TD898
.H39
1987
H39                                      OOOR87002
                    THE HAZARDOUS
                     WASTE SYSTEM
                U.S. Environmental Protection Agency
                     Office of Solid Waste and
                       Emergency Response
                           June 1987
                                   U.S Environmental Protection Agency
                                   Region V, Library
                                   230 South Dearborn Street
                                   Chicago. Illinois  60604

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                               FOREWORD


This report provides an overview of hazardous waste management practices in the United
States.  The  primary  focus  is  on  hazardous  wastes  as  defined  in  the Resource
Conservation and Recovery Act  (RCRA)  and the Superfund program. In addition  to a
description of the current system, discussions are provided of the potential impacts of
current regulatory and other initiatives.

This is a summary report which draws from more detailed, ongoing investigations.  It is
anticipated that  the report  will be updated  periodically as  new information becomes
available.  It is also possible that the report may be expanded in the future to include more
discussion of related statutes and waste systems.

We hope  that this report, and its subsequent revisions,  will serve as a  focal  point for
discussions of future directions  in  the hazardous waste management area.  Comments on
the information presented herein will be very much appreciated.
                                                  A
                                                     Winston Porter
                                                  Assistant Administrator

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                       TABLE OF CONTENTS

                                                                     PAGE


EXECUTIVE SUMMARY 	 ES-1
         Hazardous Waste Managed	ES-1
         Treatment and Disposal   	ES-2
         Regulatory and Other Effects	ES-4
         Implications for the Future	ES-7


SECTION 1  HAZARDOUS WASTE MANAGED	 1-1
         Definitions of Hazardous Waste	1-1
         Large Quantity Generators  	1-3
         Small Quantity Generators	1-4
         Geographic Implications	1-5


SECTION 2  TREATMENT AND DISPOSAL	2-1
         Treatment Technologies	2-2
         Incineration Technologies	2-4
         Land Disposal Technologies  	2-5


SECTION 3  REGULATORY AND OTHER EFFECTS	3-1
         Land Disposal Restrictions and Technology Standards 	3-1
         Waste Minimization Policy  	3-3
         Deep-Well Injection Regulation 	3-4
         Domestic Sewage Sludge Regulation	3-4
         Ocean Incineration Regulation	3-6
         Corrective Action Policies  	3-6
         Superfund Off-Site Policy and Clean-Up Standards	3-7
         Redefinition of RCRA Hazardous  Waste	3-8


SECTION 4  IMPLICATIONS FOR THE FUTURE  	4-1
         More Incinerators Needed  	4-1
         More Information About On-Site  Activities	4-2
         Regional and Waste Specific Capacity	4-3
         Waste Minimization	4-6
         Siting and Permitting Issues	4-6

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                     TABLE OF CONTENTS
                             (continued)
                                                            PAGE
APPENDICES
        A. Operating Commercial Incinerator Facilities  	A-1
        B. Operating Commercial Land Disposal Facilities	B-1
        C. Commercial Deep-Well Injection Systems 	  C-1

BIBLIOGRAPHY
                                    111

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                                 EXHIBITS
                                                                      PAGE
Exhibit 1     Simplified Waste System Chart	 ES-3
Exhibit 2     Volumes of RCRA Hazardous Waste Treated and Disposed .... ES-4
Exhibit 3     Hazardous Waste Managed by Industry  	1-4
Exhibit 4     Hazardous Waste TSDRs and  Waste Volumes
             by Geographic Sector   	1-5
Exhibit 5     Number of Active Facilities by Type of Technology	2-1
Exhibit 6     Estimate of Physical Characteristics of RCRA Hazardous Wastes . 2-3
Exhibit 7     Treatment Technologies 	2-3
Exhibit 8     Incinerator Types and Incinerable Waste Descriptions	2-4
Exhibit 9     Number of Land Disposal Facilities by Type of Process 	2-6
Exhibit 10   Distribution of Municipal Sludge by Managment Practice	3-5
Exhibit 11    Regulations and Policies and Their Potential Effects
            on Capacity	3-9
Exhibit 12   Potential Capacity Problem  Areas	4-4
Exhibit 13   Land Disposal Facilities by Number, Volume, and
            Available Capacity 	4-5
                                          IV

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                        EXECUTIVE SUMMARY
The purpose of this report  is to  provide an overview of the country's hazardous waste
system.  Included are discussions of the sources and quantities of hazardous wastes; the
system for treatment, storage, and disposal (TSD) of these wastes; and  discussions of
upcoming regulatory and other impacts on the hazardous waste system.

Rather than looking at  hazardous waste issues from a single medium perspective, this
report examines hazardous  waste issues through an integrated framework  for addressing
environmental problems.  Several functions are to be served by this report.

      •   First, the report provides an overview of the hazardous waste system. It serves
          as a point of reference for continuing, more detailed work.

      •   Second, it serves as a  starting point for  the 20-year state capacity certification
          efforts required by the Superfund Amendments and Reauthorization Act of 1986
          (SARA).

      •   Third, the report provides an initial vehicle for discussion of possible impacts of
          the various EPA regulatory efforts underway with respect to hazardous waste
          control.

      •   Finally,  the question of whether there  is,  in fact, a  "capacity problem"  is
          addressed in  a very preliminary way.

Each section of  the report is shown below  and briefly  summarized  in  the  following
paragraphs. More detail is provided in subsequent report sections.
                               Hazardous Waste System
                                 Executive Summary
Hazardous Waste
Managed

Treatment and
Disposal

Regulatory and
Other Effects

Implications for
the Future
HAZARDOUS WASTE MANAGED

The  primary  focus of this  report is hazardous  waste as  defined  in  the  Resource
Conservation  and Recovery Act (RCRA)  and by the Superfund program.  However, the
hazardous waste  system  does not exist in isolation.   Before dealing with the specific
subject of hazardous wastes, it is useful to overview several key elements of the overall
waste system.
                                      ES-1

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Such an overview is provided  in Exhibit 1.  The point of this diagram is to  illustrate the
relationships  among  such  items  as  hazardous  wastes,  municipal  and  industrial
wastewaters, and non-hazardous solid wastes. It  will  be  increasingly  important  to
understand  "where  things  go" as  we deal  with hazardous and  solid  waste,  and
wastewaters.

It is also important to note that the overview in Exhibit 1 does not deal with every source or
possible exposure  route  of hazardous wastes or toxic  substances.   For example,
hazardous air emissions, pesticide applications, and many "non-point" waste sources are
not included in Exhibit 1.  These sources and others such as wastes discharged to surface
waters through a  National Pollutant Discharge Elimination System (NPDES) permit are not
discussed in detail in this report.

Now, let's return to RCRA and Superfund hazardous wastes, which are highlighted in the
bold portion of Exhibit 1. The hazardous wastes managed under RCRA totaled about 275
million metric tons  (MMT)  in  1985.   The overwhelming  majority of this,  well over  99
percent, was managed by "large quantity generators" (over 1,000 kilograms per month).

A number of factors could affect the volumes of wastes generated in  the future. Factors
such as economic and population growth, regulatory decisions, and  waste  minimization
efforts will influence the amount of waste produced.  As industrial production increases the
volume of industrial wastes produced could also increase. However, efforts to recycle and
reuse wastes, as well as programs to minimize the amount of waste generated are likely to
temper  increases in waste volumes.
TREATMENT AND DISPOSAL

Referring again to the bold print portion of Exhibit 1, let's now outline the treatment and
disposal part of the hazardous waste system.

First, it is important to note that about 96 percent of all RCRA hazardous waste is managed
on the sites of private companies,  the remaining 4 percent  goes to off-site commercial
treatment and disposal facilities. An approximate breakdown of the treatment and disposal
system follows.
                                         ES-2

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                                         Exhibit 1
                        Simplified Waste System  Chart
     GENERATION
    RCRA REGULATED
      DISCHARGERS

    - Large Quantity
    - Small Quantity
    OTHER INDUSTRIAL

    Direct Discharge of
    Wastewater

    Indirect Discharge of
    Wastewater
       MUNICIPAL
      WASTEWATER
 ^       LEAKING
     UNDERGROUND
     STORAGE TANKS
                                                                           DISPOSAL
                    TREATMENT
PRETREATMENT
                                Residuals
SOLID WASTE
- Municipal
- Industrial








Bold lines refer to RCRA and Superfund
'hazardous waste system.
                      INDUSTRIAL
                     WASTEWATER
                      TREATMENT
                              Sludge
                                              MUNICIPAL
                                            WASTEWATER
                                             TREATMENT
                                                      Sludge
                                              MUNICIPAL
                                            SOLID WASTE
                                            COMBUSTORS
                                            COMMERCIAL
                                            INCINERATORS
                                                  COMMERCIAL
                                                 LAND DISPOSAL
   ON-SITE
LAND DISPOSAL
                                      Ash
                                      Ash
                                              ON-SITE
                                            INCINERATORS
                                                           Ash
                                          OTHER TREATMENT

                                            - Commercial
                                            - On-Site
                                    Sludge
                                          SOLVENT & OTHER
                                             RECOVERY
                                             OPERATIONS
                                   Sludge
                      INDUSTRIAL
                    FURNACES OR
                       BOILERS
                                                           Ash
                                                   DEEP-WELL
                                                    INJECTION
                                                                       SURFACE WATERS/
                                                                            OCEAN
                                                    SUBTITLE D
                                                  LAND DISPOSAL
                                                   - Municipal
                                                   - Industrial
                                                 UNCONTROLLED
                                                     SITES
                                                  - Superfund
                                                  - RCRA-related
                                                  - Other
                                             ES-3

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                                     Exhibit 2
       Volumes of RCRA Hazardous Waste Treated and  Disposed
• -.;.;. \ ..... , ;:.. | ^ - -,.. •, .;_.-
Incineration
Other Treatment
Solvent & Other
Recovery
Furnaces & Boilers
Land Disposal
Deep-Well Injection
Total
• •• - 1 On-Site at
Private Firms
: :(MMT): L
1.7
204.0
*
*
8.0
*
Off^Site at .-;' .
Commercial Firms ">.?
.: ..(MMT).. ;- ;•{, .
0.4
1.6
*
*
5.0
*
/Estimated '$•'
•• :-. '•• Total •<• •.;•>
•;:l-:...flyTOv^:
2.1
205.6
57.0
0.9
13.0
-25.0
303.6**
Source: National Screening Survey, U.S. EPA, Office of Solid Waste (1986).
* Breakdown of on-site versus off-site waste volumes is not currently available.
** Total exceeds 275 MMT as deep-well injection, which is covered under the Safe Drinking Water Act, is Included.
MMT=million metric wet tons per year

The  above table relates to about 3,000 facilities which treat,  store,  or dispose of RCRA
hazardous waste.  There are currently  over 175  on-site incinerators and  14 commercial
incinerators. A list of commercial  incinerators is contained in Appendix A of this report. In
addition to incineration, there are  many other treatment  practices including biological
wastewater treatment, solidification,  steam stripping, and treatment impoundments.  Most
current treatment  systems consist  of  on-site  impoundments handling  relatively dilute
wastewaters. There are about 430  operating land disposal facilities, approximately 60 of
which are commercial facilities which accept a  wide range of wastes. Appendix B of this
report  contains a list of commercial operating  land disposal facilities.  Finally, while  the
majority of deep-well injection systems are  located on-site, a few commercial  facilities
also  use deep-well injection systems.  These facilities are identified in Appendix C of this
report.
REGULATORY AND OTHER EFFECTS

Due  to a  large number  of  new  statutory  and other requirements,  hazardous  waste
management must deal with a series of "moving targets".  Some of the more significant
ones are briefly outlined below.

Land Disposal  Restrictions and Technology Standards

The Hazardous  and Solid Waste Amendments of 1984 (HSWA) required that EPA ban the
land disposal of over 400 chemicals and waste streams unless the wastes are treated, or it
can  be demonstrated that there will  be "no  migration as long as the waste remains
hazardous."  The  solvents and dioxin portion  of the rules went into effect in November
1986.  Others will be promulgated over the next 2 to 3 years. The major impact of these
rules will be to significantly increase treatment required for many hazardous wastes.
                                         ES-4

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Waste Minimization Policy

EPA strongly favors preventing the generation of waste rather than controlling it after it is
generated. EPA's waste minimization program focuses on two main goals.  First, to foster
the use of waste minimization through technology and information exchange, and second,
to report to Congress in 1990 on the need for regulations on waste minimization.

According to a recent study conducted  by EPA, a 20-30 percent reduction in waste
volume  should be possible  through process changes, product substitution, recycling and
"good housekeeping" practices.  Concerns over economic and liability issues are already
driving firms  to reduce the volume  and toxicity of the  wastes they produce. Finally, a
number of states  have aggressive  waste  minimization  programs;  EPA will  attempt to
encourage and support such  programs.

Deep-Well Injection Regulation

In accordance with the Hazardous and Solid Waste Amendments EPA must also determine
whether to further restrict certain hazardous wastes  from deep-well  injection by August
1988. Currently, information is being collected to support the development of a regulatory
decision.

It is important to note that a large amount of dilute hazardous wastes (about 20-35 MMT
per year) is disposed of in this manner.  Deep-well injection is largely practiced in a few
Southwest and  Midwest states.  Thus,  a  significant  regional impact  could be felt if this
practice is inhibited.

Domestic Sewage Sludge Regulation

Under the  Clean Water Act, municipalities  are  required to treat  wastewater before
discharging it to surface waters.  This treatment process generates sludge which must be
used  or disposed of.  Very large amounts of non-hazardous sludge  are produced each
year.  The overwhelming majority of this sludge is landfilled and used  for land application.
A smaller amount (about 20 percent) is incinerated.

RCRA contains an exclusion for hazardous wastes which are mixed with domestic sewage.
EPA is developing information on the volume of hazardous waste being discharged to
sewers,  and is scheduled to  propose  regulations on  domestic  sewage  sludge  by
September 1987.

A major environmental  issue currently involves whether  domestic sewage sludge will be
considered hazardous  under EPA's new Toxicity  Characteristic Leaching  Procedure
(TCLP).  This could potentially bring large volumes of waste into the RCRA system.

Ocean Incineration Regulation

Regulations are currently being developed to  provide a framework for possible applications
for ocean incineration of hazardous waste. If and when successful applications are made
to ocean incinerate these wastes, such operations could provide additional capacity for
concentrated, liquid hazardous wastes.
                                         ES-5

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By  October 1987, EPA is  scheduled to  issue final regulations on designating  sites for
burning hazardous waste  at sea.   Final  regulations  on  ocean  incineration  will  be
promulgated in late 1988. The planned ocean incineration regulations apply exclusively to
liquid organic wastes and do not cover solid wastes.

Corrective Action Policies

Corrective action involves cleaning up RCRA facilities which have  been contaminated by
hazardous wastes releases.  This includes instances where past management practices
involved the disposal  of  hazardous wastes in  solid waste management units.  Leaking
underground storage tanks are another potentially large universe for corrective action.
Presently,  there  are about  one million underground  storage tanks,  approximately  5-20
percent of which may be leaking.

The volume of contaminated soils and sludges generated from corrective action cleanups
could be large.  While most  of the waste will likely be treated and disposed  of on-site,
some concentrated wastes  may require off-site handling. These wastes will compete for
existing commercial incineration and land disposal capacity.

Superfund Off-Site Policy and Clean-up Standards

Under the  Superfund  Amendments  and  Reauthorization Act of 1986 (SARA),  EPA is
required to establish standards for  Superfund clean-up  actions and also to identify the
conditions for  disposing of  Superfund wastes off-site.   The impact of these provisions
could change  the proportions of hazardous wastes managed on-site  and off-site.  For
example, the new clean-up standards could increase the use of  mobile treatment units
and stabilization  techniques to manage wastes on-site.  Some of the more concentrated
wastes will likely shift off-site for treatment and disposal.

Furthermore, the off-site disposal provision of SARA restricts where Superfund wastes can
be  taken.   Only  those  facilities  which are in compliance with  RCRA and the Toxic
Substances Control Act (TSCA) and applicable state requirements are eligible to accept
wastes from Superfund sites.  Specifically, the unit receiving Superfund wastes must not
be  releasing  any  hazardous wastes and the overall facility must  be controlled  by a
corrective action program.  Several Superfund sites have experienced  difficulties locating
a commercial  facility eligible to accept their wastes.

Redefinition of  RCRA Hazardous Waste

Currently  a waste is defined  as  hazardous  under  RCRA if  it possesses  certain
characteristics or is listed in Subpart D, Part 261 of the Code of Federal Regulations (40
CFR). About  half  of RCRA hazardous waste possesses one of the four  characteristic
attributes:  reactive, ignitable, corrosive, or EP toxic.  The other  half of the  wastes are
"listed"  hazardous wastes.

Under the current definition, RCRA regulates about 275  MMT of waste and about 3,000
facilities treat,  store or dispose of RCRA hazardous waste. EPA is  considering the use of
such  criteria  as  waste  concentration  and  management practices  in  potential  new
definitions  of hazardous wastes.  Changing such  criteria for defining a hazardous waste
could significantly affect the volume of waste currently regulated by RCRA and the size of
the  regulated community.
                                         ES-6

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IMPLICATIONS FOR THE FUTURE

It is highly likely that the hazardous waste system of tomorrow will be different than the one
of today.  Regulatory impacts,  costs of waste disposal, liability considerations, regional
capacity  constraints,  and  waste  minimization  efforts  are  already affecting  waste
management practices.

    As a result of the regulatory and other factors discussed above, a  number of general
observations about the waste management system become apparent.

      •   First, there will be increasing restrictions on land disposal without some type of
          treatment.

      •   Second, hazardous waste treatment and disposal will steadily increase in cost.

      •   Third, it will be  important  that  the impacts  of  new regulations are  carefully
          examined to ensure that additional problems  are not created.

Having made these observations, let's briefly look at the initial implications that can be
drawn from information provided in the report. These implications are intended to  serve as
a starting  point in identifying national priorities as well as focusing on issues of concern to
regions  and states.  The initial implications of the report are summarized below.

      •   First, more  facilities are needed to incinerate certain hazardous wastes.  This
          need is likely to  increase as SARA's  remedial action provisions and RCRA's
          corrective action  and land disposal restriction programs are  implemented.

      •   Second,  a better  understanding of  on-site hazardous waste management
          activities is  required.  With 96 percent of all RCRA hazardous wastes managed
          on-site, it is important to understand and  deal with likely industry responses to
          the various regulatory and other impacts.

      •   Third, waste management capacity  is  largely a regional and  waste specific
          issue. While there is generally adequate capacity to handle some wastes, such
          as most liquid organic wastes, there  is currently inadequate capacity to treat
          dioxin  and solvent contaminated soils  and certain  dilute wastewaters.  In
          addition, some states and regions have inadequate capacity and must ship their
          wastes to other areas of the country.  Since wastes can move freely in interstate
          commerce, it will be difficult to "tie down" specific capacity shortfalls.

      •   Fourth, EPA fully  supports the concept of waste minimization  through the use of
          technology  transfer,  recovery  and   recycling  operations,  waste  exchange
          programs,  and source  reduction techniques.  It  is far  better  to  reduce the
          generation of hazardous waste  than manage  waste after it is created.

      •   Finally, there is  a recognized need to  site and  permit  new hazardous  waste
          management facilities and to  expand existing  units. This is an important part of
          planning for the future.  The 20-year state capacity certification requirement in
          SARA is a major  step in  encouraging  states to develop new capacity.
                                         ES-7

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This report provides a "big picture" look at emerging hazardous waste issues.  It offers a
framework for strategic  planning at the national, regional, and  state level.  Furthermore,
Exhibit 1 provides a conceptual tool for qualitatively evaluating the interrelationships among
various parts of the waste system.  However, for assessing the needs for regional or waste
specific capacity,  more detailed information is required than is  presented in this report.

The information contained in this report is based on existing EPA surveys and studies as
well as in-person interviews with several major hazardous waste generators and treatment
and disposal facility operators.  Some data are better than  others, and not all data are
comparable.  At the conclusion of  several on-going EPA and  other studies, more detailed
information on hazardous waste  generation, treatment, and disposal will be available.
                                          ES-8

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                                 SECTION 1

                 HAZARDOUS WASTE MANAGED
                                  Hazardous Waste
                                     Managed
Definitions of
Hazardous Waste

Large Quantity
Generators

Small Quantity
Generators

Geographic
Implications
In 1985, about 275 million metric tons (MMT) of hazardous waste, as the term is currently
defined, were managed in RCRA regulated units.  In this section, the important issue of
hazardous waste definition is addressed. Also included in this section is a breakdown of
the sources, locations, and quantities of hazardous waste managed in the RCRA-regulated
system.


DEFINITIONS OF HAZARDOUS WASTE

Defining what constitutes a "hazardous waste" requires consideration of both legal and
scientific factors. The basic definitions used in this report are derived from: the Resource
Conservation and Recovery Act (RCRA) as amended by the Hazardous and Solid Waste
Amendments  (HSWA), and the Comprehensive Environmental Response, Compensation
and  Liability  Act  (CERCLA)  as  amended  by  the Superfund  Amendments  and
Reauthorization Act (SARA).

      •  Hazardous Waste refers to  "...a solid waste, or combination of solid wastes,
         which because of its quantity, concentration, or physical, chemical, or infectious
         characteristics may...pose  a hazard to human health or the environment..."
         [RCRA, Section 1004(5)].

      •  Solid  Waste means "any garbage, refuse,  sludge from a waste treatment plant,
         water  supply treatment plant, or air  pollution control facility and other discarded
         material,  including  solid,  liquid, semisolid,  or  contained  gaseous  material
         resulting from industrial, commercial, mining,  and agricultural operations and
         from community activities, but does not include  solid or dissolved material in
         domestic sewage..." [RCRA,  Section 1004(27)].

      •  Hazardous  Substance   means  "any  substances  designated  in  Section
         311(b)(2)(A) of the Federal Water Pollution Control Act...any hazardous waste
         having the characteristics identified  in Section 3001 of the Solid Waste Disposal
         Act...any toxic pollutant listed  under  Section 307(a) of  the  Federal Water
         Pollution Control Act, any hazardous air pollutant listed under Section 112 of the
         Clean  Air  Act,  and  any  imminently  hazardous  chemical  substance  or
         mixture...listed in Section 7  of the  Toxic Substances Control Act"  [CERCLA,
         Section 101(14)].

                                      1-1

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Under RCRA, a waste is considered hazardous if it is reactive, ignitable, corrosive or toxic
or if the waste is listed as a hazardous waste in Parts 261.31-33 of the Code of Federal
Regulations  (40CFR).  Currently, there are about 400 listed wastes.

In addition to hazardous wastes defined under RCRA, there are "hazardous substances"
defined  by Superfund.  Superfund's  definition of  a  hazardous substance is broad and
grows out of the statutory definitions in the Clean Water Act  (CWA), the Clean Air Act
(CAA), the  Toxic Substances Control Act (TSCA),  and RCRA.  Essentially, Superfund
considers a  hazardous substance to be any air or water pollutant defined as hazardous in
the CAA or the CWA or  as a hazardous waste defined in RCRA which exceeds reportable
quantity levels.  Accordingly, Superfund encompasses  numerous  wastes and chemical
substances:


      •  126 "priority pollutants" and 65 "toxic pollutants"  (CWA)

      •  16 "hazardous air pollutants" and 7 chemicals identified as "criteria pollutants"
         (CAA)

      •  95 chemicals  defined as toxic on the basis of  production volume, exposure and
         biological effects (TSCA)

      •  Substances identified or listed as hazardous waste under §3001 of RCRA
      •  CERCLA Contract Lab List

Both RCRA and Superfund wastes are discussed  in this report.  There are, however, other
hazardous wastes or toxic substances which are not specifically included.  Examples are:


      •  Wastes from non-point sources (e.g.,  storm  or irrigation run-off)

      •  Wastes that are exempt from RCRA management, such as wastewaters treated
         in  enclosed tanks and discharged subject  to NPDES permits

      •  Industrial wastewaters discharged to surface  waters under  NPDES permits or
         into underground  injection systems.

      •  Agriculture application of pesticides
      •  PCB wastes that are not contaminated with hazardous waste

Although these wastes are not regulated under RCRA or Superfund, they are covered by
other statutory  authorities such as the Clean Air Act,  the  Clean  Water Act, the Safe
Drinking Water Act, and the Toxic Substances Control Act.  The  various ways  in which
these acts interact with RCRA and Superfund are discussed  briefly below.

      •  The Clean Air Act (CAA),  under Section 112,  authorizes EPA to list various
         hazardous  air  pollutants.   Currently  included are  asbestos, beryllium, vinyl
         chloride, benzene, arsenic, radionuclides,  mercury, and coke oven emissions.
         The CAA also sets certain emission standards for many types  of air emission
         sources,  including  RCRA-regulated  incinerators  and  industrial  boilers  or
         furnaces.
                                       1-2

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      •  The  Clean Water Act (CWA) lists 126 priority pollutants to be regulated by
         effluent limitations over 21 primary industries.  The CWA priority pollutants are
         incorporated into  both RCRA  and CERCLA.  In  addition, the CWA regulates
         discharges from publically owned treatment works (POTWs) to surface waters,
         and indirect discharges to municipal wastewater treatment systems (through the
         pretreatment program).  Some  hazardous wastes  which would generally be
         considered RCRA regulated wastes are covered under the CWA because of the
         use of treatment tanks and  a National  Pollutant Discharge Elimination System
         (NPDES) permit to dispose of the wastewaters.

      •  The  Safe  Drinking Water  Act (SDWA)  regulates  underground  injection
         systems including deep-well injection systems.

      •  The  Toxic Substances Control  Act  (TSCA)  regulates the production and
         distribution  of  new chemicals  and  governs  the  manufacture,  processing,
         distribution, and use of existing chemicals.  Among the chemicals controlled by
         TSCA regulations are:  PCBs, chloroflurocarbons, and  asbestos.  In specific
         cases, there is an interface with RCRA regulations. For example, PCB disposal
         is generally regulated by TSCA.  However, hazardous wastes  mixed with PCBs
         are covered under RCRA.

This report focuses primarily on  RCRA regulated processes for treating  and  disposing of
hazardous waste (e.g., incineration,  impoundments,  chemical and biological treatment
technologies, and land disposal).  The report does not cover various exposure routes of
hazardous waste, such as  air emissions and discharges to surface waters and POTWs.
These are important considerations which  may be addressed  in subsequent updates of
this report.
LARGE QUANTITY GENERATORS

Once a RCRA hazardous waste is generated, it must be managed (i.e., stored, treated or
disposed)  in accordance with RCRA or  CWA requirements.  Currently, there are  about
3,000 facilities  managing 275 MMT of RCRA hazardous waste. Generators also produce
over 300 MMT of RCRA exempt waste which is regulated by the CWA.

The  overwhelming  majority of such hazardous  waste  is  produced  by  large  quantity
generators. Large quantity generators are defined as those firms which produce more than
1,000 kilograms of hazardous waste per month. These generators account for 99 percent
of the hazardous waste produced and managed under RCRA.

Furthermore, it is possible  to look at the industries that produce most of  the  hazardous
waste generated  each  year.  The  chemical,  petroleum,  metals,  and   transportation
industries  stand  out as major producers of hazardous  waste.   Exhibit 3 provides
information on the number of facilities, the volume of hazardous waste managed, and the
nature of waste handled by major industrial categories.
                                      1-3

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                                     Exhibit 3
                  Hazardous Waste Managed by Industry
INDUSTRY
Chemical
Fabricated
Metals
Electrical
Equipment
Petroleum
Refinery
Primary
Metals
Transportation
Equipment
National
Security
Other
Total
NUMBEKOF
FACILITIES
700
200
240
100
150
150
100
1360
3000
: AMOdNT WASTE-
MANAGED (MMT)
218
4
1
20
4
3
1
24
275
•- -.- • ••>•::•::••'•.•;;:; GENERAL
-• ./•• •'*•': ::-&4-WASTE
...: -.:•> : ::DE§PRIPTIQN
Contaminated wastewaters, spent
solvent residuals, still bottoms,
spent catalysts, treatment sludges,
and filter cakes.
Electroplating wastes, sludges
contaminated with metals and
cyanides, degreasing solvents
Degreasing solvents
Leaded tank bottoms, slop oil
emulsion solids, API separator
sludge, DAF float.
Pickle liquor, sludge with metal
contaminates
Degreasing solvents, metals, sludges
All types of wastes
All types of wastes
   Source: National Screening Survey of Hazardous Waste Treatment, Storage, Disposal and Recycling Facilities,
         U.S. EPA, Office of Solid Waste, Office of Policy, Planning and Information, 1986.


SMALL QUANTITY GENERATORS

A much smaller  amount of waste, about one million tons per year, is generated by small
quantity generators. These firms generate between  100-1,000 kilograms of  hazardous
waste per month.  The  majority of the  100,000 small quantity generators  are automotive
repair firms, construction firms, laundromats and dry  cleaners,  photographic processors,
equipment repair shops, laboratories, electroplaters and schools.

Prior to their  being regulated  in 1984, small quantity  generators  legally  disposed of
hazardous waste outside of RCRA regulated facilities. Today,  small quantity generators
must treat or dispose of their waste in accordance with RCRA's regulations (Subtitle C).
Most small quantity generators do not manage their own waste but rely  on  the services of
a commercial  facility.

The  wastes produced  by small quantity  generators span the full  spectrum  of RCRA
hazardous  wastes.  According  to  EPA's  "National  Small Quantity  Hazardous  Waste
Generator Survey," over 60 percent of small quantity generator waste is derived  from lead
acid batteries.   The remainder includes acids,  solvents,  photographic wastes, and dry
cleaning  residues.
                                        1-4

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Small quantity generator industries are widely dispersed across the country.  Frequently,
geographic pockets of small quantity generators representing a collection of industries are
concentrated in a few city blocks.   While  each firm individually  generates only a small
volume of waste, collectively these  firms may constitute "hot  spots" of hazardous waste
generation. The combined industrial discharge from small firms can potentially upset the
chemical or biological treatment processes at publicly owned  treatment works (POTWs).
While small quantity generators produce only a small volume of waste, their waste is
hazardous and must be handled to  protect human  health and the environment.
GEOGRAPHIC IMPLICATIONS

Next,  a look at where hazardous wastes are managed. While most hazardous waste is
treated and disposed at the site where it is produced, some hazardous wastes must be
transported hundreds of miles to  an incinerator or secure landfill.   Because waste is
shipped interstate,  it is important to understand where waste is  produced in  relation to
where it is treated and  disposed.   For example, some states are net importers  of
hazardous waste (e.g.,  Alabama) while other states (e.g., New England states) are net
exporters of hazardous  waste.

As might be expected, the large majority of hazardous waste is managed in the more
highly industrialized areas of the country —  particularly those areas with active chemical
and petroleum  industries.   An approximate geographic  breakdown  by the number  of
Treatment, Storage, Disposal and Recycling (TSDR) facilities,  and the volumes of waste
managed is provided in Exhibit 4.
                                    Exhibit 4
               Hazardous Waste TSDRs and Waste Volumes
                             by Geographic Sector
'GEOGRAPHIC •: j
: SECTQ& ' •- •-••"•:
Northeast
Southeast
Southwest
Mid-West
Rocky Mountains
Far West
Total

830
440
390
910
90
340
3,000
f flUANTITY'bF RCRA v
WASTE jy)ANfAGEp(wiyiT)
63
84
58
64
1
5
275
  Source: National Screening Survey, U.S. EPA, Office of Solid Waste, 1986, and EPA's Hazardous Waste Data
        Management System.
                                       1-5

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                                   SECTION 2

                     TREATMENT AND DISPOSAL
                                 Treatment and Disposal
                        Treatment
                        Technologies
 Incineration
Technologies
Land Disposal
Technologies
  The Hazardous Waste System includes about 3,000 facilities that treat, store, or dispose of
  RCRA hazardous waste (see Exhibit 5).  In this section the types of treatment  typically
  used  are discussed,  with  particular emphasis  on  incineration  and  land  disposal
  technologies.
3,000
                                     Exhibit 5
              Number of Active Facilities by Type of Technology
2,000-
1,000-
    0
             1,596
                               2,585
                     TOTAL NUMBER OF
                  FACILITIES IN 1985 = 2959

                         All Facilities
                         Commercial Facilities
                                                                   846
                                                 433
              Treatment         Storage        Land Disposal       Recycling
     Source; National Screening Survey, U.S. EPA, Office of Solid Waste, 7986.

      Note: Some facilities have more than one  process.
                                       2-1

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Because of economic factors and liability concerns, many firms prefer to store, treat, and
dispose of hazardous waste on-site.  About 96 percent of all  RCRA hazardous waste is
managed on-site.  The remaining waste is taken off-site to commercial facilities, which
are in the business of managing other firms'  waste.  In addition, significant amounts of
industrial wastes are exempt from RCRA regulations  but covered under the Clean Water
Act.  These wastes are typically treated and then discharged to surface waters under an
NPDES  permit.  This  section is, however,  restricted  to  the  treatment and disposal
practices used to manage various types of RCRA hazardous waste.


TREATMENT TECHNOLOGIES

In the Hazardous and Solid Waste Amendments of 1984 (HSWA), treatment technologies
are favored over disposal of certain wastes. Treatment refers to any process, including
neutralization, designed to  change the character of hazardous waste in order to render it
less hazardous.  Typical treatment methods include incineration,  biological and chemical
wastewater treatment, steam stripping, and solidification.

The vast majority of the 275 MMT of hazardous waste managed  annually is  treated in
impoundments and wastewater treatment plants.  A very small  amount of waste, about 2
MMT, is  presently incinerated. However, the volume of waste incinerated may increase
significantly in response to  HSWA requirements.   Although most  treatment processes
reduce the volume or toxicity of waste, there is often a residual that must be further treated
or disposed.  A waste stream may go  through more than one treatment process to reduce
its toxicity or volume.  The most widely  used treatment technologies are briefly described
below.

      •   Incineration  is used  to  burn primarily  liquid  organic hazardous waste.   In
          addition, some incinerators  are designed to burn solids and sludges as well as
          liquid wastes.   Increasingly,  regulatory  decisions  favor such practices as
          incineration over land disposal of certain wastes.
      •   Biological  and  Chemical  Wastewater  Treatment  is  the most widely used
          method of treating aqueous hazardous waste.  Wastewaters are rendered less
          hazardous by biological decomposition, chemical neutralization, or precipitation.
          Treatment occurs in large settling ponds,  covered  tanks, or impoundments.
          Retention time in the treatment units varies from a few hours to several days
          depending on temperatures and the types of waste streams.  A residual  sludge
          is produced in the treatment process which is generally incinerated,  treated or
          land disposed.
      •   Steam  Stripping  technologies  are used in  treating  aqueous,  hazardous
          wastewaters.  Hazardous constituents in the water are converted into gas by
          means of physical treatment.  A  non-hazardous gas  is  then emitted into  the air
          and the hazardous constituents are  captured  through  air  pollution control
          equipment.

      •   Solidification involves mixing a stabilizing agent with hazardous waste to  create
          a  solid  or impermeable material.  The technology  requires  a large area to
          combine the stabilizing  agent (e.g., Portland cement) with hazardous  waste.
          Solidification is most effectively used on  inorganic sludges.
                                       2-2

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                                   Exhibit 6
    Estimate of Physical Characteristics of RCRA Hazardous Wastes
                                                            Organic Sludges (2 MMT)
                                                                 Organic Liquids
                                                                 (4 MMT)
                                                                  Inorganic Solids
                                                                  (2 MMT)
                                                                   Inorganic Sludges
                                                                   (15 MMT)
    Inorganic Liquids
    (252 MMT)
 Source: National Screening Survey, U.S. EPA (1986)
 An important element in knowing what treatment and disposal practices can be used to
 manage waste is understanding the physical characteristics of waste.  For each type of
 waste,  there  are  appropriate  treatment  and  disposal  technologies. The  physical
 characteristics of the 275 MMT of RCRA hazardous waste managed in 1985 vary from
 dilute wastewater to metal bearing  sludges to PCB contaminated soils.  Over 90 percent
 (by weight) of RCRA hazardous waste is in the form of wastewater. The  remaining wastes
 are organic and inorganic sludges and organic and inorganic solids. Exhibit 6 categorizes
 hazardous waste by physical characteristics.

 As illustrated in Exhibit 7 below, for each type of waste there are one or  more appropriate
 treatment and disposal technologies. The vast majority of hazardous waste  is inorganic
 liquid  waste  which is generally treated in  wastewater treatment  plants or treatment
 impoundments and then discharged to  surface waters subject  to effluent limitations in
 NPDES permits.  A residual sludge is also  produced in the treatment  process which is
 generally treated, stabilized and then land disposed.


                                    Exhibit 7
                           Treatment Technologies
PHYSICAL -
CHARACTERISTICS
Organic Liquids (4 MMT)
Inorganic Liquids (252 MMT)
Organic Sludges (2 MMT)
Inorganic Sludges (15 MMT)
Inorganic Solids (2 MMT)
• Widely Used
o Sometimes Used
INCINERATION
•
o
O
O
0

WASTEWATER
; TREATMENT
O
•
0
O


TREATMENT
IMPOUNDMENTS
O
•
O
o


SOL1DSRCAT10N

O
O
•
O

! 	 STEAM 	
; STRIPPING

O




Source:  EPA, Office of  Solid Waste
                                       2-3

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The volume of incinerated hazardous waste is small and composed mainly of  organic
liquids and sludges.  There is a potential, however, for other types of wastes to require
incineration as a result of upcoming regulatory and policy actions. These additional wastes
could include more sludges and solids.

Because of the strong interest in the incineration of additional wastes and the restriction on
land disposal of certain chemicals, these two technologies are discussed in more detail in
the remainder of this section.
INCINERATION TECHNOLOGIES

This section focuses on the growing importance of incineration in treating wastes and the
types of incinerators operating today.  Incinerable wastes range from highly concentrated,
organic liquids to sludges and low concentration, but hazardous,  solid wastes.   However,
wastes  with  low  levels of  metals  and  high  organic content  burn most efficiently.
Incineration will be used for a specific waste if  it  is the most efficient and economically
feasible treatment technology.

Exhibit 6,  Estimate of Physical Characteristics of RCRA Hazardous Wastes, serves as a
guide for  identifying general  categories of waste suitable  for incineration.  Incinerable
wastes include the following.

      •   Organic  Sludges                      2 MMT
      •   Organic  Liquids                       4 MMT
      •   Inorganic Sludges, Liquids, and Solids   Unknown

The  above wastes are burned  in  incinerators specifically designed and  permitted to
destroy a  limited range  of wastes.  Organic liquid waste, for example, can be burned in
liquid injection incinerators, rotary kilns, cement kilns, or used as fuel for industrial boilers
and  furnaces.   Exhibit  8  shows  the  four major  types of  incinerators,  the number of
incinerators in each category and the kinds of waste capable of being incinerated by a
specific incinerator design category.
                                    Exhibit 8
          Incinerator Types and Incinerable Waste  Descriptions

: INCINERATOR
JDESIGN
Rotary Kiln
Liquid Injection
Fume
Open Hearth
Total

ESTIMATED
NUMBER
OF UNITS
40
95
25
30
190

; WASTE DESCRIPTIONS ^
Liquid sludges, solids, drummed wastes
Pumpable hazardous wastes, no solids
Liquids
Liquids, sludges, and some solids

       Source;  EPA, Office of Solid Waste
                                       2-4

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Most of the RCRA hazardous waste incinerators operating today are located on-site. There
are over  175 on-site incinerators that burn 1.7 MMT of hazardous waste.  In contrast, the
commercial sector has 14 incinerators and burns 0.4 MMT of hazardous waste each year.
These  units are required to meet air emission and performance standards. An incinerator
permit  restricts the type of wastes that can be burned in a specific unit.  See Appendix A
for a list  of commercial incinerators.

It appears that commercial incinerators are operating at or near capacity. In response to
the potential increase in  demand to burn solids  and  sludges caused  by Superfund
cleanups and RCRA corrective action, industry is looking into the siting of new incinerators
and the  expansion  of existing  incinerator capacity. Section 4  of this  report examines
incineration capacity in more detail.


LAND DISPOSAL TECHNOLOGIES

Having discussed the major forms of treatment technologies for hazardous waste,  let's
now turn to land disposal technologies.  Historically,  many hazardous wastes were  land
disposed because  landfilling was an economical and available means to  dispose of
wastes. When the land disposal restrictions imposed by HSWA become effective, the land
disposal of certain wastes will be prohibited.  Only wastes that meet specific standards or
are treated to meet  these standards will  be allowed to be disposed on  the land.

A small percentage of the 275 MMT of hazardous waste  generated each year is  land
disposed in landfills,  land farms, or disposal  surface impoundments.  Land disposal is the
depositing or injecting of  solid or hazardous wastes on or into the land. Currently, there are
about 430 operating  land disposal facilities. The various kinds of land disposal facilities are
briefly described below:

       •  Landfills are generally below ground, rectangular pits.  A  permitted hazardous
         waste  landfill  must be lined  with synthetic materials and  have a leachate
         collection   system to  prevent  groundwater contamination.    Most residuals
         generated in treatment processes,  such as incinerator ash  or impoundment
         sludge, are ultimately landfilled.   Landfills range in size from a few acres to
         hundreds  of acres.  Currently there  are about 100 hazardous  waste landfills in
         the country, 33 of which are commercial landfills.
      •  Land treatment involves spreading hazardous waste  on  the land or  placing
         waste  in a shallow pit and using  biological decomposition to treat the waste.
         Land treatment, particularly the form of treatment  referred to as land farming, is
         most often  used to dispose organic solids and sludges, such as the waste
         by-products of the petroleum industry.
      •  Deep-Well  Injection  Systems are  primarily  used to dispose of aqueous
         hazardous waste. Approximately 20-35  MMT   of  dilute,  hazardous waste is
         disposed  annually into deep-well  injection systems. This represents about 10
         percent (by weight) of all RCRA hazardous waste managed in the country.

     •  Surface Impoundments vary in size from a few hundred square feet to hundreds
         of acres. They are currently used to treat, store, and dispose of large quantities
         of aqueous wastes.  As much as 100 MMT of RCRA hazardous waste may be
         treated and disposed of in impoundments. This practice handles a large amount
         of the wastes currently managed under RCRA.

                                       2-5

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As shown in Exhibit 9,  most land disposal facilities are impoundments located on-site at
the plant.  In  comparison, about 60 commercial facilities have  land disposal  units and
manage  5 MMT of hazardous waste. These units include:  landfills, impoundments, land
treatment, and waste piles.   A list of the commercial land disposal units is provided in
Appendix B.

The nature of the  wastes managed at commercial facilities may be vastly different from
that of on-site wastes.  Representatives from the commercial waste management industry
indicate that they are now receiving more concentrated wastes than in the past. This is
because firms are reusing waste and sending less aqueous waste off-site.  This trend is
likely to continue in the future as firms minimize the volume of waste they generate.
                                    Exhibit 9
         Number of Land Disposal Facilities by Type of Process
              TOTAL NUMBER OF
              FACILITIES = 433
                 All Facilities

                 Commercial Facilities
         Deep Well   Disposal    Landfill      Land      Waste    Storage     Treatment
          Injection  Impoundment          Treatment     Pile  Impoundment Impoundment

     Note: Some facilities have more than one process.
     Source: National Screening Survey, U.S. EPA, Office of Solid Waste (1986).
                                        2-6

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                                  SECTION 3

             REGULATORY AND  OTHER  EFFECTS
                              Regulatory and Other Effects
                         T
          Land
         Disposal
        Restrictions
          and
        Technology
        Standards
  Waste
Minimization
  Policy
       Corrective
         Action
        Policies
  Domestic
Sewage Sludge
  Regulation
  Ocean
Incineration
Regulation
                                                        Redefinition
                                                         of RCRA
                                                        Hazardous
                                                          Waste
There are a number of  on-going  regulatory and other activities  which  will substantially
affect the hazardous waste system in the country.  Many of these were mandated by the
1984 Hazardous and Solid Waste Amendments (HSWA). Another key factor, of course, is
the Superfund cleanups being conducted under  the Superfund program.

These regulatory and other activities are in very  different stages of development and their
potential impacts, therefore, can only be  estimated.  This section attempts to outline the
issues expected  to be presented by these activities in order to provide  a framework for
future planning.
LAND DISPOSAL RESTRICTIONS AND TECHNOLOGY STANDARDS

Since 1984,  the number of operating land disposal facilities has decreased from 1500 to
less than 500 today.  Under the Hazardous  and Solid Waste Amendments firms were
required to meet certain financial tests, comply with groundwater monitoring and minimum
technology  standards.   Many  facilities chose to  close rather  than  meet the  above
standards.  It is believed that many of these facilities were at or near capacity and many
others  were  small units.  Consequently,  the closing  of these  facilities is unlikely to
significantly decrease land disposal capacity.  In 1985, EPA estimated that  commercial
landfills had  about 10-15 years of useful life remaining.

The Hazardous and Solid  Waste Amendments prohibit the land disposal  of  certain
hazardous wastes unless the wastes  are treated or it can be demonstrated that there will
be  "no migration as long as the waste remains hazardous." Also prohibited from land
disposal are bulk or non-containerized liquid hazardous wastes, certain dioxin-containing
hazardous wastes, and  some  solvent wastes.  By 1990, EPA will publish regulations
implementing land disposal restrictions for all RCRA wastes.  Land disposal of wastes will
be  prohibited unless the Agency  specifies methods  that are protective   as long as the
waste remains hazardous.
                                      3-1

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•Chemicals
Solvents
California List
First 1/3
Second 1/3
Third 1/3
Effective Date of Ban
November 8, 1986
July 8, 1987
August 8, 1988
June 8, 1989
July 8, 1990
On November 7,  1986,  EPA  promulgated  its first regulations implementing the Land
Disposal Restrictions for solvent and dioxin bearing wastes.  The Agency found there was
insufficient capacity nationwide to treat dioxin  and solvent contaminated soils and dilute
wastewaters contaminated with solvents.  Consequently, extensions were  granted for
these wastes.  However,  sufficient capacity was found to treat liquid solvent wastes.  An
exclusion was  not granted for these wastes.

HSWA's minimum technology standards also require improving the ways existing and new
landfills  and surface impoundments are constructed.  These standards include:  installing
two or more liners, a leachate  collection system, and a  groundwater monitoring system.

As a  result of  HSWA's requirements,  it appears that many surface impoundments may
close rather that retrofit existing impoundments.  About 100 MMT of hazardous wastewater
is managed in surface  impoundments.  Much of these wastes may shift to treatment tanks.
The sludge from the treatment tanks would be subject to RCRA if it is listed as a hazardous
waste or exhibits a characteristic.  The wastewater treatment tanks  would be exempt from
RCRA regulations if the treated wastewater were discharged  under NPDES permits into
surface  waters or under the  National Pretreatment Program to publicly owned treatment
works (POTWs).  In either case, the  discharge would be subject to the Clean Water Act.
These new discharges could  have a  significant permitting impact on the Clean Water Act
permitting and  pretreatment programs.

Sludges resulting from  the above treatment tanks, and subject to RCRA, would be subject
to the HSWA land disposal restrictions.  Such  sludges could require incineration or other
treatment.   Currently,  there  are  14  commercial incinerator facilities,  over 175 on-site
incinerators, and about 30 new incinerators under consideration.
                                       3-2

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WASTE MINIMIZATION POLICY

EPA strongly favors preventing the generation of waste rather than controlling waste after it
is generated.  It is a national policy that the generation of hazardous waste be reduced as
expeditiously as  possible.

Within the private  sector,  strong incentives already exist to promote waste minimization.
These incentives include:

       •   Large  increases in the price of treating and disposing of hazardous wastes
       •   Difficulties in siting  and permitting new hazardous waste units
       •   Concern with liability associated with managing hazardous waste
       •   Public  pressure  on industry  to reduce waste generation

According to a  recent EPA study,  "Waste Minimization Issues and Options", a 20-30
percent reduction  in waste volume  may be possible through  process  changes,  product
substitution,  and  "good housekeeping" practices.   Many firms have  already and are
continuing to reduce the amount of hazardous waste produced through a variety of waste
minimization techniques including:

       •   Source Reduction
       •   Waste Separation  and Concentration
       •   Waste Exchange
       •   Reuse and Recycling Waste

At present,  there  are three  statutory  requirements relating to waste minimization,  all  of
them enacted in the 1984 Hazardous  and Solid Waste  Amendments.  The  requirements
are summarized  below.

       •   Generators must certify on their manifests that they  have a program in place  to
          reduce the volume and toxicity of waste (Section 3002(b)).

       •   Any new treatment,  storage  or  disposal  permit  must  include  a  waste
          minimization  certification  statement (Section 3005(h)).

       •   As part  of the generator's biennial report, generators must describe the efforts
          undertaken  during the year  to  reduce  the volume  and  toxicity  of waste
          generated (Section 3002(a)(b)) and  document actual reduction achieved.

EPA's waste minimization  program  has two main objectives.  First, to  foster the use  of
waste minimization through  technology  and information dissemination, and second,  to
report to Congress by  1990  on the  need for regulations on waste minimization.

In conclusion, concern  over economic and liability issues are driving generators to reduce
the volume and toxicity of hazardous waste produced.  Waste minimization  can alleviate
the capacity problem by reducing the  volume  of  waste  requiring treatment and disposal.
                                       3-3

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DEEP-WELL INJECTION REGULATION

Over 300 MMT of aqueous waste are deep-well injected each year. About 20 to 35 MMT
of this waste could be RCRA hazardous wastes.

The majority of  deep-wells are located on-site and wastes are disposed of at the plant
where they are  generated.  A small  number of  commercial firms  operate  deep-well
systems (refer to Appendix C for a list of deep-well injection systems).  Most deep-well
systems are concentrated along the Gulf Coast of Texas and Louisiana,  and in  Illinois,
Ohio, and Indiana.

The Hazardous  and Solid  Waste Amendments (HSWA) require that  EPA determine by
August 8,  1988  whether to further  restrict hazardous wastes from deep-well injection.  If
deep-well injection were prohibited, most of these wastes would probably be redirected to
surface waters.  Firms could obtain or modify their National Pollutant Discharge Elimination
System (NPDES) permit in order to discharge treated wastes from a wastewater treatment
plant to surface waters.  Some of these wastes  may also be sent to publicly  owned
treatment works  (POTWs) and then discharged into surface waters.  It is likely that most
firms would continue to treat their waste on-site rather than ship large volumes of dilute,
aqueous waste  to a commercial facility.

The  Agency  is  presently collecting information on the  volumes  and  types of waste
disposed of through deep-well injection.  It is important  to know the amount of waste
disposed and where waste will shift if this form of disposal is restricted.  Those firms which
currently  use on-site,  deep-well  injection  systems probably  would  need to construct
wastewater treatment plants to treat their waste.

In summary,  large volumes  of  RCRA  hazardous and  non-hazardous wastewaters are
currently  discharged  into deep-well injection systems.    Making  deep-well injection
regulations more stringent will affect biological and chemical treatment capacity.  There is
likely to be minimal impact on incineration capacity  because it is usually not economically
feasible to incinerate  dilute, aqueous wastes.
DOMESTIC SEWAGE SLUDGE REGULATION

The Clean Water Act requires municipalities to treat wastewater before discharging it to
surface waters. In 1984, approximately 32 billion metric tons of municipal wastewater was
discharged to  publicly  owned  treatment  works  (POTWs).   The treatment process
generates a sludge which must be used or disposed of.

The quantity  of  municipal sludge produced  annually has almost doubled  since  1972.
Municipalities  now generate about 7.6 million dry metric tons of wastewater sludge a year,
the majority of which is landfilled and used for land application.  Exhibit 10 illustrates the
proportions of sludge managed by type of practice.
                                       3-4

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                                    Exhibit 10
        Distribution of Municipal Sludge by Management Practice


                                                 Other

                                                    Ocean Disposal
                 Distribution &
                 Marketing
                                                 Incineration
                             Land Applications
Municipal sludge production is expected to double to 12 million dry metric tons by the year
2000 as the population increases, as more  municipalities comply with Clean Water Act
requirements, and as more sophisticated wastewater treatment systems are installed.

EPA's technical regulations for reuse and disposal of sewage sludge will set concentration
limits for a variety of metals and organics found in municipal sludge.  These limits will vary
by management practice.

RCRA contains an exclusion for hazardous wastes which are mixed with domestic sewage.
The exclusion  allows industries connected to POTWs to discharge hazardous wastes to
sewers containing  domestic  sewage  without having to  comply with  RCRA  manifest or
reporting requirements.  These industrial wastewaters would be regulated under the Clean
Water Act's pretreatment  program.   Furthermore,  RCRA hazardous  wastes  brought to
wastewater treatment plants directly through a non-domestic sewage pipeline or by rail or
truck  is not covered  by the exclusion and must  meet RCRA manifest  and reporting
requirements.  EPA is scheduled to propose regulations  on domestic  sewage sludge by
September 1987.

EPA is developing information on the volume of RCRA hazardous waste being discharged
to sewers.  When the pretreatment  program is  implemented  fully, the wastewaters
discharged into sewers will be cleaner, resulting in a potential increase in industrial sludge
that may require additional treatment and disposal,

A  major  environmental  issue  involves the application of  the  Toxicity  Concentration
Leaching Procedure (TCLP)  test to domestic sludges.  If the sludges  fail the TCLP test,
they  would be  managed as a RCRA  hazardous waste.  It is  uncertain  whether most
domestic sludges will pass or fail the test.  If most municipal sludges fail, large volumes of
waste could be brought into the  RCRA system.
                                       3-5

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OCEAN INCINERATION REGULATION

EPA has proposed regulations that would allow certain hazardous wastes to be burned at
sea.  By October 1987, EPA is scheduled to issue final regulations on designating sites for
burning  hazardous waste  at sea.   Final  regulations on  ocean  incineration  will  be
promulgated in late 1988.  These ocean incineration regulations will apply exclusively to
liquid organic wastes and exclude solid  wastes.

About 4 MMT of liquid  organic hazardous wastes are  managed annually.   Approximately
1.7 MMT of these wastes is burned in on-site hazardous waste incinerators and 0.4 MMT
is incinerated  at commercial hazardous wastes facilities.  The  remainder  is recycled  or
used as fuel. Demand for hazardous waste incineration capacity could change based on
the following circumstances.

       •  The land disposal restrictions may divert liquid incinerable wastes currently land
          disposed to incineration.

       •  A small amount of wastes presently burned in boilers could shift to incineration.
       •  The Deep-Well  Injection regulations  now  being  developed could  shift some
          concentrated wastes currently deep-well injected to incineration.

       •  Increased Superfund and RCRA cleanup activities could increase the volume of
          hazardous wastes that require incineration.  Most of these wastes are likely to
          be contaminated  soils and sludges. It is difficult to estimate the extent to which
          the RCRA corrective action program and Superfund's selection of remedy policy
          will change the demand for incineration capacity.

The extent to which ocean incineration  is used will depend upon need,  cost and risk
considerations.  The availability  and cost of land based incineration units will affect
demand for ocean incineration. Other major factors affecting ocean incineration  are the
ability  to designate sites, to obtain permits for  portside support facilities,  and to permit
ocean incinerator ships.  Additionally, the cost of transporting and incinerating wastes in
land based versus ocean incinerators would affect utilization rates for each technology.
Finally, managing risk to satisfy the public is an issue which affects  both land and sea
incineration of hazardous wastes.
CORRECTIVE ACTION POLICIES

Corrective action involves cleaning up soils,  sludges and groundwater contaminated with
hazardous wastes at  hundreds of RCRA facilities.  Corrective actions may be required
where hazardous waste releases have  occurred at hazardous waste treatment, storage,
and  disposal facilities (TSDs)  and  solid waste  management  units  (SWMUs).   Early
estimates suggest there are about 7 SWMUs per TSD facility. Corrective action may be
required  at many of these facilities.

Leaking  underground  storage  tanks  represent another  potentially  large  universe  for
corrective action projects.  There are  approximately one  million  underground storage
tanks, approximately 5-20 percent may be leaking.
                                        3-6

-------
The volume of waste that will be generated from corrective action projects could be large.
Although most waste probably will be treated on-site, some concentrated wastes may
require  off-site treatment.   These wastes  will  likely compete for  existing  commercial
treatment and land disposal capacity.
SUPERFUND OFF-SITE POLICY AND CLEAN-UP STANDARDS

The  Superfund Amendments and Reauthorization Act (SARA) establishes standards for
Superfund clean-up actions and also stipulates the conditions for disposing of Superfund
wastes off-site.   These  provisions  could  change the proportions  of hazardous waste
managed on-site and off-site.

The  new clean-up standards provided for in SARA require that Superfund remedies must
be protective of human health and the environment, cost-effective,  and utilize permanent
solutions, alternative treatment technologies and resource recovery to the maximum extent
practicable.  The on-site remedies must also meet applicable or relevant and appropriate
regulations  (ARARs) of other federal statutes including: RCRA, TSCA,  SDWA, CAA, and
CWA.  And, where  state standards are more stringent  than federal standards,  state
standards must be met.  For wastes  remaining on-site, the remedial actions are reviewed
every 5 years.

The  new clean-up standards are expected to increase the use of mobile treatment units
and  stabilization techniques to  manage  waste on-site.   However, some concentrated
hazardous wastes will likely require off-site treatment and  disposal.  This could increase
the demand for commercial capacity.

The  off-site disposal provision in SARA restricts disposal  of Superfund wastes to those
facilities  in  compliance  with  RCRA  and  TSCA and  applicable  state  requirements.
Specifically,  the  unit  receiving  Superfund  wastes must not be releasing  any hazardous
wastes and  releases from other units at the facility must be controlled  by a corrective
action  program.   Several Superfund  sites  have experienced  difficulties  locating  a
commercial facility eligible to accept their waste.

Currently, 4  percent of all hazardous waste is managed off-site by commercial facilities.
The  amount of waste taken off-site  could increase substantially in the near-term.  This
increase  is partially attributed to the new clean-up standards and  the off-site disposal
provision of  SARA.   This  could stress  the nation's commercial  capacity to  handle
Superfund contaminated soils and sludges.
                                       3-7

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REDEFINITION OF RCRA HAZARDOUS WASTE

EPA is considering  whether  to  revise  the  current  defintion  of  "hazardous"  waste.
Presently,  a waste  is  defined as  hazardous  under RCRA if  it possesses  certain
characteristics or is listed in Subpart D ,  Part  261 of  the  Code of Federal Regulations
(40 CFR).   About half of RCRA hazardous waste possesses one of four characteristic
attributes:  reactivity, ignitability, corrosivity, or EP toxicity. The other half of the wastes are
"listed" hazardous wastes. There are now over 400 listed hazardous wastes.

Approximately 275 MMT  of RCRA hazardous  waste are generated by 40,000 to 60,000
large quantity generators and about 100,000 small quantity generators. Changing the
criteria for defining a hazardous  waste could significantly affect the  volume  of waste
currently regulated by RCRA as well as the size of the regulated community.

During  the next 12 to 14 months, EPA plans to make a series of decisions relative to how
wastes are currently  defined as hazardous. Issues  being considered include  using such
criteria as waste concentration and management practices in potential  new definitions of
hazardous wastes.

Each of the above regulatory and policy decisions has the potential to shift waste from one
medium to another or one location to another.  The  various impacts of the regulation
discussed in this section  are summarized in Exhibit 11.
                                       3-8

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                          Exhibit 11
Regulations and Policies and Their Potential Effects on Capacity
peOULATJON
OR POUCY
Land Disposal
Restrictions and
Technology
Standards




Waste Minimization
Policy




Deep-Well
Injection
Regulation


Domestic Sewage
Sludge Regulation


Ocean
Incineration
Regulation

Corrective Action
Policies










Superfund Off-Site
Policy
and Clean-Up
Standards

Redefinition
of RCRA
Hazardous Waste




WASTE TRANSFER : ! ; ;
DESCRIPTION ;" ; ..'-
• Shift organic liquids and sludges
to incineration.
• Solidify inorganic sludges prior to
land disposal.
• Redirect wastewaters from surface
impoundments to treatment tanks
and surface waters. Treat and
dispose of residual sludge under RCRA.
* Likely to result in concentration of
hazardous wastes prior to treat-
ment and disposal.



• Potentially restrict disposal of RCRA
hazardous, aqueous wastes from
deep-wells; shift wastes to POTWs
and industrial wastewater treament
plants .
• Large volumes of non-hazardous,
municipal sludge are produced annually.
RCRA contains an exclusion for hazardous
wastes mixed with domestic sewage.
• Permit certain wastes to shift from
land based incinerators and
industrial boilers and furnaces to
incinerator ships.
• UST and SARA may result in some
wastes transferred off-site to RCRA
commercial facilities.
• Increase the volume of solids and
sludges requiring treatment and
disposal.







• Encourages on-site treatment and
disposal of Superfund waste.
Will minimize the volume of untreated
waste transferred to commercial
facilities.
• Potentially change the amount of
waste defined as hazardous.
It is unknown if specific categories
of waste would increase more than
others or the impact on particular
waste management practices.

: AMOUNT OF
WASTE
Moderate

Moderate
Unknown but
potentially large


Reduce volume
25-35%




Moderate to
Large



Unknown but may
be potentially
significant

Small



Moderate to
significant










Moderate




Unknown but
may be potentially
significant




CAPACITY
OUTLOOK:
Constrained

Available for
short-term
May be
constrained
in short-term

Increase the
longevity of
land disposal
units. May increase
demand for
treatment capacity
Constrained




Sludge currently
landfilled, used
for land application
or incinerated.
Constrained
for short-term


Incineration
capacity is
limited in the
short-term.
Could improve
in long-term
given successful
siting programs.
Land disposal
capacity may be
constrained in
long-term unless
successful siting
occurs.
Could be in-
creased through
use of innovative,
mobile treatment
technology.
Capacity
constrained
already for
particular
wastes such as
some solvents
and dioxins.
                             3-9

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                                  SECTION 4

               IMPLICATIONS FOR THE FUTURE
                               Implications for the Future

1
Incinerators 1
Needed 1
Understanding
On-Site Activities



Region & Waste
Specific Capacity

1 Waste
Minimization


Siting and
Permitting
The  regulatory actions discussed  in the previous section  will significantly  influence the
ways waste is managed in the future.  It is difficult to predict the exact interaction among
future  regulatory  actions, generators'  response to  regulations,  and  the  commercial
hazardous waste industry reaction.  However, several preliminary conclusions emerge from
information provided earlier in this  report.  These conclusions are:

      •  More incinerators will likely be needed

      •  A better understanding of on-site activities is required

      •  Capacity is generally a regional and waste specific issue

      •  Waste minimization programs should be strongly encouraged

      •  Siting new facilities and expanding capacity at existing facilities is a priority

The  following provides a brief  summary and  the rationale supporting each of these
conclusions.
MORE INCINERATORS NEEDED

Incineration capacity is already limited for specific types of RCRA hazardous wastes.  In
addition, some states  and regions have inadequate incineration capacity to handle their
wastes and must ship waste out  of  state.  Best available  data  suggest that  existing
incineration capacity would have been exhausted if an extension had not been granted for
solvent wastes when the land ban rule was promulgated in November 1986. While there is
adequate national capacity to burn most hazardous wastes, the addition of solvents to the
incineration market would have stressed existing capacity.

More  incinerators are particularly needed that can burn solids and  sludges contaminated
by hazardous wastes.   More solids and sludges  will be added to the hazardous waste
system as a result of RCRA corrective actions and Superfund response actions.  This will
increase the need for  incinerators.
                                       4-1

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According  to  a  recent  EPA study,  the majority  of  incinerators  are liquid injection
incinerators that are operating at about 55 percent capacity.  There are about 40 rotary
kilns running  at approximately 77  percent capacity.  As the need to burn solids and
sludges increases,  the demand for additional  rotary kiln  capacity will also increase.
Recognizing an emerging  new  demand, several  firms  are  considering  building  new
incinerators.   However, the siting  and permitting of incinerators  are  difficult and  time
consuming.  It is not  uncommon to take  3 to 5 years to site, permit,  and construct an
incinerator. This means that significant new capacity is unlikely in the near  term.

Because incinerators  are designed to burn  specific types  of waste, EPA is  assessing
incineration capacity on a waste specific  basis (e.g., solvents, PCB, etc.).  EPA recently
granted a two-year extension for dilute solvent wastes disposed of on the land based on
data which indicated that there was insufficient capacity to burn these solvents  as well as
other wastes currently being incinerated.  With respect to PCBs,  there are 7 commercial
incinerators permitted  to burn PCB  wastes.  (Refer to Appendix A.)  The incinerators are
located  in  Deer  Park,   Texas;   Chicago,  Illinois;   Coffeyville,  Kansas;  Pittsfield,
Massachusetts and El  Dorado, Arkansas.    Because firms are no longer generating  PCB
wastes, liquid PCB waste is likely to decrease in the next 2-5 years.  On the other hand,
more PCB contaminated soils and  sludges from  RCRA corrective action,  Superfund
cleanup action, and the PCB phase down requirements are likely to continue demand for
PCB incineration.  According  to EPA's  Office of Toxic Substances,  demand for  PCB
treatment and  disposal will likely peak between  1987 and 1991. By October 1988, about
1.7 million PCB capacitors will be phased out and 40,000 PCB transformers by October
1990. EPA is  currently assessing the capacity to handle  the California  listed wastes and
the first third of the listed wastes for the land disposal ban.
MORE INFORMATION ABOUT ON-SITE ACTIVITIES

Since 96 percent of all RCRA hazardous waste is managed on-site EPA intends to focus
on developing a better understanding of on-site  activities.  Furthermore, due to increased
concern about liability and escalating costs of commercial waste disposal, on-site waste
management is likely to  continue at or near current levels.

Anticipating changes in on-site waste management practices is vital.  One area to watch
in the near future is what will happen to on-site facilities when surface impoundments are
required  to  meet  minimum technology requirements  (i.e., liners,  leachate collection
systems and monitoring systems) and  when land disposal  restrictions take effect.   Will
facilities close their surface impoundments,  change to treatment tanks, and use an NPDES
permit to  discharge hazardous  wastewaters  to  surface waters?  If  so, these would no
longer be regulated under RCRA but would be  subject to Clean  Water Act regulations.
This would significantly  decrease the volume of RCRA-regulated waste.  However, the
decrease  will represent an "accounting" change rather than a  reduction in the amount of
waste generated.
                                       4-2

-------
Learning more about on-site management is also important for several other reasons.  Not
only are volumes significantly larger for on-site facilities, but the types of waste managed
at on-site facilities generally are different from those managed by commercials.  On-site
facilities, with the  exception of  those in the chemical industry, generally handle a smaller
range of hazardous wastes.  Commercial facilities, on the other hand, handle very dilute to
highly concentrated forms  of  wastes.   Also, commercial facilities  could probably  not
absorb  large shifts in incineration demand if on-site facilities decided  to ship wastes
off-site.
REGIONAL AND WASTE SPECIFIC CAPACITY

Numerous examples exist to support the conclusion  that regional  and waste  specific
capacity is already a problem.  In some states, there are no commercial hazardous waste
incinerators or landfills in operation.  In these cases, waste must be  transported  to other
states  for treatment and disposal.   Some firms already transport hazardous waste
hundreds of miles for ultimate treatment and disposal.   The regional capacity issue has
become particularly important due to the new Superfund requirement that requires states
to certify long term capacity to manage hazardous waste.

A few states are actively working to site treatment or disposal units to handle hazardous
waste.  In certifying 20 years of capacity to manage hazardous waste in order to comply
with SARA, some states  may consider state or  state/private arrangements for operating
waste management facilities.  Potential capacity  problem areas are noted in Exhibit 12.
                                       4-3

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                                              Exhibit  12
                            Potential Capacity Problem Areas
           CAPACITY
       PROBLEM AREAS
    LIKELY CAPACITY
    PROBLEM AREAS
  UNLIKELY TO BE PROBLEM
  AREAS FOR CAPACITY I
    Incineration

 •  Limited excess capacity currently
    exists commercially for certain
    liquid organic wastes. On-site
    capacity is uncertain.

 •  Siting and permitting delays slow
    capacity expansion.

 •  More sludges and solids could
    be brought into hazardous waste
    system (e.g., RCRA and
    Superfund corrective action),
    some of which will be Incinerated

 •  Capacity inadequate for dioxin and
    solvent contaminated soils.
    Capacity problem exists.
  Wastewater Treatment
  in Tanks or Double
  Lined Surface Impound-
  ments

• Large volumes of RCRA
  hazardous waste are currently
  treated and disposed of in
  surface impoundments.

• Some shift from surface
  impoundments to tanks could
  occur (exempt from RCRA,
  but regulated under the
  Clean Water Act).

• Potential increase in demand
  for tank treatment.

• Solvent wastes scheduled
  for bans have been granted
  (if they would require tank
  treatment) a variance (2 years)
  from ban.
                                    Capacity problem will occur if
                                    conversion to tanks or retrofit
                                    does not take place.
  Solidification

 • Many Inorganic solids and sludges
   are potential candidates for
   solidification.  Limiting factor
   is availability of landfills.

 • Set up time and costs
   are low to stabilize wastes.

 • Technology is not a limiting factor.

 • Some waste may need to be
   stabilized in tanks.
   Capacity should be
   available.
Recycling,  Reuse, Fuel
Distillation
 • Most wastes currently going to
   land disposal would not require
   these technologies.  More likely
   the wastes would require Incin-
   eration in a hazardous waste
   incinerator.
 • Major permit modifications are
   not necessary (RCRA exempt
   processes).

 • Use of these alternatives may be
   reduced by regulations on waste
   minimization, fuel specifications,
   air emissions.
                                                                     Capacity should not be a problem.
Note:

The  reader should note that this chart focuses on national,  physical capacity. However, economic,
transportation, regulatory and legal considerations may constrain the practical availability of capacity.
Moreover, regional  and state capacity problems  may exist.
                                                 4-4

-------
Based on  information currently available,  the number and  capacity of  land disposal
facilities was estimated and is provided in Exhibit 13.

                                     Exhibit 13
             Land Disposal Facilities by Number, Volume,  and
                               Available Capacity
BCFlA Hazardous Waste
Land Disposal Facilities
On-Site Land Disposal
Commercial Land
Disposal
Number off
Facilities
375
60
Volume of
Waste Land
Disposed
1985
8 MMT
5 MMT
Available
; Capacity i
unknown
10-15 years
     Source: National Screening Survey, U.S. EPA (1986) and Survey of Selected Firms in the Commercial
           Hazardous Waste Industry, U.S. EPA (1986).
Assuming current fill rates, it is estimated that 10-15 years of commercial land disposal
capacity exists.  The life expectancy of on-site land disposal is speculative.  However, a
number of complex factors could significantly change land disposal capacity in the future:
          The land disposal restrictions will prohibit the disposal of certain wastes.
          could extend the useful life of some landfills.
This
      •   Waste minimization could potentially reduce the volume of waste generated by
          20 to 30 percent. This should result in a small decrease in the volume of waste
          disposed.

      •   Stabilization will be used to treat some inorganic solids and sludges prior to land
          disposal.  This involves mixing hazardous waste with a solidifying agent, such as
          Portland cement.  Stabilization could increase the  volume of waste by 20-100
          percent.  This will cause landfill space to be used up at  a faster rate.

      •   Wastes and contaminated soils from Superfund sites, RCRA Corrective Action,
          and Leaking Underground Storage Tank cleanups  may increase the volume of
          waste requiring land disposal.

      •   Possible changes in the criteria for listing RCRA waste may change the volume
          defined as hazardous.  The result could change  the amount of wastes ultimately
          managed under RCRA.

Although the Hazardous and Solid Waste Amendments favor treatment over land disposal
of waste, landfills will be needed long into the future.  Land disposal units will continue to
be the ultimate destination  for the  residuals of various other treatment processes (e.g.,
incinerator ash, scrubber sludge, etc.).
                                       4-5

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WASTE  MINIMIZATION

In the last few years, the costs of treating  and disposing  of  hazardous wastes have
increased significantly. Rising costs and concerns over the liability of managing hazardous
wastes have driven firms to look seriously at ways to minimize the amount of wastes they
produce.  According to a recent study conducted by EPA, it may be possible to achieve a
20  to 30 percent reduction  in  waste  through  process changes, product substitution,
recycling, and "good  housekeeping" practices.

Most importantly,  many firms and a number of states are implementing aggressive waste
minimization programs.  EPA strongly supports and encourages  such  programs.
SITING AND PERMITTING ISSUES

More effective siting and permitting are among the most important solutions to the capacity
problem.   Technologies exist to treat and dispose of wastes, but siting and permitting
facilities employing these technologies are difficult.

It will be  important for federal, state,  and local regulators to address these issues.  EPA
has a number of initiatives underway,  including potential state-wide permitting for mobile
waste treatment units.   Streamlining of the permit modification process is another issue
which EPA is addressing. In addition, EPA and the states are working diligently to meet the
Hazardous and Solid Waste  Amendments  (HSWA)  permitting  deadlines for existing land
disposal,  incinerator, and storage and treatment facilities.

Finally, with the Superfund Amendments and Reauthorization Act of 1986 (SARA) provision
that states certify 20 years of capacity to  manage  hazardous waste,  states will need to
focus on alternative treatment  technologies and innovative  approaches to siting new
facilities.
                                       4-6

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APPENDIX A
    A-1

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                 Operating Commercial Incinerator Facilities
^|?f';'gC?WN[M.,::/;?Fj:4,.'
Environmental
Systems Company
International Technology
Corporation
Chemical Waste
Management Inc.
Chemical Services, Inc.
LWD, Inc.
LWD, Inc.
Rollins Environmental
Services
Rollins Environmental
Services
Rollins Environmental
Services
Caldwell Systems,
Inc.
Ross Incineration
Stablex South
Carolina Inc.
GSX Thermal
Oxidation Corp.
B.D.T., Inc.
ioC^TIpN
El Dorado
Arkansas
Martinez
California
Sauget
Illinois
Chicago
Illinois
Calvert City
Kentucky
Clay
Kentucky
Baton Rouge
Louisiana
Bridgeport
New Jersey
Deer Park
Texas
Lenoir
North
Carolina
Grafton
Ohio
Rock Hill
South
Carolina
Roebuck
South
Carolina
New York
: TYPfcOPUNlT. -; ^
Rotary Kiln
Liquid Injection
Liquid Injection &
Fixed Hearth
Liquid Injection &
Rotary Kiln
Liquid Injection
Rotary Kiln
Liquid Injection &
Rotary Kiln
Liquid Injection &
Rotary Kiln
Liquid Incineration
& Rotary Kiln
Liquid Injection &
Solid Incineration
Liquid Injection &
Rotary Kiln
Fixed Hearth
Liquid Injection
Not Available
-' - ,- TYPE OF WASTED. •.;..;,;.;/- «.:;'.'
PCB, Acids, Halogenated & Non-
Halogenated Solvents, Halogenated
& Non-Halogenated Organics
Acids, Non-Halogenated Solvents &
Organics, Metallic Inorganics
Halogenated & Non-Halogenated
Solvents, Halogenated & Non-Halo-
genated Organics
PCB, Halogenated & Non-Halo-
genated Solvents, Halogenated & Non-
Halogenated Organics, Non-Metallic
Inorganics
Acids, Halogenated & Non-Halo-
genated Solvents, Halogenated &
Non-Halogenated Organics,
Metallic Organics
Acids, Halogenated & Non-Halo-
genated Solvents, Halogenated &
Non-Halogenated Organics ,
Metallic Organics
Acids, Halogenated & Non-Halo-
genated Solvents, Halogenated &
Non-Halogenated Organics,
Metallic Organics, Metallic and
Non-Metallic Inorganics
Acids, Halogenated & Non-Halo-
genated Solvents, Halogenated &
Non-Halogenated Organics,
Metallic Organics, Metallic and
Non-Metallic Inorganics
PCB, Acids, Halogenated & Non-Halo-
genated Solvents, Halogenated &
Non-Halogenated Organics,
Metallic Organics, Metallic and
Non-Metallic Inorganics
Halogenated & Non-Halogenated
Solvents, Halogenated & Non-Halo-
genated Organics, Metallic & Non-
Metallic Organics
Acids, Halogenated & Non-Halo-
genated Solvents, Halogenated &
Non-Halogenated Organics,
Halogenated & Non-Halogenated
Solvents, Halogenated & Non-Halo-
genated Organics, Metallic Organics
Halogenated & Non-Halogenated
Solvents, Halogenated & Non-Halo-
genated Organics
Metals
* In addition, there are four TSCA commercial Incinerators permitted to burn PCB wastes. They include:
  Pyrochem (Coffeyville, Kansas), Pyrotech Systems - mobile unit, U.S. EPA Incinerator - mobile
  unit, and General Electric (Pittsfield, Massachusetts).

Source:  EPA,  Office of Solid Waste and Office of Toxic Substances.

                                            A-2

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APPENDIX B
    B-1

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                    Operating Commercial Land Disposal Facilities
           OWNER
                  TYPES OF FACILITIES]
Chemical Waste Management Inc


Lion Oil Company


IT Corp Benecia


IT Corp Vine Hill


IT Corp Imperial


Casmalia Resources


Chemwest Industries Inc


AMCE Fill Corporation



IT Corp Baker Facility


Chemical Waste Management Inc

CECOS International Inc


City of Danbury


Torrington Landfill


Salsbury Laboratories


Envirosafe Services of Idaho


SCA Chemical  Services Inc


Peoria  Disposal Co


CID-Landfill



Kerr-McGee Chemical Corp

CECOS International Inc./BFI


Four County Landfill


Adams Center  Landfill Inc
Emelle
Alabama

El Dorado
Arizona

Benecia
California

Martinez
California

Westmoreland
California

Casmalia
California

Fontana
California

Martinez
California


Martinez
California

Kettleman City
California
Bristol
Connecticut
Danbury
Connecticut

Torrington
Connecticut

Charles City
Iowa

Grand View
Idaho
Chicago
Illinois

Peoria
Illinois

Calumet City
Illinois
Madison
Illinois
Zion
Illinois

Rochester
Indiana

Fort Wayne
Indiana
Landfill, Storage Impoundments,
Treatment Impoundments

Land Treatment, Storage
Impoundments

Landfill, Disposal Impoundments,
Storage Impoundments,

Treatment Impoundments
Disposal Impoundments,
Treatment Impoundments

Landfill, Disposal Impoundments,
Treatment Impoundments

Storage Impoundments
Landfill
Disposal Impoundments,
Treatment Impoundments

Landfill, Treatment
Impoundments
Waste Piles
Landfill
Landfill
Storage Impoundments,
Treatment Impoundments

Landfill, Waste Piles
Storage Impoundments,
Treatment Impoundments

Landfill
Landfill



Storage Impoundments


Landfill


Landfill


Landfill
Metals,Cyanides, Acidic
Corrsives, PCBs, Halogens

Metals
Metals, Cyanides, Solvents


Metals


Metals, Solvents


Acidic Corrosives, Metals,
Cyanides,  Halogens

Acidic Corrosives


Other



Metals, Acidic Corrosives


Acidic Corrosives, Metals

Metals, Cyanides


Metals


Metals


Metals, Solvents, Halogens


Acidic Corrosives, Metals,
Cyanides,  Solvents, PCBs,
Halogens
Other


Metals


Acidic Corrosives, Metals,
Cyanides,  Solvents,
Halogens

Other


Metals, Solvents, Halogens


Metals


Acidic Corrosives, Metals,
Cyanides,  Solvents,
Halogens
                                                B-2

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                Operating Commercial Land  Disposal Facilities  (cont.)
          OWNER
  LOCATION
   TYPES OF FACILITIES
          WASTE
CECOS International Inc.

CECOS International Inc

Chemical Waste Management Inc


Rollins Environmental Services


Wayne Disposal, Inc


Environmental Waste Control


Chem-Met Services Inc


Federal-Hoffman Inc


North Star Steel Co


B. H. S. Inc


Rogers Rental Landfill


Burlington Northern Somers


US Ecology Inc


Frontier Chemical  Waste Process


CECOS International Inc


F E I Landfarming


Ashland Chemical Co


Chemical Waste Management Inc


Fondessy Enterprises Inc


Erieway Pollution Control Inc


CECOS International Inc


Delhi Industrial Products
Westlake
Louisiana
Livingston
Louisiana
Carlyss
Louisiana

Baton Rouge
Louisiana

Bellerville
Michigan

Inkster
Michigan

Wyandotte
Michigan

Anokia
Minnestoa

St. Paul
Minnesota

Wright City
Missouri

Centreville
Mississippi

Somers
Montana

Beatty
Nevada

Niagara Falls
New  York

Niagara Falls
New  York

Oregon
Ohio

South Point
Ohio

Vickery
Ohio

Oregon
Ohio

Bedford
Ohio

Williamsburg
Ohio

McDonald
Ohio
Storage Impoundments

Landfill

Landfill
Landfill, Storage Impoundments
Treatment Impoundments

Treatment Impoundments
Treatment Impoundments


Waste Piles


Landfill


Waste Piles


Landfill


Land Treatment
Waste Piles, Storage
Impoundments

Landfill
Waste Piles


Landfill


Land Treatment


Waste Piles


Storage Impoundments


Landfill


Waste Piles


Landfill


Waste Piles
Acidic Corrosives, Metals,
Solvents, Halogens
Acidic Corrosives, Cyanides,
Solvents, Halogens
Metals, Cyanides, Solvents,
Halogens

Metals, Solvents, Cyanides,
Acidic Corrosives

Acidic Corrosives, Metals

Acidic Corrosives, Metals
Acidic Corrosives, Metals,
Solvents, Halogens

Other
Metals


Metals, Halogens


Other
Acidic Corrosives, Metals,
Solvents

Metals, Cyanides, Solvents,
PCBs, Halogens

Metals
Acidic Corrosives, Metals,
PCBs

Metals
Other
Acidic Corrosives, Metals
Metals, Cyanides, Solvents,
Halogens

Acidic Corrosives, Metals,
Halogens

Metals, Cyanides, Solvents,
PCBs, Halogens

Metals
                                                B-3

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                   Operating Commercial Land  Disposal Facilities (cont.)
            OWNE8
  LOCATION
   TYPES OF FACILITIES
         WASTE
  Eagle Richer Industries Inc

  USPCI




  Chem-Security Systems Inc



  Mill Service Inc



  Mill Service Inc



  GSX Services of South Carolina


  Yale Security Inc


  Gibraltar Chemical Resources


  US DOE K-25 Site


  Gulf Coast Waste Disposal


  Chemical Waste Management Inc





  Rollins Environmental Services




  Olin Corporation



  Malone Service Company



  Texas Ecologists Inc.



  USPCI
Quapaw
Oklahoma
Waynoka
Oklahoma
Arlington
Oregon
Yukon
Pennsylvania

Bulger
Pennsylvania


Pinewood
South Carloina

Lenoir City
Tennessee

Winona
Texas

Oakridge
Texas

Texas City
Texas

Port Authur
Texas
 Deer Park
 Texas
Beaumont
Texas
Texas City
Texas
Robstown
Texas
Knowles
Utah
Disposal Impoundments

Landfill, Disposal
Impoundment, Waste Piles,
Storage Impoundments
Treatment Impoundments

Landfill, Storage
Impoundments,
Treatment Impoundments

Disposal Impoundments,
Waste Piles
Disposal Impoundments,
Waste Piles
Storage Impoundments


Storage Impoundments


Treatment Impoundments


Storage Impoundments


Landfill, Land Treatment
Landfill, Disposal
Impoundments,
Storage Impoundments,
Treatment Impoundments
 Landfill, Storage
 Impoundments, Treatment
 Impoundments
Treatment Impoundments
Landfill, Storage
Impoundments,
Treatment Impoundments

Landfill
Landfill, Land Treatment,
Storage Impoundment
Metals, Solvents

Acidic Corrosives, Metals,
Cyanides
Acidic Corrosives, Metals,
Solvents, PCBs, Halogens
Metals
Metals
Acidic Corrosives, Metals,
Cyanides

Acidic Corrosives, Metals
Cyanides, Halogens
Acidic Corrosives, Metals
Metals, Cyanides
Acidic Corrosives, Metals,
Cyanides,  Solvents, Dioxins
Halogens
Metals, Cyanides, Solvents,
Halogens
Acidic Corrosives, Metals,
Cyanides,  Solvents,
Halogens

Metals, Cyanides, Acidic
Corrosives
Metals, Cyanides, Solvents,
Halogens
Metals, Acidic Corrosives,
Solvents, PCBs, Halogens
Source:  EPA, Office of Solid Waste.
                                                 B-4

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APPENDIX C
     C-1

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                Commercial Deep-Well Injection Systems
                                    LOCATION
                                                                WASTE
CECOS International



CECOS International
                                   Lake Charles
                                   Louisiana
                                   Livingston
                                   Louisiana
Chemical Waste Management Inc.
                                   Lake Charles
                                   Louisiana
Rollins Environmental Services
                                   Baton Rouge
                                   Louisiana
Chemical Waste Management Inc.
Chemical Resources, Inc.
Disposal Systems, Inc.
                                   Vickery
                                   Ohio
                                   Tulsa
                                   Oklahoma
                                   Houston
                                   Texas
Acids,  Caustics,  Cleaning Solutions,
Organic and Inorganic Wastewaters,
Leachate, Contaminated Soils

Acids,  Chromic Acids, Pickling Acids
Caustics, Cyanides, Paints and Inks,
Non-Halogenated Solvents,
Halogenated Solvents, Waste Oil,
Commercial Chemical Products,
Contaminated Soil, Asbestos,
Spent Catalysts

Acids,  Chromic Acids, Pickling Acids
Caustics, Cyanides, Paints and Inks,
Non-Halogenated Solvents,
Halogenated Solvents, Waste Oil,
Non-metallic Inorganic, Metallic
Inorganics,  Non-Halogenated
Organics, Halogenated Organics,
Contaminated Soils

Acids,  Chromic Acids, Pickling Acids
Caustics, Cyanides, Paints and Inks,
Non-Halogenated Solvents,
Halogenated Solvents, Waste Oil,
Commercial Chemical Products,
Non-metallic Inorganics, Metallic
Inorganics,  Non-Halogenated and
Halogenated Organics, Pesticides,
PCB Liquids <50ppm, PCB Solids
<50ppm, Contaminated Soil, Lab
Packs.

Acids,  Chromic Acids, Pickling Acids
Caustics, Waste  Oil, Non-metallic
Inorganics,  Metallic Inorganics,
Non-Halogenated Organics.

Acids,  Pickling Acids, Cyanides,
Paint and Inks, Non-Halogenated
Solvents, Waste  Oil, Metallic
Inorganics,  Metallic Organics,
Pesticides.

Acids,  Chromic Acids, Caustics,
Cyanides, Paints  and inks, Non-
Halogenated Solvents, Halogenated
Solvents, Waste  Oil, Commercial
Chemical Products, Non-Metallic
Inorganics,  Metallic Inorganics,
Metallic Organics, Non-Halogenated
Organics, Halogenated Organics,
Pesticides,  Contaminated Soil,
Texas Class I Hazardous Wastes.
                                        C-2

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                Commercial Deep-Well Injection Systems
                                    LOCATION
                             WASTE
Chemical Waste Management Inc.
Corpus Christ!
Texas
Malone Service Co.
Texas city
Texas
EMPAK, Inc.
Deer Park
Texas
Gibraltar Chemical Resources
Chemical Waste Management
Winona
Texas
Port Authur
Texas
CECOS International, Inc
Odessa
Texas
Acids, Chromic Acids, Pickling Acids
Caustics, Cyanides, Paints and Inks,
Non-Halogenated Solvents,
Halogenated Solvents, Waste Oil,
Non-metallic Inorganics,  Metallic
Inorganics,  Non-Halogenated
Organics, Halogenated Organics
Acids, Chromic Acids, Pickling Acids
Caustics, Cyanides,  Paints and Inks,
Non-Halogenated Solvents,
Halogenated Solvents, Waste Oil,
Commercial Chemical Products
Non-Metallic Inorganics, Metallic
Inorganics, Metallic Organics,
Non-Halogenated Organics,
Pesticides.

Acids, Chromic Acids, Pickling Acids
Caustics, Cyanides,  Paints and Inks,
Non-Halogenated Solvents,
Halogenated Solvents, Waste Oil,
Commercial Chemical Products
Non-Metallic Inorganics, Metallic
Organics, Non-Halogenated
Organics, Pesticides.
Acids, Chromic Acids, Pickling Acids
Caustics, Cyanides,  Paints and Inks,
Non-Halogenated Solvents,
Halogenated Solvents, Waste Oil,
Texas Class I Waste


Acids, Chromic Acids, Pickling Acids
Caustics, Cyanides,  Paints and Inks,
Non-Halogenated Solvents,
Halogenated Solvents, Waste Oil,
Commercial Chemical Products
Non-Metallic Inorganics, Metallic
Organics, Non-Halogenated  and
Halogenated Organics, Pesticides,
Contaminated Soil.


Acids (pH >5), Chromic Acids, Pickling
Acids, Caustics, Metallic Organics
Flammable  Liquids, Cyanide Waste
Stream.
Source: EPA, Office of Solid Waste.
                                        C-3

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BIBLIOGRAPHY

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                             BIBLIOGRAPHY
Analysis  of  Capacity Short Falls  of  Schedules  for Implementing the Land  Disposal
Restriction Program.  U.S. EPA, Office of Solid Waste, ICF, Inc., March, 1985. (Report)

Assessment  of the Commercial Hazardous Waste Incineration Market.  U.S.  EPA,  OPA,
Booz-Allen & Hamilton, Inc., November 30, 1984.  (Report)

Capacity  Short Falls  and  the  Land Disposal  Restriction  Program:    A  Preliminary
Assessment.  U.S. EPA, Office of Solid Waste, ICF Inc., July, 1985. (Report)

Commercial  Hazardous Waste Treatment Capacity:   Data  Sources, Evaluation  and
Potential  Survey Questionnaire:  Final Report (Task 2).   U.S.  EPA, Waste Treatment
Branch, Office of Solid Waste,  Booz-Allen Hamilton, GCA, December, 1984. (Report)

Comprehensive Hazardous Waste  Management Study.   Mississippi Hazardous Waste
Council, ERM, Inc., January, 1982.  (State Report)

EPA to Issue New Toxic-Waste Rules;  Big Rise in  Disposal Costs Seen for Firms, Robert
E. Taylor, Wall Street Journal, October 23,  1986. (Article)

Estimate  of  Need.   Minnesota Waste Management  Board,  September,  1985.   (State
Report) Attachments:  Commercial  Hazardous Waste Landfill Capacity.  Memo, Marcia
Williams,  U.S. EPA, Office of Solid  Waste, November 14, 1985.  Recent Data on Out of
State Landfill Capacity.  Office  Memo,  December 1985.

Estimating Competition  for  Commercial  Hazardous  Waste  Treatment  Capacity  from
non-RCRA Wastes:  Draft Report (Task 1.3).  U.S. EPA, Waste Treatment Branch, Office
of Solid Waste, Booz-Allen & Hamilton under contract for GCA, Inc., December, 1984.
(Report)

Final Report on Hazardous Waste in North Carolina:  Analysis of the Collection Systems,
and of the Need for Waste Management Facilities.  Battelle Columbus, February 21, 1985.
(State Report)

Gulf Coast Disposal of Hazardous Waste:  Demand, Capacity, and Pricing - 1980-1990.
Gulf Coast Waste Disposal Authority, The Pace Co., September 1981. (State  Report)

Hazardous and Solid Waste Amendments of 1984.

Hazardous Waste Facility Needs Assessment.  New York State Dept. of  Environmental
Conservation, Division of  Solid and Hazardous  Waste,  ERM-Northeast,  March, 1985.
(State Report)

Hazardous Waste Generation and Commercial Hazardous Waste Management Capacity.
U.S. EPA, Office of  Solid Waste, Booz-Allen & Hamilton,  Inc., and Putnam, Hayes  &
Bartlett, Inc., December, 1980.  (Report)

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                           BIBLIOGRAPHY (cont.)


Hazardous  Waste Management Plan.   Minnesota Waste Management Board, February,
1984.  (State Report)

Hazardous Waste Management Report.  Minnesota Waste Management Board, December,
1983.  (State Report)

Hazardous Waste Management System: Land Disposal Restriction, California List, Office
of Solid Waste, November 3, 1986.  (Proposed Rule)

Hazardous Waste Management System: Land Disposal Restriction, Solvents and Dioxins,
Office of Solid Waste,  November 8,  1986.  (Final Rule)

Hazardous Waste Management Technology:  Draft Report  (Task 2.1).  U.S. EPA, Waste
Treatment Branch,  Office of Solid Waste,  Booz-Allen Hamilton, GCA, December, 1984.
(Report)

Hazardous Waste Treatment and Resource Recovery Facility Feasibility Study.  Missouri
Environmental Improvement and Energy Resources Authority, ERM, January, 1985. (State
Report)

Identification and Evaluation of Sources of Capacity-Related Data for Hazardous Waste
Management Technology: Draft Report (Task 2-1).  U.S. EPA, Waste Treatment Branch,
Office of Solid Waste,  Booz-Allen Hamilton, GCA, December 1984.

Improved  Hazardous  Wastes Management Needs, Chemical  Engineering  Progress,
September  1986. (Article)

Incineration Permitting  and Capacity, Office of Emergency  and Remedial Response,  July
16, 1986. (Briefing)

Incinerator and Cement Kiln Capacity for Hazardous  Waste Treatment, G.A. Vogel,  A.S.
Goldbuk, R.E. Zier,  and A. Jewell of  Mitre Corporation and I. Licis of U.S. EPA, Cincinnati,
Ohio. (Article)

Incinerator and Cement Kiln Capacity for Hazardous Waste Treatment.  Vogel, G.A., et al.,
Mitre Corp., presented at 12th Annual EPA Research  Symposium,  April  21-23, 1986,
Cincinnati, Ohio.  (Report)

National  Screening  Survey  of  Hazardous  Waste Treatment, Storage, Disposal,  and
Recycling Facilities. 1986 U.S. EPA, Office of Policy, Planning and Information, Research
Triangle Institute.  (Ongoing Study)

National Small Quantity Hazardous  Waste  Generator Survey, U.S. EPA, Office  of Solid
Waste, Abt Associates, February,  1985 (Report).

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                           BIBLIOGRAPHY (cont.)


National Survey of Hazardous Waste  Generators and Treatment, Storage and Disposal
Facilities Regulated under RCRA in 1981.  U.S. EPA, Office of Solid Waste, Westat, Inc.,
April,  1984. (Report)

1984  Needs  Survey  Report  to Congress  Assessment of  Needed  Publicly  Owned
Wastewater Treatment  Facilities in the  United States.   U.S.  EPA,  Office of Municipal
Pollution Control, Roy F. Weston, Inc., February 1985. (Report)

New  Jersey  Hazardous  Waste Facilities Plan, NJ  Hazardous  Waste  Facility  Siting
Commission, ERM, March, 1985. (State Report)

Permitting of Land Treatment Units;  EPA Policy, and Guidance Manual on Land Treatment
Demonstration,:  J. Winston Porter, September 17, 1986.  (Memorandum)

Potential for Capacity Creation in the Hazardous Waste Management  Service Industry.
U.S. EPA,  Office of Solid Waste, Foster D. Snell, Inc., August 1976.  (Report)

Profile of Existing Hazardous Waste Incineration Facilities and Manufacturers in the United
States.  Mitre, February, 1984. (Report)

Question of Effect of  UST Cleanups on the  Capacity  Subtitle C Facilities,  Richard
Valentinetti, Office of Underground Storage Tanks, U.S. EPA, Fall, 1986. (Memorandum)

Re-Analysis  of  the  National Survey  of Hazardous Waste  Generators and Treatment
Storage and Disposal Facilities Regulated under RCRA in 1981.  U.S.  EPA, Office of Solid
Waste, Westat,  Inc., April, 1984.  (Ongoing Study)

Report on  Hazardous Waste Management Needs Assessment, TVA, Battelle Columbus.
June, 1984. (Report)

Report to Congress on Injection of  Hazardous Waste.  U.S. EPA, May,  1985. (Report)

Report to Congress: Waste Minimization,: Office of Solid Waste, U.S. EPA.

Resource Conservation  and Recovery  Act of  1976.

Review of Activities of Major Firms in the Hazardous Waste Management Industry:  1982
Update. U.S. EPA, OPA,  Booz-Allen & Hamilton, Inc., August, 1983. (Report)

Review of Activities of Firms in the Commercial Hazardous Waste Management Industry:
1983 Update.  U.S. EPA, OPA,  Booz-Allen & Hamilton, Inc., November, 1984. (Report)

Serious Reduction of Hazardous Waste, Office  of Technology Assessment,  September
1986. (Report)

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                           BIBLIOGRAPHY (cont.)


Statement of J.  Winston  Porter  on Capacity and Waste Minimization  before the
Subcommittee on Environment,  Energy  and Natural  Resources of the  Committee in
Government  Operations,  U.S.  House  of  Representatives,  September  24,  1986.
(Testimony)

Study to Evaluate Impact  of EAF Dust Land Disposal  on Human  Health  and the
Environment, prepared for  the American Iron  and  Steel Institute  by Baker/TSA, Inc.,
September 1986. (Report)

Survey of Selected Firms in  the Commercial Hazardous Waste Management  Industry:
1984 Update. U.S. EPA, OPA, IGF, Inc., September, 1985. (Report)

Survey of Waste as Fuel:  Track  II.  U.S. EPA, Office of Solid Waste, Westat, Inc.,
November, 1985. (Report)

Survey of Selected Firms in  the Commercial Hazardous Waste Management  Industry:
1985 Update. U.S. EPA, Office of Policy Analysis, ICF, Inc., September, 1986.

Time Requirements for the Siting, Permitting, and Construction of New Hazardous  Waste
Treatment Facilities prepared for the Office of Solid Waste by Jacobs Engineering Group,
Inc., January 3,  1986. (Final Report)

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U.S. Environmental  Protection Agency
Region V, Library               ,.-•
230 South Dearborn Street
Chicago, Illinois  60604 ,-x

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