as that
used in the business in which he holds a partnership interest.
Conversely, limited partners usually risk only the amount of
capital committed to the business.  Limited partnership arrange-
ments are often used as tax shelters by persons with high tax-
able incomes.  Limited partnerships are sometimes used in
conjunction with certain leasing arrangements to be discussed
below.

The above equity interests relate only to the private or quasi-
public sector, as in a Comsat-type corporation.  No equity
interests are available in municipalities, counties, regional
authorities, and other political subdivisions which by their
public nature cannot issue securities granting ownership rights.

Internal resources available to finance private corporation
ventures are obtained from retained earnings, on earnings
available after all expenses and deductions have been made from
all sources of income, operating and nonoperating revenue
streams.  Retained earnings represent an accounting entry, not
a pool of liquid assets.  However, this resource can be used to
finance corporate expansions into new or existing businesses.

Financing can also be obtained for the system through the tax-
ing power of various political subdivisions.  The four taxes
examined can each generate funds for construction, operation,
maintenance, and perpetual care of the system.  User taxes/
charges represent a charge based on a prorated formula, usually
by volume or weight of waste processed by the facility.  This
is a direct charge which forces the financial burden onto the
waste generators.  General tax revenues are also possible
sources of financing.  Using general tax revenues places the
burden of financial responsibility upon all persons in the
political subdivision imposing the general tax.  Special taxes
and assessments differ from general tax revenues in that they
are clearly identifiable as to their amount and purpose.  These
may be imposed upon certain persons in the general population
of the subdivision.  Note that authority structures have no
taxing power.

All tax sources are the province of the public sector; no pri-
vate corporation or partnership can employ tax revenues
directly.  In the case of loans from a subdivision to the
private sector, tax sources may be used indirectly, however.
Loans from banks, insurance companies and other financial inter-
mediaries may also be sources of funds to finance the system.
It may also be feasible to obtain a combination of insurance
and loans from a major insurance company or consortium of
companies to reduce the effective interest rate on the loan.
                            A-753
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Loans from banks may carry lower-than-market interest rates if
a favorable IRS ruling is obtained to allow interest payments
to the lending institution on the loan to be excluded from its
taxable income.  Lastly, loan instruments are generally inter-
mediate term  (5 to 10 years)  financing mechanisms.

Leasing may also be used as a financing tool.  Lease arrange-
ments primarily supply capital assets without the need for
large initial cash outlays, securities issues, or significant
balance sheet changes.  Leases supply working assets without
impairing the corporate debt-equity ratio, which is used as a
guideline in credit rating.  However, leases must be reported
(at least a footnote)  in the corporation's balance sheet.  If
the public sector leases facilities, no voter approval is re-
quired.   The public organizations reviewed which use leasing do
so only as interim financing, for a period of months, until
other financing such as budget allocations is found.

Ordinary lease arrangements are typically accompanied by higher
interest costs but relatively little initial cash flow.  In the
case of leveraged leasing, a transfer of certain tax benefits
from the lessee to a third-party financial institution (e.g.,
a bank)  results in lower interest expense to the lessee.   In
leveraged leasing a third-party financial institution invests
some fraction of the equipment/facilities cost,  usually in the
range of 20-40 percent; the remaining 60-80 percent is borrowed
from long-term lending institutions.  The equipment/facilities
are then leased by the third-party interest to the lessee, who
makes rental payments at least sufficient to cover the princi-
pal and interest on the long-term debt.  This debt is secured
by a lien on the equipment and an assignment of the rights of
the third-party financial institution.

Lease terms generally range from 10 to 30 years; the terms of
the lease must be less than the useful life of the leased assets
to qualify as a true rather than financing lease.  In the latter
case the lessee would be treated as the asset owner for tax
purposes.  Usually the lessee will have the option to purchase
the assets at lease expiration at its fair market value.

The key to leveraged leasing rests in the allocation of depre-
ciation and investment credits to the third-party financing
institution.  The degree to which the lessor will effect inter-
est savings for the lessee is realized only to the extent that
the tax benefits shifted to the financial institution could not
be used by the lessee if he had chosen to purchase or obtain a
financing lease.

Variations on leveraged leasing are available.  One variation
is to obtain  the long-term debt portion of the financing from
                            A-754
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an authority or political subdivision which issues tax-exempt
IRBs or PCBs.   Proceeds from the bond issue, together with a
prepaid rent of 20 to 40 percent of the equipment/facilities
cost supplied by an institutional investor, are then used by the
authority/political subdivision to purchase the equipment facil-
ities.  The institutional investor obtains a financing lease
from the authority/political subdivisions.  The institutional
investor then becomes the owner of the assets for tax purposes;
in turn the institutional investor subleases the assets to a
private corporation under a true lease.  An income tax ruling
would have to be obtained to determine if the sublease qualifies
as a true lease; bond counsel opinion on the legality of a
political subdivision entering into the transaction may also be
required.  As in the case of straight leveraged leasing, the
interest savings to the private corporation are based on the
grounds that the institutional investor can realize tax benefits
that the company itself could not have used.

Other arrangements using limited partnerships to supply the 20
to 40 percent of the asset cost with either long-term loans or
IRBs supplying the balance of the purchase cost are analogous
to the above two examples.  In this case the tax benefits accrue
to the limited partners in much the same way as these benefits
accrued to the financial institution in the above examples.

The private sector may be able to make use of tax benefits from
investment tax credits and accelerated depreciation schedules
to help finance the development and operation of a processing
and disposal site system.  In conjunction with these tax write-
offs, guaranteed loans or bonds may become available to the
private sector for additional financing sources.  New legisla-
tion would be necessary to allow guarantees on loans or bonds
for financing part or all of the system.  Together these
mechanisms may enable private corporations to more easily
identify a potentially profitable business opportunity and
enter this area as a new business.

ANALYSIS OF FINANCING MECHANISMS
The mechanisms discussed above will be reviewed on the basis
of their practicality and degree of utility in providing funds
for a national site system.  This analysis attempts to identify
the characteristics of the possible financing mechanisms and
factors affecting them in relation to their capabilities for
generating sufficient funds at reasonable cost.  A principal
concern in this analysis is acceptability of a mechanism to
either the public and/or private sector interests which might
employ it.  In addition, incentives for developing new financ-
ing mechanisms will be discussed in this section.
                            A-755
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       Industrial Revenue/Pollution Control Bond Issues

Of the bonds available for financing the site system, PCBs have
an advantage since a) they can be issued in any amount, b) they
are tax-exempt for all but substantial users of the assets so
financed, and c)  they are financing vehicles acceptable to the
investment community.  A major consideration in issuing PCBs is
the potential that this type of security will be phased out of
existence if IRS rules unfavorably on their tax-exempt status
as they did on IRBs in 1968.  Consequently, plans to roll over
debt using future issues of PCBs are speculative and may not be
reasonable.

The interest cost on PCBs and IRBs is equal, generally 1 1/2
percent to 2 1/2 percent lower than the market interest rate on
long-term funds;  however, IRBs carry the $5 million limitation
on unrestricted application of the proceeds of the issue.  In
cases in which an IRS ruling is required, the tax-exempt status
of the issue must be within the guidelines established in Sec-
tion  103 (c)  of the Internal Revenue Code.  Cases which meet
the established guidelines can use PCBs issued in any amount.
It is possible that the system would qualify for tax-exempt
status under IRC Section  103 (c);  an IRS ruling will be required
to fully determine this issue.

A private corporation using PCBs may frequently be treated as
the owner of the facility for Federal income tax purposes.
This would entitle the company to take depreciation on the
facility, the investment credit (if available), and to deduct
a portion of the lease payments equivalent to the interest on
the bonds.  In addition, it has been possible for private cor-
porations to use PCBs without restrictions on other forms of
borrowing by the company.  Further, these bonds are exempt from
the registration requirements of the 1933 Securities Act and,
in many States, from qualification under the Blue Sky laws.  In
States where the political subdivision is treated as the owner
of the facilities, the private company may be entitled to a
total or partial exemption from State and local taxes on real
property or make reduced rental payments in lieu of these taxes..
In some States, the private company may be exempt from sales
taxes on materials and equipment used in constructing or
acquiring the facility.  Lastly, IRBs  (or PCBs) are a less
costly form of bond financing than straight, or convertible bond
financing.

            General Obligation and Revenue Bonds

General obligation and revenue bonds are tax-exempt but less
attractive financing mechanisms.  GO bonds require a pledge
that the principal and interest will be secured by the taxing
                            A-756
-------
power of the political subdivision.  In addition, these bonds
affect the borrowing capacity of a political subdivision since
they reduce the subdivision's unallocated debt capacity.
Revenue bonds carry the credit rating of the issuer but do not
affect the unallocated debt capacity of the issuer.  Revenue
bonds do not require voter approval and are serviced only out
of user charges.

                      Authority Financing

In offering public bonds, it is advisable to establish an
authority for a number of reasons.  First, deficit operations
of an authority do not result in liens against the local govern-
ment; next, the credit rating of an authority's bonds is inde-
pendent of the political subdivision, including the authority;
lastly, authority bonds have terms up to 40 years.  Further,
since the administration of an authority often outlasts the
term of office of local officials, a degree of independence is
maintained.

In conclusion, bonds, particularly PCBs, represent a viable and
continuous mechanism to finance a site system.  The degree of
risk and the accompanying return are commensurate.

                       Equity Financing

Equity interests hold less promise as complete financing ve-
hicles since they entail a far greater degree of risk by
investors.  It presently is not clear that there would be a
market for stock in private companies seeking hazardous waste
disposal business.  Clearly, the worst case of any equity
interest is the full partnership since this arrangement carries
unlimited liability.  In a business where the future risks can-
not be reasonably assessed, full partnerships are extremely
risky.  Limited partnerships, on the other hand, offer poten-
tially the best source of equity financing for the system since
these investors will at least be able to obtain a tax shelter.
The poorest equity financing mechanisms for this system are
common and lettered stock since there is virtually no publicly
available operating data on an operation of this nature.  There
is no protection of a guaranteed dividend payment which accom-
panies preferred stock if the company make sufficient profit
to pay any dividends; consequently, the holder of common or
lettered stock has no assurance that he will ever be able to
recoup any of the investment.

                  Retained Earnings Financing

From the standpoint of a corporation, retained earnings financ-
ing should be a cheaper means of financing any corporate expan-
sion.  However, due to the magnitude of the required investment,
                            A-757
-------
it is extremely unlikely that any one company alone would be
interested in developing a complete national system. Instead,
in conjunction with a PCB issue, a corporation may be willing
to establish a wholly-owned subsidiary holding a controlling
interest in one or more processing and disposal sites.   The
nature of the entire system would have to be determined to
elicit retained-earnings financing from the private sector.
Various systems configurations will be discussed below to iden-
tify possibilities.

                         Tax Financing

Public taxing power is capable of generating sufficient funds
to finance a national site system.  However, it is unlikely that
political subdivisions will readily assume this posture since
hazardous waste disposal has no precedent for funding by local,
county, or State government.  Further, it is quite likely that
these governmental units will argue that hazardous waste dis-
posal is a national problem; as such they may argue the problem
should be treated by the Federal Government.  Since officials
of political subdivisions are reluctant to increase the taxes
of their electorate, it is unlikely that they will readily
adopt the responsibility of financing the system's disposal
sites through tax revenues.  It is expected that some wastes
processed at a facility will not be generated locally,  which
further removes the case for local tax financing from realistic
consideration.  However, the user tax appears to be a feasible
mechanism for financing operations and maintenance.

                             Loans

The case for using loans to finance a national site system is
weak, due to their high costs.  In addition, since the financial
community grants loans primarily for the intermediate term, an
alternative means of refinancing would have to be planned from
the start.  However, an FNMA-type organization might either
guarantee a loan or buy an issue from an authority or political
subdivision and resell its own issue; this action, although not
now a practice of FNMA, would present an innovative financing
approach approximating a loan arrangement with a third party
financing partner  (i.e., the FNMA-type organization).  Lastly,
it is unclear whether the commercial banks would be interested
in granting loans to finance the system  (or some portion of it)
without a form of Government guarantee or tax-exempt feature
attached.  consequently, for the above reasons, it is doubtful
that a loan arrangement would be a realistic form for financing
this system.
                            A-758
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                       Lease Financing

Although true leasing is a high-cost way of financing, it may
be possible to employ leverage leasing to the extent that the
cost of capital would be reasonable or possibly even attractive.
The problem with leverage leasing  (and its modifications) is
that IRS rulings are needed to determine their tax status for
financing this system.  However, leverage leasing does appear
more feasible than loans, retained earnings, or public tax
sources.

                         Tax Credits

Since tax benefits can only assist the private corporation in
reducing the cost of developing the operating sites, they really
do not have the capability of supplying a complete financing
package.  However, tax benefits accruing to private corporations
interested in establishing sites may be sufficient to induce
sources of private capital to finance the system.

DEVELOPMENT OF NEW FINANCING MECHANISMS

Most new and innovative financing mechanisms are combinations
of previously existing mechanisms or features of the same re-
arranged to yield a better vehicle.  Some of the newly formed
mechanisms will require legislation to make them operational.
The basic factors which are manipulated to form financing
mechanisms for the system are tax exemptions and guarantees of
interest or coupon payments.

As an example, a security which reasonably may supply financing
for the system is an authority-issued bond with tax-exempt and
coupon-guarantee status; this issue would incorporate the high-
est degree of security for the investor while requiring enabling
legislation to attain the guarantee status.  Presently the
Department of Housing and Urban Development, through the Com-
munity Development Corporation, guarantees obligations of
private developers of new communities.  Under Title XI of the
Merchant Marine Act of 1936 the U.S. Government guarantees pay-
ment of interest and unpaid principal.  Furthermore, the payment
of principal and interest on Washington Metropolitan Area Transit
Authority bonds is guaranteed by the U.S. Government through the
Department of Transportation pursuant to Public Law 92-349.
Consequently, precedent for guarantees exists; however, these
issues do not have tax-exempt status.  An issue with both would
be attractive to the investment community.

Variations on the use of guarantees with limited partnership
interests, common stocks, or loans also present possible financ-
ing mechanisms.  For example, to use tax-exempt IRBs in
                            A-759
-------
conjunction with tax-exempt loans from commercial banks would
render residual financing attractive to speculators for equity
positions since the potential for loss would be small while
potential for gain might be very large.  If equity positions
are not offered, the portion of the financing supplied by tax-
exempt IRBs may have to be increased in order to elicit response
from commercial banks.  In either case no enabling legislation
would be required to accomplish this financing.

Financing the system in the holding company mode could entail
tax exemptions on operations for a stated period to elicit
private sector financing if public authority bonds are not avail-
able.  The tax exemption on operations would then be equivalent
to exchanging present outlays for future tax-free revenue streams
This arrangement may be very acceptable to a private corporation
with extraordinary earnings now and a need to use these effi-
ciently (i.e., to obtain tax shelters for their profits).  Tax-
exempt operating status would require enabling legislation.

Certainly the list of innovative financing mechanisms could be
extended.  However, the two basic factors, tax exemption and
interest and principal guarantees, form the cornerstone for
development of successful mechanisms to finance the system.  The
above are offered only as examples and are representative of a
much larger number of possible combinations of financial media,
some of which may require enabling legislation, others of which
can be used in their present forms but in different combinations.

SYSTEM CONFIGURATIONS

To correctly determine a reasonable financing mechanism or set
of mechanisms for funding development of the system, it is
necessary to develop the configuration of that system.  The
system in broadest terms can be envisioned over a wider range,
from a Government-owned and operated system to a free enter-
prise design, with other configurations falling between these
two extremes.

The system itself will require a certification or licensing
agency to see that safe and efficient operations are maintained.
In addition, some provision must be made for transportation of
wastes to the plant sites.  Consequently, the site system can
have many combinations and types of governmental and free
enterprise involvement, from operation to transportation to
perpetual care.

In one configuration the Government would totally own and oper-
ate the system.  Bonds issued by political subdivisions or the
Federal Government, Government loans and grants, as well as
tax revenues could be used separately or in concert to fund
                            A-760
-------
this system.  Legislation insuring that producers of waste
would use the facilities could be passed, thereby providing a
captive market for this service.

In free competition, private industry may be induced to estab-
lish plants across country by providing a ready market for the
plant's service.  To finance the system a combination of
authority-issued PCBs together with some retained-earnings
financing could provide sufficient impetus for the private
sector to enter and actively pursue this business.  Of course,
a regulatory body would maintain appropriate standards for
operation.  Questions of rate structures may initially be left
to the private sector with later imposition of a regulated rate
structure once equilibrium pricing is attained.

A Government-owned, contractor-operated  (GOCO) system patterned
after the structure of the munitions industry could also be
feasible.  Financing would be supplied by the public sector;
facilities would then be leased or contracted out to the pri-
vate sector.  Any number of working arrangements from fixed
fee to leasing could form the basis of a joint Government-
industry combination.

Another structure for the system could involve a utility con-
cept with one holding company and many operating companies.  In
this fashion, if one operating company in a certain geographic
region was profitable while another was unprofitable, the system
as a whole might be able to better service the public need.
This concept is analogous to a telephone company's structure.
Questions on profit limits and rate structure would be resolved
prior to issuing securities to finance such a system.  It would
be necessary to maintain monopolistic competition for the
holding company structure to work effectively.

Many other alternative configurations could be developed which
would directly affect the financing instruments employed, the
regulatory nature of the system, the monopoly conditions
established within the country, rate structures, forecasted
market size and penetration, degree of enforcement of legisla-
tion prohibiting illegal dumping of wastes, and other conditions.
These various system configurations must be considered before
financing mechanisms can be selected on any set of criteria.
                             A-761
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A-76.
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                          APPENDIX W


                          REFERENCES


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A-2.   Papers presented at Committee on Hazardous Materials'
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A-3.   Finney, D. J.  Profit analysis.  Cambridge University
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A-5.   McKee, J. E. and H. W. Wolf.  Water quality criteria.
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A-6.   Ibid.

A-7.   Water quality criteria data book.  Volume 1, Arthur D.
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A-8.   Personal communication, Ralph Wands, Director, Advisory
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A-9.   Data for preliminary demonstration phase of the Environ-
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A-13.  Personal communication, D. S. Trent, October 1972.

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                             A-765
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A-52.  Private communication from sales engineer, Process
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A-53.  Private communication from salesman, Hoffmann Container
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A-54.  Private communication from C. H. Bradshaw, 2040 Wilson
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A-55.  Catalogue quotation from salesman, Compac Specialties,
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                             A-767
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A-62.  Private communication from rate clerk, Associate Truck
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A-63.  Maxwell, T. L.  Estimated from Supplement No. 13 to PUCO
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A-64.  Private communication from freight rate clerk, Penn
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A-65.  Code of Federal Regulations 49CFR170.1 - Transportation
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