<&EPA
United States
Environmental Protection
Agency s -
. ' Solid Waste and
' Emergency Response
(5305W)
EPA530-R-97-028
NTIS: P897-176937
April 1997
Background Document
for Land Disposal
Restrictions - Wood
Wastes
(Final Rule)
' * ' ' .
i . - "
i ' " ,
Capacity Analysis and
Response to Capacity-Related
Comments
s, sw
DC 20460
Printed on paper that contains at last 20 percent postconsumer fiber
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TABLE OF CONTENTS ,
CHAPTER!. INTRODUCTION; ; ; 1-1
1.1 LEGAL BACKGROUND : : ;.... 1-1
.1.2 OVERVIEW OF CAPACITY ANALYSIS AND COMMENT RESPONSE METHODOLOGIES.. 1-2
1.2.1 Determination of Required Commercial Treatment Capacity;.. 1-3
1.2.2 Determination of Available Commercial Treatment Capacity .: ;..'. 1-4
1.2.3 Comment Response '. ..:........ 1-5,
1.3 SUMMARY OF CAPACITY ANALYSIS FOR TODAY'S RULE ;.....! ....! 1-5
1.4 ORGANIZATION OF BACKGROUND DOCUMENT SUPPORTING THE CAPACITY ANALYSIS..1-5
CHAPTER 2. AVAILABLE TREATMENT CAPACITY ........; '. 2-1
2.1 COMMERCIAL COMBUSTION CAPACITY :...2-l
. 2.1.1 General Methodology : '. 2-1
2.1.2 Results. : '. ; '.2-3
2.2 WASTEWATER TREATMENT CAPACITY '.."...'.....' .'......2-7
2.3 STABILIZATION CAPACITY : ... ; 2-11
2.4 VITRIFICATION CAPACITY..... :. : !.> : 2-11
CHAPTER 3. CAPACITY ANALYSIS FOR NEWLY LISTED WOOD PRESERVING WASTES 3-1
1
3.1 INTRODUCTION......: '. ; : ,. .' '....; '. .......3-1
3.1.1 Regulatory History -. ! ; 3-1
3.1.2 Wood Preserving Listings....:.....: : .. 3-1
. 32 DATA SOURCES.. :.. ...'. ; .....:....:.; 3-2
3.2.1Biennial Reporting System (BRS) .'; ; 3-2
3.2.2 Wood Preserving RIA .' J .'. 3-2
' 3.2.3 1994 Micklewright Report :... ....< r 3-3
3.2.4 ANPRM Comments 1...1 : '....; 3-4
3.2.5 Comments to the Phase IV Proposed Rule and Notice of Data Availability .3-4
3.2.6 Phone Logs, Communications, and Clarifications of Comments Submitted 3-4
3.3 WASTE GENERATION AND MANAGEMENT I...... '. ...3-5
. 3.3J Waste Generation :..,..... .'. '.'. '. ........3-5
3.3.2 Waste Management : : . 3-8
.3.4 SOIL AND DEBRIS CONTAMINATED WITH NEWLY LISTED WOOD PRESERVING WASTES.3-10
3.5 MIXED RADIOACTIVE WOOD PRESERVING WASTES ..;....'....: :'. : ...3-12
3.6 CAPACITY ANALYSIS '. . ; :..3-12
3.6.1 Wood Preserving Wastewaters and Nonwastewaters Contaminated with Newly Listed Wood-Preserving
Wastes. . ! ..: : 3-12
3.6.2 Soil and Debris Contaminated with Newly Listed Wood Preserving Wastes 3-14
3.6.3 Mixed Radioactive Wastes. : 3-14
< CHAPTER4. COMMENT/RESPONSE..... .. . . .. ,..4-1
4.1 INTRODUCTION.... .- !....-.; ." '....-. '. ;.! .-..,'. 4-1
4.2 DISCREPANCY EXISTS IN THE WOOD PRESERVING WASTE GENERATION ESTIMATES 4-2
4.3 SUFFICIENT COMBUSTION CAPACITY EXISTS FOR NEWLY LISTED WOOD PRESERVING
WASTES.: '. ;......-. : ; .- ; ; ; -. 4-7
4.4 INSUFFICIENT INCINERATION CAPACITY EXISTS FOR F032 WASTES 4-14
. 4.5 CAPACITY FOR F032 WILL NOT INCREASE '....'. '. 4-43
4.6 NO ALTERNATIVE DIOXIN/FURAN TECHNOLOGIES ARE COMMERCIALLY AVAILABLE ...4-57
4.7 INSUFFICIENT VITRIFICATION CAPACITY EXISTS FOR NEWLY LISTED WOOD PRESERVING
WASTES :.: : : .-. ;...:. '. ;.;.-. .4-74
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4,8 AVAILABLE CAPACITY DOES NOT EXIST FOR NEWLY LISTED WOOD PRESERVING
WASTEWATERS .- '. 4-81
4,9 NATIONAL CAPACITY VARIANCE IS NEEDED FOR SOIL AND DEBRIS CONTAMINATED WITH
NEWLY LISTED WOOD PRESERVING WASTES : ; ,. 4-85
Appendix A: DATA ON AVAILABLE COMBUSTION CAPACITY
Appendix B: DATA ON AVAILABLE WASTEWATER CAPACITY
Appendix C: DATA ON CURRENTLY AVAILABLE STABILIZATION CAPACITY
Appendix D: DATA ON AVAILABLE VITRIFICATION CAPACITY
Appendix E: COMMENTER DATA
Appendix F: COMMUNICATION LOGS
Appendix G: BIENNIAL REPORTING SYSTEM (BRS) REPORT
Appendix H: METHODOLOGY FOR ESTIMATING QUANTITY OF SOIL AND DEBRIS
CONTAMINATED WITH WOOD PRESERVING WASTES
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, CHAPTER 1
INTRODUCTION
This document presents the capacity analysis that EPA conducted to support the Phase IV Land
Disposal Restrictions (LDRs) rulemaking on newly listed wastes from wood preserving. EPA conducts
capacity analyses to evaluate the need for national capacity variances from the land disposal
prohibitions.' The capacity analysis provides estimates of the quantities of wastes that will require
alternative commercial treatment prior to land disposal as a result of the LDRs and estimates alternative
commercial treatment capacity available to manage wastes restricted from land disposal. In this rule,
EPA is promulgating LDRs for certain wastes listed and identified since November 1984 that have not
been covered in previous LDR rulemakings.
1.1 LEGAL BACKGROUND
The Hazardous and Solid Waste Amendments (HSWA) to the Resource Conservation and
Recovery Act (RCRA), enacted on November 8, 1984, set .basic new priorities for hazardous waste
management. Land disposal, which had been the most widely, used method for managing hazardous
waste, is now the least preferred option. Under HSWA, EPA must promulgateiregulations restricting the
land disposal2 of hazardous wastes according to a strict statutory schedule. As of the effective date of
each regulation, land disposal of .wastes covered by that regulation is prohibited unless (1) the waste
meets the treatment standards that have been established, or (2) it can be demonstrated that there will be
no migration of hazardous constituents from the disposal unit for as long as the waste remains hazardous.
Under the LDR Program, EPA must identify levels or methods of treatment that substantially '
reduce the toxicity of.a.waste or the likelihood of migration of hazardous constituents from the, waste.
Whenever possible, the Agency prefers to define treatment in terms of performance (i.e., maximum .
acceptable concentrations of hazardous constituents in the treated waste or residuals), rather than in
terms of specific treatment methods, and thus provide the regulated community, with flexibility in
. complying with the LDRs. EPA's standards are generally based on the performance of the best
demonstrated available technology (BDAT) for that waste, as documented by treatment data collected at
well-designed and well-operated systems using that technology, or are based on data derived from the
treatment of similar wastes that are as difficult or more difficult to treat.
' ' * ' ., \
The LDRs are effective immediately upon promulgation unless the Agency grants a national
capacity .variance from the statutory date because of a lack of available treatment capacity (see RCRA
section 3004(h)(2)). For every waste, EPA considerson a national basisboth the capacity of
commercially available treatment technologies and the quantity of restricted wastes currently sent to land
disposal for which on-site treatment capacity, is not available. If EPA determines that adequate
alternative commercial treatment capacity is available for a particular waste, the land disposal restriction
is effective immediately. If not, the Agency establishes an alternative effective date based on the earliest,
date on which adequate treatment capacity will-be available or two years, whichever is less. During the
1 The LDRs are effective when promulgated unless the Administrator grants a national capacity variance from the
otherwise applicable date and establishes a different date (not to exceed two years beyond the statutory deadline)
based on: "... the earliest date on which adequate alternative treatment, recovery, or disposal capacity which protects
human health and the environment will be available" (RCRA section 3004(h)(2))."
* . ' " -.
2 RCRA defines land disposal "to include, but not be limited to, any placement of such hazardous, waste in a landfill,
surface impoundment, waste pile, injection well, land treatment facility, salt dome formation, salt bed formation, or
underground mine or cave" (RCRA section 3004(k)). ' . .
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meet the LDR treatment standards. EPA uses the available information and best engineering judgment to
develop estimates for required commercialcapacity, Those wastes that are managed in on-site treatment
systems are excluded from the estimates of required commercial capacity. Required commercial capacity
also includes the residuals generated by treatment of these wastes (i.e., the quantity of generated residuals
that will need treatment prior to land disposal). ^
EPA identifies the waste streams potentially affected by the LDRs by types of land disposal
units, including surface impoundment, waste pile, land treatment unit, landfill, and underground injection
well. Salt dome formations, salt bed formations, and underground mines and caves are additional
methods of land disposal that are affected by the LDRs; however, because few wastes are disposed by
these three methods, these methods typically are not addressed in the analysis of required alternative
capacity. .
To determine the type of alternative capacity required to treat the affected wastes, EPA conducts
a "treatability analysis" of each waste stream. Based on the waste's physical and chemical form and
information on prior management practices, EPA assigns the quantity of affected waste to an appropriate
technology (i.e. a technology that can meet the treatment standards). Mixtures of RCRA wastes (i.e.,
waste streams described by more than one waste code) present special treatability concerns because they
often contain constituents (e.g., organics and metals) requiring different types of treatment. To treat
these wastes, EPA develops a treatment train that can treat all waste types in the group (e.g., incineration
followed by stabilization of the incinerator ash). In these cases, the Agency estimates the amount of
residuals that would be generated by treatment of the original quantity of waste and includes these
- residuals in the quantities requiring alternative treatment capacity. , _
EPA identifies the quantities of waste requiring alternative treatment on a facility level basis; if
the appropriate treatment technology is not available on site, or if adequate available capacity is not
present to manage the waste, then the appropriate quantity of waste requiring alternative treatment is
aggregated into a national demand for commercial capacity. EPA excludes from the estimate^ of
required commercial capacity those wastes that are managed in on-site treatment systems.
1.2.2 Determination of Available Commercial Treatment Capacity
The analyses,conducted to determine available commercial treatment capacity focuses on
treatment capacity projected to be available for the two years following promulgation of the LDRs,
starting from the baseline capacity identified in the Phase III LDR rule (61 FR 15565).7
' The determination of available capacity focuses on commercial facilities. Consequently, all
estimates of capacity presented in this document represent commercially available capacity.8 In order to
determine whether to grant a national capacity variance for newly listed and identified wastes regulated
in today's rule, EPA analyzed available commercial capacity for alternative treatment technologies
7 EPA, Background Document for Capacity Analysis for Land Disposal Restrictions - Phase ///, Decharacterized
Wastewaters, Carbamate Wastes, and Spent Potliners^ April 1996.
8 Available treatment capacity can be categorized by facility status into four groups: (1) commercial capacity -
capacity at.facilities that manage waste from any facility; (2) on-site (private capacity) - capacity at facilities that
manage only waste generated on-site; (3V captive capacity - capacity at facilities that manage only waste from other
facilities under the same ownership; and (4) limited commercial capacity - capacity at facilities that manage waste
from a limited number of facilities not under the same ownership. For all capacity analyses, estimates on available
capacity reflect available commercial capacity. ' ^
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capable of meeting the LDR treatment standards. This capacity analysis generally included estimating
the maximum or design capacity for appropriate waste management systems and the amount of waste
currently going to these systems (utilized capacity). Available capacity was estimated as the difference
between maximum and utilized capacity. For today's rale, EPA analyzed commercial capacity for
wastewater treatment systems, hazardous waste combustion (including incineration and reuse as fuel),
and stabilization for soil and debris. On-site treatment technologies, which may also be used, are not
discussed here. . ' <
1.2.3 Comment Response . -
, EPA reviews all comments submitted in response to the proposed LDR rule and NODA, and for
the purposes of this background document, identifies those related to treatment capacity. Relevant
comments then are summarized and categorized according to type of waste, treatment technology, issue,
etc. Data from the comments are identified and incorporated into the capacity analysis. Next, the
Agency develops responses to each comment category, as appropriate. Finally, the comment summaries,
copies of the verbatim comment text, and the responses are compiled into a background document. (For
wood preserving wastes, the capacity analysis arid comment response documents are combined into one
document). '..'/ .
1.3 SUMMARY OF CAPACITY ANALYSIS FOR TODAY'S RULE
To estimate the need for national capacity variances, EPA estimated the quantities of waste
requiring alternative commercial treatment as a result of the land disposal restrictions and the capacity ..
available at commercial treatment facilities to manage the restricted wastes. Exhibit 1-2 indicates the
total quantities of surface disposed wastes that will require alternative commercial treatment capacity as
a result of the rale, and whether treatment capacity is available for these wastes.
Exhibit-1-3 summarizes the wastes for which EPA is granting a national capacity variance. EPA
is granting two-year national capacity variances for soil and debris contaminated with newly listed wood
preserving wastes and mixed radioactive wood preserving waste, including soil and debris contaminated
with mixed radioactive wood preserving wastes. , .
1.4 ORGANIZATION OF BACKGROUND DOCUMENT SUPPORTING THE CAPACITY
ANALYSIS' ''. ' " . - '
EPA has prepared this background document to present the capacity analyses conducted for, the
Phase IV LDRs. This document is organized into four chapters, as described below:
* '^ .
' . Chapter 1: Introduction. Provides background, general methodology,.and a summary of
the analysis. * ' ' '
' f . ' '
Chapter 2: Available Treatment Capacity. Describes the methodology and data used to
. ., determine available capacity, for wastewater treatment, combustion of liquids and solids, and
stabilization. . . ' .
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EXHIBIT 1-2
QUANTITIES REQUIRING COMMERCIAL TREATMENT
AS A RESULT OF THE LDRs
Waste Type
Newly Listed Wood Preserving Wastes
- Organic Nonwastewaters
- Inorganic Nonwastewaters
- Organic Wastewaters
- Inorganic Wastewaters
- Soil and Debris
Mixed Radioactive Wood Preserving
Wastes/Soil and Debris Contaminated with
Mixed Radioactive Wood Preserving Wastes
Quantities Requiring
Alternative Capacity
(tons/year)
8,600
350
440
13,000
Over 100,000
-
Oa
Adequate
Alternative Capacity
Available? (Yes/No)
Yes
Yes
Yes
Yes
No
No
The Agency has not found any quantities of mixed radioactive wood preserving waste. However, if any such wastes
exist, commercial capacity that is available must be used for mixed wastes that were regulated in previous LDR
rulemakings and whose variances have already expired
EXHIBIT 1-3
SUMMARY OF NATIONAL CAPACITY VARIANCES
FOR PHASE IV WASTES
Waste Category "
Newly Listed Wood Preserving Wastes
- Organic Nonwastewaters
- Inorganic Nonwastewaters
- Organic Wastewaters
- Inorganic Wastewaters
Soil and Debris Contaminated with Newly Listed
Wood Preserving Wastes
Mixed Radioactive Wood Preserving Waste
Effective Date of
Land Disposal Prohibition
90 Days from Date of Promulgation
Two Years from Date of Promulgation
Two Years from Date of Promulgation
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Chapter 3: Capacity Analysis for Newly Listed Wood Preserving Wastes. Discusses the
methodology and data used to conduct the capacity analysis for newly listed wood preserving
wastes (F032,F034, F035). ' , ' ;
^Chapter 4: .Summary.of Comments and Response to Comments for Newly Listed .
Wood Preserving Wastes. Presents and summarizes the industry comments received for the
proposed rule and the NODA. This chapter also includes EPA's response to the comments.
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CHAPTER2
AVAILABLE TREATMENT CAPACITY
v
This chapter presents EPA's estimates of available commercial treatment capacity for Phase IV
wood preserving wastes. Section 2.1 summarizes the results of EPA's analysis of available commercial
combustion capacity at incinerators and boilers and industrial furnaces (BIFs). Section 2.2 summarizes
the results.of EPA's analysis of the available wastewater treatment capacity. Section 2.3 summarizes the
results of EPA's analysis of the available commercial stabilization capacity. Section 2.4 summarizes
vitrification capacity. Note that other technologies besides those addressed in this chapter that are
capable of achieving UTS are not precluded from being used. Best demonstrated available technology
.(BOAT) for arsenic in F035 wastewaters, for example, is based on vitrification.'yet treatment
.technologies such as stabilization can be used as long as UTS are met (and the treatment does not
constitute impermissible dilution).
2.1 COMMERCIAL COMBUSTION CAPACITY
This section summarizes the results of EPA's analysis of available commercial combustion
capacity at incinerators and BIFs (primarily cement kilns that are authorized to burn hazardous wastes as
fuel). This includes an analysis of incinerator and BIF combustion .capacity information received from
the Hazardous Waste Treatment Council (HWTC) and the Cement Kiln Recycling Coalition (CKRC) in
1993 and the Environmental Technologies Council .(ETC) in 1994.9 Data were also obtained from
Rollins Environmental Services (RES) through comments and subsequent submissions of Confidential
Business Information (CBI) in 1996. ' - ' : '
2.1.1 General Methodology
In 1993, the HWTG and CKRG surveyed their membership to obtain data on combustion :
capacity, which was then submitted to EPA. Subsequent to the original HWTC survey, members also
received a supplemental questionnaire regarding the burning of soils. In 1994, ETC submitted updates to
the HWTC Survey from its members. Survey responses received from incinerators are classified as
confidential business information (CBI) and thus are provided only in an aggregated form in this
document. Following the receipt of the original surveys, the Agency reviewed the data submitted by each
facility to evaluate the completeness, consistency; and accuracy of the information; The Agency
identified and reconciled data gaps and anomalies by contacting the respective HWTC or CKRC
coordinators and the individual facilities in question. , .
Concurrent with the receipt of surveys received from the member groups, the Agency developed
a database to track and process major data elements for the capacity analysis. The database contains
facility information (e.g., location, EPA identification number of burner, number of units currently on-
line), unit specific information (e.g., type of incinerator/kiln unit, operating hours per year, types of
hazardous waste feed systems, types of .hazardous waste burned in 1992), and waste-type specific ..
information (e.g., tons of hazardous waste burned in 1992, average hazardous waste feed rate, maximum
practical capacity, maximum permit capacity). Subsequent updates to the original survey submissions
have also been entered into this database. . .
The information received from facilities participating in these surveys does not lend itself to
simple summation and tabulation of results because facilities sometimes differed in their approach to
9 In 1994, HWTC became the Environmental Technologies Council (ETC). ETC provided EPA with a 1994 update
to the commercial incinerator survey.
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reporting quantities burned or burning capacity. Incineration systems can generally accept multiple
waste forms (e.g., pumpable sludges and aqueous liquids) and accepting larger amounts of one waste
form may reduce the capacities for others. In responding to the HWTC survey (and ETC updates),
facilities sometimes grouped waste types for their capacity-related responses. For example, if a feed
system can accommodate both liquids and pumpable sludges, a facility may report a capacity for both
forms grouped together. To address this interchangeability of waste forms, the Agency's LDR capacity
database accommodated the reported waste groupings (e.g., by developing one capacity estimate for
liquids and pumpable sludges combined).
A second issue also relating to the interchangeability of waste forms required more extensive
consideration. In the HWTC survey (and ETC update), some facilities reported the maximum
combustion capacity for individual waste forms that together exceed the reported overall capacity of the
unit. As a result, summing these individual capacities results in a total capacity that far exceeds what a
facility may practically accommodate. Therefore, the Agency developed an algorithm to address this
situation. The waste apportionment algorithm focuses on three primary variables: the quantity of waste -
burned during the year, the maximum practical capacity of the unit, and the available capacity for
burning hazardous waste. The available capacity for a waste form (e.g., aqueous liquids, dry solids) is
obtained by taking the difference between the quantity of .the form burned (hazardous and non-hazardous
waste) and the maximum capacity for the waste form. The Agency's approach assumes that a facility will
not stop burning non-hazardous waste if it is currently burning non-hazardous waste but all unutilized
capacity will be used for hazardous waste. Difficulties arise, however, because facilities report
maximum capacities for each waste form without regard to capacity accounted for by other waste forms
(e.g"., some facilities report the same treatment capacities for sludges as for soils because their treatment
systems can accommodate both wastes). Consequently, the sum of maximum capacities for all waste
forms may exceed the total capacity.
In these cases, the Agency distributed the total maximum hazardous waste capacities reported by
each facility to individual waste forms based on burning practices. The utilization rate for each waste-
form was calculated by dividing the larger of the quantity of hazardous waste burned or total waste
burned for that waste form by the sum of the quantities burned for all waste forms. A new maximum
hazardous waste capacity for each waste form was then calculated by multiplying the utilization rate for .
that waste form by the maximum practical capacity for the incineration unit as a whole. .
If the calculated maximum capacity for a waste form exceeded the reported value for that form,
EPA used the reported value. In this case, the difference between the calculated and reported value was
then redistributed to other waste forms using a hierarchy based on the types of wastes in this rule for
which capacity has historically been most limited relative to demand. The Agency used the following
order for redistributing capacity:
Soils; .
Bulk Solids;
. Containerized Solids;
Nonpumpable Sludges;
Pumpable Sludges;
. , Compressed Gases;-
. . Non-aqueous'Liquids; and
Aqueous Liquids. _
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Cement kiln capacity for hazardous waste generally is limited by air emission limits (e.g., boiler
and industrial furnace (BIF) limits under 40 CFR 266 subpart H), feed system limitations (e.g., particle
size and viscosity limits), and product (i.e., cement clinker) quality considerations.10 For instance, ~
cement quality considerations may require that wastes burned in cement kilns have a heating value of at
least 5,000 BTU/lb to ensure adequate temperatures in the kiln. (Comments received by EPA in previous
rulemakings, however, indicate that some kilns accept wastes below this heating value.) Incineration
capacity is also limited by air emission limits and other permit limits (such as heat release limits), and
feed system limits. EPA has taken these limitations into account in its estimates of available commercial
combustion capacity. ' ,
"Pre-baseline" (i.e., prior to accounting for Phases I, II, and III LDR required capacity) available
combustion estimates were calculated using the above methodology.11 EPA then-subtracted the required
combustion capacity for any previously regulated wastes that are not accounted for in the data received
from the incinerators or BIFs (e.g., Phase I wastes under variance and Phase II and III wastes) to derive
the baseline available combustion capacity for Phase IV wastes. The capacity required for Phase II and
III wastes is not reflected in the estimates of utilized capacity because the Phase II and III rules,.
promulgated on September 19,1994.(59 FR 47982) and April 8, 1996 (61 FR 15566), respectively, were
not in effect when the estimates were submitted to EPA. In addition, some Phase I wastes. (F037 and
F038 ;in particular) were under a variance for at least part of the period of time for which EPA received
capacity estimates (see 57 FR 37194, June*30, 1992). ..--'
For this final rule, EPA conducted additional analysis by incorporating new data submitted by.
commenters to the proposed rule, developing assumptions to account for the uncertainty associated with
the age of the bulk of the data (which are now several years old), assessing the availability of mobile '
.combustion capacity to address on-site demand for treating contaminated soil arid debris, and assessing
potential trends in combustion capacity over the next two years. Thus, this additional analysis primarily
involved four activities: (1) updating available capacity where possible using facility-specific CBI
'submitted by Rollins Environmental Services (RES); (2) applying assumptions to obtain a bounded range
of overall available capacity; (3) reviewing data on mobile incinerators; and (4) researching potential
impacts of upcoming maximum achievable control technology (MACT) standards. - .
2.1.2 Results . ' " :
Exhibit 2-1 summarizes EPA's estimate of the "pre-basetine" commercial hazardous waste
available capacity by waste form for incinerators and BIFs. The following paragraphs discuss
refinements of these estimates for wood preserving wastes in terms of two types of capacity: (1) liquids,
and (2) pumpable/npnpumpable sludges, solids, and soils. This discussion is organized around these two
, types of capacity because most wastes are assigned to these two types of treatability groups.
to
As discussed later in this section and in Chapter 3, additional limitations are applicable for wood preserving
wastes. . , . .--..'
11 Background Document for Capacity Analysis for Land Disposal Restrictions Phase 11 - Universal Treatment
Standards, and Treatment Standards for. Organic Toxitity Characteristic Wastes and Other Newly Listed Wastes.
Volume 1: Capacity Analysis Methodology ands Results. U.S. EPA. August 1994. '
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Combustion capacity for liquid forms of hazardous wastes has historically been more readily
available than capacity for sludges and solids. 'Using data from Exhibit 2-1, EPA estimates that the pre-
baseline available commercial combustion capacity for liquids is 1,078,000 tons per year.12 EPA then
subtracted the 11,000 tons of capacity required for liquid Phase II wastes. Because Phase III did not
result in any required capacity for liquids, the result1,067,000 tons per yearis assumed to still be
available overall. EPA then refined this estimate for Phase IV wood preserving wastes by using CBI
information from the HWTC/ETC surveys and CKRC about which incinerators have final Part B permits !
to treat hazardous these wastes. That is, because of the dioxin/furan monitoring requirements for interim
status incinerators, EPA assumes that such facilities will not accept Phase IV wood preserving wastes (as
a worse case). This refinement reduces available liquid capacity by 45,896 tons/year to approximately
1,021,104 tons/year. Finally, EPA used CBI to subtract the available "capacity of combustion facilities
that do not yet have, or have not applied for, a modification to their permit to treat Phase IV wood
preserving wastes. This refinement reduces available liquid combustion capacity for Phase IV wood
preserving wastes by approximately 135,565 tons/year to 885,539 tons/year.
, -' EPA used data from Exhibit 2-1 to estimate that the available pumpable/nonpumpable sludge,
solid, and soil commercial combustion capacity in the pre-baselirie (i.e., prior to the Phase I rule ) is
638,000 tons/year.13 Post-Phase I and II (but pre-Phase IV) data obtained from one major treater, RES,
through comments (see Chapter 4) and subsequent submissions of CBI (see Appendix A for non-CBI
meeting minutes), as well as extrapolation of these data to all other combustion data, were used to update
this pre-baseline estimate and to simultaneously account for Phase I and II wastes. The result is
approximately 489,100 tons/year,14 with a range of about 410,400 to 568,600 tons/year.15 For the Phase
III wastes, EPA estimated that the relevant required sludge^ solid, and-soil combustion capacity is 4,600
tons/year. Therefore, the overall current (pre-Phase IV) combustion capacity for sludge, solid, and soil is
estimated at 484,500 tons/year (between about 405,800 to 564,000 tons/year). EPA then adjusted this
estimate by subtracting the 142,800 tons/year of available capacity from BIFs16based on the worst-case
assumptions that the BTU and other characteristics of the wood preserving sludges, solids, and soils will
result in the BIFs refusing the wastesto estimate that approximately 341,700 tons/year of incineration
12 EPA first estimated that there is approximately 1,010,000 tons/year of available capacity for waste forms reported
as "aqueous liquids" (92,000 tons/year), "non-aqueous liquids" (159,000 tons/year),vand "all liquids" (759,000
tons/year). EPA then added to this quantity the estimate of available capacity to'treat "liquid/putnpable sludges"
(i.e., 68,000 tons/year). Because this latter quantity is for mixed forms of waste, it was excluded from the non-liquid
estimate described below to avoid double counting. ,
,13 EPA summed the available capacity for "pumpable sludges" (78,000 tons/year), "nori-pumpable sludges (18,000
tons/year), "solids and non-pumpable sludges" (49,000 tons/year), "bulk solids" .(88,000 tons/year), "dry solids"
(39,000 tons/year), "containerized solids" (208,000 tons/year), and "soils" (157,000 tons/year). ,
14 To calculate this quantity, EPA first developed separate estimates of available combustion capacity for RES
facilities arid non-RES facilities. EPA determined the pre-baseline capacity available at non-RES facilities by
subtracting the pre-baseline combustion at RES facilities from the pre-baseline estimate of national sludge, solid, and
soil combustion available capacity. EPA then subtracted an estimate of the non-RES share of wastes restricted from
land disposal due to the Phase I and n rulemakings. EPA then added this result to the estimated increase in RES
available capacity to estimate the total available capacity for incinerators and BIFs. Because most of this
information is CBI, EPA cannot disclose the details in this document. . .
15 Because of the, age of the data used and the uncertainties of the various assumptions used, EPA developed a "best
estimate" and a range of available combustion capacity values. EPA's best estimate is based on a calculation of the
current percentage of the Phase I and II wastes that RES is combusting. The range was calculated by assuming that
RES is corhbiisting a lesser percentage than the best estimate (lower end), or is burning a greater percentage than the
best estimate (upper end). . . ,
16 This quantity was obtained by estimating the ratio of the pre-baseline quantity of BIF to total
pumpable/nonpumpable sludges, solids, and soil available capacity (i.e., 187,000/638,000 tons/year) and applying it
to the pre-Phase IV available capacity. . , ,.
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2-6
capacity (between about 286,100 to 397,600 tons/year) is available. EPA then refined this estimate
further for Phase IV wood preserving wastes, as it had for the liquid combustion capacity analysis, by
using information from the HWTC/ETC and CKRC surveys about which facilities have final Part B
permits and which combustors will have modified their permits to treat these wastes. Thus, subtracting
the capacity of incinerators that are interim status and will not have modified permits (i.e., 38,366 and
159,634 tons/year, respectively) results in an estimate of 143,700 tons/year (between about 87,600 to
199,100) of available combustion capacity for Phase IV wood preserving sludges, solids, and soils.
Finally, as indicated in Exhibit 2-1, the available combustion capacity for soils is expected to be
substantially less than 87,600 tons/year' (the lower bound for sludges, solids, and soils) since not all
combustion units that accept nonpumpabie/pumpable wastes or solids are expected to accept soils for
treatment. A rough estimate for soils is that approximately 35,800 tons/year of the available capacity is
expected to accept Phase IV wood preserving soils for treatment.I7 This estimate could range from a
lower end of about 21,900 tons/year to an upper end of about 49,775 tons/year.
In an analysis of the mobile incineration industry in 1989, no vendor contacted by the Agency
felt that RCRA wastes are a viable market for mobile incinerators since the length and site specificity of
the permitting process pose a barrier that companies find uneconomic to overcome.18 Recent industry
publications, such as The Hazardous Waste Consultant, indicate that the public continues to oppose
nearly every proposed hazardous waste management facility, and state and local legislative bodies
continue to pass restrictive siting laws or permitting moratoriums. As a result, many project sponsors of
mobile (and stationary) incinerators have already, or may eventually, find the process too costly.19
The estimates discussed above of available combustion capacity are expected to remain relatively
steady or decrease somewhat through 1999. Although one munitions treatment facility is awaiting
approval of its permit to burn military munitions and other explosives, no applications for new hazardous
waste incinerators are immediately pending. Most of the proposals for new combustion capacity that
have surfaced recently are for facilities that specialize in the combustion of military munitions, other
explosive materials, or mixed wastes.20 In addition, several facilities that had proposed expansion of
thermal capacity have now abandoned their proposals. Moreover, difficulties in permitting make it
highly unlikely that other combustion units, such as mobile incineration units, could be brought on-line in
the near-term (i.e., within two years). Lastly, the final maximum achievable control technology (MACT)
standards for combustors (expected in 1998; see proposed rule, 61 FR 17358) may decrease this available
capacity to some degree. However, given the worst-case assumptions used above, EPA does not expect
the MACT standards to significantly reduce the available capacity estimated for Phase IV wood
preserving wastes. . .
17 This estimate is 25 percent of 143,200 ton/year (the best estimate for sludges, solids, and soils). The percentage is
obtained using the pre-baseline available soil capacity of 157,000 tons and the pre-baseline available sludge, solid
and soil capacity of 638,000 tons per year.
18 U.S. EPA. Mobile Incineration: An Analysis of the Industry. February 1989.
19 "Commercial Hazardous Waste Management Facilities: 1997 Survey of North America," The Hazardous Waste
Consultant. March/April 1997.
20 "Commercial Hazardous Waste Management Facilities: 1997 Survey of North America," The Hazardous Waste
Consultant. March/April 1997.
21 Aptus, Inc. (Rollins) of Coffeyville, Kansas; Holnam, Incorporated of Ada, Oklahoma; and Medusa Cement
Company of Clinchfield, Georgia, as described in "Commercial Hazardous Waste Management Facilities: 1997
Survey of North America," The Hazardous Waste Consultant. March/April 1997. Note that the planned expansion
by Aptus, Incorporated, would have added more combustion capacity to the estimates discussed above.
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2-7
2.2 WASTEWATER TREATMENT CAPACITY
This section summarizes the results of EPA's analysis of wastewater treatment systems for
wastewaters covered by the Phase IV rule. The analysis of available capacity used three data sources. '
. The primary source is the set of two BOAT background documents for wood preserving wastewaters.22
Another source is an'Office of Water questionnaire specifically targeted to wastewater treatment systems.
The third source, the 1991 Biennial Reporting System (BRS), was used to confirm the data provided by
the second source. The BRS .is a system by which RCRA-regulated treatment, storage, and disposal
facilities (TSDFs) and large quantity generators provide EPA with information on their hazardous waste
activities. The PS Form of the 1991 BRS contains information on the waste treatment systems, including
both maximum and utilized capacity.
As described in more detail in the BOAT technical background document, most of the .
wastewater treatment effluent data examined from wood preserving sites indicate that UTS are already
being met. Furthermore, in cases where UTS are hot being met, that document describes how prevailing
wastewater treatment practices at wood preserving facilities are either capable of meeting the standard,
by proper optimization, or within the context of a treatability variance under 40 CFR 268.44 (h).
Wastewater treatment technologies such as biological treatment, steam stripping, carbon adsorption, or
combinations of these and other technologies can treat organics regulated in F032 and F034 to the
concentration levels promulgated in this rule. These wastewater technologies are readily available to, or
in use at, wood preserving facilities. For metals in wastewater forms of F032, F034, and F035, EPA has '
determined that treatment levels can be achieved by lime addition followed by sedimentation'and
filtration for arsenic, and on chemical precipitation followed by sedimentation.for chromium. Again,
these wastewater technologies are readily available to, or in use at, wood preserving facilities. F032
wastewaters'can be pretreated and commingled in order to enable their treatment via biological treatment
systems. For instance, it is common practice to commingle wastewater and to remove total suspended
solids, oil suspensions, and other colloids and suspended species to ensure the amenability of these waste
streams to biological treatment. In addition, the BOAT document indicates that activated carbon
adsorption is used widely for the remediation of surface and grouridwaters contaminated with chemicals
in wood preserving wastes and has been shown to reduce the levels of dioxins/furans in wastewater
effluents.from biological treatment units. These practices are common at wood preserving facilities. Of
course; since no specific method of treatment is required to be used under the promulgated treatment
standards, any type of treatment other than impermissible dilution may be used to achieve these
concentration levels. , . . ,
Notwithstanding the ability .of readily available treatment systems to be optimized to meet
treatment standards, EPA also evaluated the availability of wastewater treatment in terms of actual
quantities. In 1991, EPA's Office of Water (OW) developed-the Waste Treatment Industry Questionnaire
to collect information on centralized wastewater treatment capacity.23 The information collected during.
this effort represents 1989 data and includes maximum and available treatment capacity. Exhibit 2-2
presents the information provided by individual facilities. All of the listed facilities have a final or
interim RGRA permit. As shown, approximately 40 million torts (9.7 billion gallons) of wastewater
treatment capacity are available each year at these facilities. In addition, there are 11 other treatment
" facilities that were not included in this estimate because they did not supply the requested capacity.
information. By assigning die average available capacity (638,000 tons/year) to each of the non-
22 These two documents are,the BDAT technical background document and the BOAT response to comment
document in the docket for today's rule.
23 Memorandum,from Debra DiCianna, Engineering and Analysis Division, Office of Water, U.S. EPA to Bengie
Carroll, Capacity Programs Branch, Office of Solid Waste, U.S. EPA, April 20, 1993. See Appendix B.
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2-8
reporting facilities, EPA estimates a total available wastewater treatment capacity of more than 47
million tons each year. According to data collected for the Third Third Rulemaking, this capacity is in
the form of many different types of treatment.24 . :
'
EXHIBIT2-2
AVAILABLE WASTEWATER TREATMENT CAPACITY
Name
Sloss Industries Corporation
Crosby and Overtoil, Inc.
Oil Process Co.
Southern California Chemical Co., Inc.
Romic Chem. Corp.
CPChemicals
Chem-Tech Systems
H&H Ship Service
Norris Industries, Inc.
Appropriate Technologies II, Inc.
Solvent Service Co., Inc.
American Chemical & Refining Co.
En virite .Corporation (CT)
Pratt & Whitney Aircraft Group MD & CPD.
United Oil Recovery, Inc.
Cecos Treatment Corp.
Environmental Waste Resources, Inc.
Alternate Energy Resources, Inc.
Pearl Hbr. Navy Public Works Or. :
Maytag Co.
John Deere-Component Works .
Envirite Corp. (TL)
Peoria Disposal Co.-Pottstown
Chem-aear, Inc.
Beaver Oil Co., Inc.
EPA ID Number
CADO5O806850
CAT080033681 "
CAD059494310
CTD001 184894
CTD000844399
CTD072138969
/
ILD000666206
' '
ILD064418353
Maximum Capacity
(gallons)
548,000,000
2,340,000
1,894,000
, 21,350,000
4,983,000
5,808,000
, . °
0
477,791,000
8,943,000
0
2,375,000
53,500,000
1,760,669,000
13,140,000
62,500,000
38,536,000
1,867,200,000
0
390,000,000
43,212,000
'10,620,000
50,000,000
36,000,000
14,000,000
% Used in
1989
33
100
81
60
59
' 74
0
0
' 45
18
0
79
30
2
50
6
78
20
0
73
63
67
49
47
.20
Available Capacity
(gallons)
367,160,000
0
363,000
8,589,000
' 2,043,000
. 1,510,000
0
0
262,355,000
7,333,000
0
499,000
37,552,000
1,312,578,000
6,570,000
,58.738,000
8,478,000
1,493,387,000
0
105,300,000
" 15,989,000
3316,000
25,625,000
19,080,000
11,200,000
24 Background Document for Third Third Wastes to Support 40 CFRPart 268 Land Disposal Restrictions, May
1990, and Background Document for Capacity Analysis for Newly Listed Wastes and Hazardous Debris to Support
40 CFR 268 Land Disposal Restrictions, June 1992.
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2-9
EXHIBIT 2-2
AVAILABLE WASTEWATER TREATMENT CAPACITY
Name
Heritage Environmental Services, Inc.
Eli Lilly & Co. Tippecanoe Labs
Clean Harbors, Inc. , ,
American Waste Oil Corp.
Environmental Waste Control, Inc
Cyanokem
Dynecol, Inc.
Edwards Oil Co. -
Metro Recovery Systems
Heritage Environmental Services, Inc
Brunswick Corp.
Dupont E I De Nemours, Chamber Works.
CP Chemicals, Inc.
Remtech Environmental Group
Chemical Waste Management of New Jersey
Eticam
Chemical Waste Management of New York
Cecos International ' \
Chemical Management, Inc.
Envirite Corp.
Clark Processing, Inc. '
Research Oil Co.
Brush Wellman, Inc.
Cecos International, Inc.,
Clean Harbors ,
Conoco, Inc. Ponca City
US Pollution Control, Inc.
Tektronix, Inc. '
Waste Conversion, Inc.
Envirite Corporation (PA)
EPA ID Number
IND093219012
IND006050967
MDD980555189
- -
MND98 1098478
NCD121700777
NED043534635
NJD002385730
NJD002141950
NJD089216790
NVD980895338
NYD080336241
NYD000691949
OHD004178612.
OHD087433744
OHD000724153
OKD007233836
ORD009020231
PAD085690592
PAD010154045 '
Maximum Capacity
, (gallons).
299,290,000
0
'44,100,000
6,240,000
60,000,000
30,865,000
36,320,000
21,600,000
15,130,000
7,500,000
244,000
14,600,000,000
54,000,000
o
, 52,560,000
750,000
21,024,000
0
7,800,000
63,963,000
, 6,500,000
86,300,000
- 0
23,400,000
. 63,000,000
720,000,000
'6,000,000
407,788,000
35,986,000
30,000,000
% Used in
1989
30
, ;0
- 12
80
30
'34
50
80
50
72
3
, 78
90
0
23
14
' 73
o
44
44
86
'49
0
12
' 65
92
50
13
80
79
Available Capacity
(gallons)
209,443,000
0
38,808,000
1,248,000
- 42,000,000
20,371,000
18,291,000
4,320,000
7,565,000
' . . 2,100,000
. . - 237,000
3,212,000,000
5,400,000
0
40,471,000
647,000
5,676,000
6
4,368,000
35,909,000
910,000
44,013,000
0
20,592,000
22,050,000
57,600,000
3,000,000
353,675,000
7,197,000
6,300,000
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2-10
EXHIBIT 2-2
AVAILABLE WASTEWATER TREATMENT CAPACITY
Name
Mill Service, Inc.
Mill Service, Inc. Yukon Pit.
Eticam
CP Chemicals, Inc.
Tricil Environmental Services, Inc.
TN Eastman Div. Eastman Kodak
Osco Incorporated
Intercontinental Terminals Co. . '
Encycle/Texas, Inc.
Empac, Inc. Deer Park
Treatment One, Div. of Set Environmental, Inc.
Belpar Environmental of Virginia, Inc.
Boeing Co.- Auburn
Crosby and Overton, Inc. Plant 2
Chemical Processors^ Inc. .
Chemical Processors, Inc.
Chemical Processors, Inc.
Petroleum Reclaiming Service, Inc.
Northwest Enviroservice, Inc.
Union Carbide AGR. Prod. Co., Inc.
Inco Alloys International, Inc.
Total
EPA ED Number
PAD059087072
RID980906986
TND003376928
WAD041337130
WVD004325353
WVD076826015
Maximum Capacity
. (gallons)
74,200,000
164,000,000
6,000,000
45,602,000
89,712,000
8,710,000
0
100.000,000
120,500,000
316,411,000
2,000,000
390,000
371,935,000
20,752,000
13,142,000
0
17,001,000
15,750,000
35,640,000
2,102.000,000
0
25,616,967,000
% Used in
1989
57
44
. -42
61
9
88
0
17
30
' 35
' 2
. 70
42
1
40
0
41
11
62
57
0
Available Capacity
(gallons)
32,129,000
91,840,000
3,480,000
17,785,000
81,638,000
1,045,000
0
; 83,000,000
84,892,000
205,636,000
1,960,000
117,000
214,123,000
20,646,000
7,830,000
0
10,102,000
14,018,000
13,458,000
903,860,000
0
9,699,612,000
. EPA used the 1991 BRS to confirm available wastewater treatment capacity (see Appendix B).
The BRS is a system by which RCRA-regulated treatment, storage, and disposal facilities (TSDFs) and
large quantity generators provide EPA with information on their hazardous waste activities. The PS
Form of the 1991 BRS contains information on the waste treatment systems, including both maximum
and utilized capacity. EPA determined the total available wastewater treatment capacity25 reported in the
BRS at facilities representing approximately 90 percent of the total operational capacity reported in the
Waste Treatment Industry Questionnaire. According to the BRS, in total these facilities have 33 million
tons of available capacity (7.9 billion gallons). If this estimate is adjusted to reflect the fact that it only
' 25
Specifically, the estimate includes all aqueous organic and/or inorganic treatment systems.
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2-11
represents 90 percent of the total operational capacity, approximately 37 million tons (33 million tons
divided by 0.9) of available wastewater treatment capacity are available. This estimate is close to 80
percent of the estimate obtained from the OW Questionnaire. , .>'-...
2.3 STABILIZATION CAPACITY ,.
Stabilization is a primary conventional commercial treatment technology for some of the wood
preserving wastes restricted from land disposal due to. the Phase IV LDRs: In analyzing alternative
treatment capacity for stabilization, the Agency in part built on the capacity analysis conducted for the
Third Third LDR rule (55 FR 22520, June 1, i990). That analysis was based on data contained in the-
May 1990.TSDR Capacity Data Set. The TSDR Capacity Data Set contains results from the National
Survey of Hazardous Waste Treatment, Storage, Disposal and Recycling Survey (the TSDR Survey).
The TSDR Survey was administered in 1987 to 2,500 facilities arid was designed to provide
comprehensive information on current and planned hazardous waste management, and practices at
RCRA-permitted and interim status treatment, storage, recycling, and disposal facilities. The TSDR
Survey collected projections of capacity changes from 1986 through 1992. The TSDR Capacity Data Set
includes the amount of hazardous and nonhazardous waste entering each treatment system in 1986, the
maximum hazardous waste capacity, and the maximum total waste capacity.
Following the original TSDR Survey, EPA updated the TSDR Capacity Data Set for critical
technologies based on .confirmation of planned capacity changes, arid other information received since
the survey (e.g., comments on proposed rules). Updated information was obtained by contacting
facilities and verifying critical projected capacities reported in the TSDR Capacity Data Set. Based on .
the information provided by facility contacts, EPA determined whether planned facility capacity had
come on line as projected. Furthermore, EPA verified various assumptions concerning treatment for the
wastes addressed in this proposed rule. (For a more detailed explanation of the TSDR Survey and trie
Third Third Rule, refer to U:S. EPA, Background Document for Third Third Wastes to Support 40 CFR
Part 268 Land Disposal Restrictions, May 1990, in the docket for the Third Third rule.).
To estimate the stabilization capacity available for Phase IV wood preserving wastes, the
capacity demand for previous LDR rules was subtracted from the available stabilization capacity
estimated from the TSDR Capacity Data Set. The available stabilization capacity from the TSDR Survey
and updates was 3,125,000 tons/year. EPA estimated in the Third .Third rulemaking that the capacity
required as a result of the Third Third and previous LDR rules was 1,921,000 tons/year. Furthermore,
the capacity required for Phase-I was 77,000 tons/year, was 0 tons/year for Phase II wastes.^and was 0
for Phase in wastes.27 Thus, EPA estimates the stabilization capacity available for Phase IV wastes to be
1,127,000 tons/year. Furthermore, as with wastewater treatment capacity, stabilization can be readily.
optimized to meet to meet UTS and can be quickly increased; see Appendix C (developed primarily for
the TC metal and mineral processing capacity analysis ) for additional detail on this topic. -
2.4 VITRIFICATION CAPACITY
The Agency has determined that vitrification technology is commercially available for treating
limited quantities of Phase IV wastes, such as some arsenic wastes, that are difficult to treat using
26 EPA believes that stabilization may be required to treat underlying hazardous metal constituents in some Phase II
organic TC wastes after combustion but that the actual amount requiring capacity is a small fraction of available . .
capacity. , . % ,..''
27 EPA believes that stabilization may be required to treat underlying hazardous metal constituents in Phase III
wastes after combustion, but that the actual amount requiring capacity is a small fraction of available capacity.
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2-12
stabilization. One commenter (Beazer East, Inc.), responding to the original Phase IV proposed rule (60
FR 43654), identified a commercial vitrification facility that may have some available capacity.28 Using
the ATTIC and VISIT databases,29 EPA also identified a sample of companies conducting or providing
supplies for vitrification and subsequently held discussions with several facility representatives (see
. Appendix D).30 One company EPA identified operates one vitrification system with an available
capacity of 15,000 tons/year (readily expandable to three systems for a total capacity of 45,000
tons/year). A full-scale, commercial unit (ME in Butte, Montana) treats approximately 2,000 tons/year.
Bench-scale and pilot-scale systems for vitrification are known to have been underway at numerous other
facilities ,in 1994.31
Notwithstanding this potentially available vitrification capacity, EPA realizes that available
capacity is relatively low. Because EPA is setting numerical limits, however, other treatment
technologies capable of achieving the UST limits are not prohibited from being used, except for those
that may constitute impermissible dilution. For example, the lower concentration arsenic wood
preserving wastes can be readily treated using stabilization or other treatment technologies.3
28 Marine Shale-Processors (MSP) uses vitritification in a tested, full-scale process. The commenter also notes,
however, that MSP's regulatory status remains in question.
29 Alternative Technology Treatment Center (ATTIC) Database, U.S. EPA. (see WWW.EPA.GOV/ATTIC) and the
Vendors Information System of Innovative Treatment Technology (VISITT) (see
WWW.PRC.EMI.COM:80/VISnT).
3° As seen in the Appendix, the following is a small sample of commercial vendors providing vitrification equipment
or services: Geosafe Corp, Vortec Corp, Retech Inc., GTS of Duratech, and MSB.
31 Attachment to memorandum from Bill Kline (U.S. EPA) to ICF Incorporated, March 17,1994 (see Appendix D).
32 See Section 2.3 in this document and Appendix C in the Phase IV LDR BOAT Background Document for
additional discussion.
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CHAPTERS
CAPACITY ANALYSIS FOR NEWLY LISTED WOOD PRESERVING WASTES
3.1 INTRODUCTION
f
This chapter presents the capacity analysis for the newly listed wood preserving wastes F032,
F034, and F035. Specifically, this chapter presents the data and methodology used to derive estimates of
the quantities of F032, F034, and F035 that require alternative treatment capacity prior to land disposal '
as a result of the proposed LDRs. . /. ;
3.1.1 Regulatory History ' . ~
Section 300 l(e) of the Resource Conservation and Recovery Act (RCRA) requires EPA to
determine whether to list wastes containing chlorinated dioxins and chlorinated dibenzofurans. As part
of this mandate, the Agency conducted a listing investigation of dioxin-containing wastes from
pentachlorophenol wood preserving processes and pehtachloro-phenate surface, protection processes. In
addition, EPA included two other similar wood preserving processes using creosote and aqueous
inorganic formulations containing chromium or arsenic in this investigation. ' .
f
On December 8,1988, EPA proposed four listings for wastes from wood preserving and surface
protection, as well as a set of standards for the management of these wastes (53 FR 53282). The Agency
finalized three of these listings as well as Subpart W standards for the management of these wastes on
drip pads on December 6, 1990 ,(55 FR 5450).33 On October 24, 1991 (56 FR 55160) EPA stated its
intentions to establish LDR treatment standards for these three newly listed wood preserving wastes. On
August 22, 1995 (60 FR 43654), EPA proposed treatment standards for these wastes and, based on a
preliminary capacity analysis, proposed to grant a two-year variance from these standards only for soil
and debris contaminated .with the newly identified wood preserving wastes.34 In addition, on May 10,
1996 (61 FR 21418) EPA published a Notice of Data Availability (NODA) which identifies additional ,
treatment standard options for F032 wood preserving wastes. Today's rule establishes final treatment
standards for the newly listed wood preserving wastes and establishes the effective date of such standards',
'based on EPA's capacity analysis.
3.1.2 Wood Preserving Listings ,
t "V " "..--.
The wood preserving listings categorize the waste streams into waste codes based on the
preservative used and type of process: , ' . . , :
F032: Wastewaters (except those that have not come into contact with process contaminants),
process residuals, preservative drippage,.and spent formulations from wood preserving processes
generated at plants that currently use or have previously used chlorophenolic formulations (except
potentially cross-contaminated wastes that have-had the F032 waste code deleted in accordance with
section 261.35 or potentially cross-contaminated wastes that are currently.regulated as hazardous wastes
(i.e., F034 or F035), and where the generator does not resume or initiate use of chlorophenolic .
'formulations). This listing does not include K001 bottom'sediment sludge from the treatment of
wastewater from wood preserving processes that use creosote and/or pentachlorophenol.
33
Although the Agency originally proposed to list one additional waste stream (F033), the Agency did not include
that waste in the final rule. - '- . . . '
34 EPA determined that there was adequate treatment capacity available for all other newly listed wood preserving
wastes, and therefore proposed not to grant any capacity variances for these wastes. . \
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3-2
F034: Wastewaters (except those that have not come into contact with process contaminants),
process residuals, preservative drippage, and spent formulations from wood preserving processes
generated at plants that use creosote formulations. This listing does not include K001 bottom sediment
sludge from the treatment of wastewater from wood preserving processes that use creosote and/or
pentachlorophenol. ." . ''"--'
F035: Wastewaters (except those that have not come into contact with process contaminants);
process residuals, preservative drippage, and spent formulations from wood preserving processes
generated at plants that use inorganic preservatives containing arsenic or chromium. This listing does not
includes K001 bottom sediment sludge from the treatment of wastewater from wood preserving processes
that use creosote and/or pentachlorophenol.
3.2 DATA SOURCES
EPA has collected information, on wood preserving wastes, including contaminated soil and
debris, to support both the listing rule and the proposed LDRs. The primary data sources used in this .
capacity analysis are described below.
3.2.1 Biennial Reporting System (BRS) ' ~
The 1993 BRS provides information.on waste generation and management practices at the
individual waste stream and facility level. The BRS is a system by which RCRA-regulated treatment,
storage, and disposal facilities (TSDFs) and large quantity, generators provide EPA with information on
their hazardous waste activities. The BRS contains information on the waste streams generated on site
and received from off site, waste physical form, waste codes, waste quantity, and the treatment systems
used to treat .each hazardous waste stream. Data from the BRS is included in Appendix F.
3.2.2 Wood Preserving RIA
A regulatory impact analysis (RIA) was prepared on November 1990 for the listing of F032,
F034, and F035 wood preserving wastes. The RIA examined the costs, economic impacts, and benefits
of listing the wastes as hazardous. Information on wood preserving facilities and waste characteristics
was obtained primarily from two sources: facility and production data from an industry consultant and
waste characteristics data from a RCRA 300? Survey. ,
The primary source of information used in the RIA to determine the number of wood preserving
facilities and their characteristics, and current production was a 1989 report developed by James T.
Micklewright that contains the names and addresses of all wood preserving plants in the U.S.,
information about their production processed, and summary statistics on the wood preserving industry in
1987. This report is issued annually and the Agency has used information from the most recent report to
adjust the estimates developed for the 1990 RIA. '
The 1990 Micklewright report identified 543 wood treating plants in operation in 1990, 534
pressure treating plants and 9 non-pressure treaters. Based on production reports for 431 plants and
estimates of production by 112 non-reporting plants, Micklewright estimated that the industry treated
585.6 million cubic feet of wood products in 1990. .
According to the RIA, the majority of pressure-treating plants (87.7 percent) used only one type
of preservative: 76.4 percent treated with an inorganic preservative,'almost all of which contained
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3-3
arsenic; 7.7 percent treated with creosote; and 3.6 percent used pentachlorophenol. .The remaining 12.3
percent used more than one type of preservative. These plants may generate more than one of the three
newly listed wood preserving wastes. ', . > ,
The primary source of data used in the RIA to assess waste generation at wood preserving . , .
facilities was a RCRA 3007 Survey conducted by EPA in 1985. This survey .was used to gather
information about 1984 treated wood production volumes, production processes, waste generation, waste
characteristics, and waste management practices. Questionnaires were mailed to the 100 wood
preserving plants listed in Micklewright's 1981 industry survey. EPA received responses from 85
facilities (81 pressure plants and 4 non-pressure plants) which together generated 6.28 million tons
(221.5 million ft3) of treated wood. The facilities responding represented 15 percent of the total number
sof identified active plants in 1984 and 44.5 percent of the total production of treated wood in 1984.
' * ' '
3.2.3 1994 Micklewright Report
EPA obtained the 1994 Micklewright report entitled Wood Preservation Statistics, 1993 from the
American Wood Preserving Association. This report provides information on key changes in waste
generation and management practices relative to previously reported data.
According to this report, 352 companies operate a total of 471 active plants in the wood
preservation industry in the United States. .Of the active plants, two are.nbn-pressure treaters. Thus,
there are 469 pressure treaters nationwide. More than half of the pressure-treating facilities are small,
single cylinder operations. ' . . ,
t ,
Among the treated products are crossties, switch and bridge ties, poles, crossarms, pilings, fence
posts, lumber, timbers, and plywood. Preservatives used to treat these products include creosote
solutions, chlorophenolic (oilborne) preservatives, inorganic (waterborne) preservatives, and fire
retardants. - . . ~ .
' Creosote solutions include creosote, creosote-coal tar, and creosote petroleum. Processes
, , that use creosote solutions generate F034 wastes. s
Oilbome preservatives include pentachlorophenol, copper naphthenate, zinc naphthenate,'
. " and copper-8-quinblinolate. Use of these preservatives results in the generation of F032
wastes. . ' '.'-
* * t
^ ' .'
Waterborne preservatives are inorganic formulations containing chromium and arsenic.
. Processes that use these preservatives generate F035 wastes.
Fifty plants use various combinations of two or more preservatives. Exhibit 3-1 provides the
number of pressure-treating facilities by type of preservative.
' As shown in Exhibit 3-1, the majority of plants use only inorganic preservatives. Furthermore,
the greatest volume of wood is.treated with inorganic preservatives. Exhibit 3-2 provides data on the
volume of wood treated by each type of preservative in 1993.
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EXHIBIT 3-1
WOOD PRESERVING PLANTS BY TYPE OF PRESERVATIVE, 1993
Preservative
Inorganic
Creosotes ' v
Pentachlorophenol
Mixed
Waste Code
F035
F034
F032
Combinations of
F032, F034, F035
Total
Number of Plants
362 .
40
19
50
471
EXHIBITS-!
VOLUME OF WOOD TREATED BY TYPE OF PRESERVATIVE, 1993
Preservative
Inorganic
Creosotes
Pentachlorophenol
Waste Code
F035
F034
F032
Wood Treated
(1,000 cubic feet)
470,504
92,132
36,155
3.2.4 ANPRM Comments
The October 24,199tl Advanced Notice of Proposed Rulemaking (ANPRM) (56 FR 55160)
identified EPA's data requirements for conducting a capacity analysis for wood preserving wastes. EPA
requested comments and information on the quantities and characteristics of F032, F034, and F035 that
are generated and managed, as well as on hazardous soil and debris contaminated with these wastes.
EPA also requested information concerning available or potential treatment technologies, their capacity,
performance, and limitations or constraints. The Agency received seven comments regarding wood
preserving wastes. These comments have been incorporated into the final capacity analysis. A list of the
commenters, the major issues addressed in the comment, and any data submitted in the comment can be
found in Exhibit E-l of Appendix E. . .
3.2.5 Comments to the Phase IV Proposed Rule and Notice of Data Availability
In response to the August 22,1995 proposed rule for the Land Disposal Restrictions -.Phase IV:
Issues Associated with Clean Water Act Treatment Equivalency, and Treatment Standards for Wood
Preserving Wastes and Toxicity Characteristic. Metal Wastes (60 FR 43654)'and the May 10,1996
Notice of Data Availability, EPA received a number of comments on the proposed wood preserving
treatment standards. These comments have been incorporated into the final capacity analysis. Please
refer to Chapter 4 of this document for a detailed discussion of these comments as well as the Agency's
response. .
3.2.6 Phone Logs, Communications, and Clarifications of Comments Submitted
During the development of the Phase TV Rule, EPA conducted communications with
representatives from industry and the EPA Regions to gather relevant data for the wood preserving waste
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3-5
capacity analysis. These comments have been incorporated into the final capacity analysis and can be
found in Appendix F. .
3.3 WASTE GENERATION AND MANAGEMENT
' "
3.3.1 Waste Generation .
"- ' ',
As described in the listing, F032 wastes are generated from wood preserving processes that use
. chlorophenolic formulations (such as pentachlorophenol and tetrachlorophenol) or from facilities that
have used chlorophenolic formulations, even though they may currently be using other preservatives.35
F034 wastes are gerierated.by facilities that use creosote in their wood preserving formulations. F035
wastes are generated by facilities that use inorganic formulations. Wastes that are generated as a result
of using mixed chlprophenolic/inorganic formulations or chlorophenolic/creosote formulations carry
more than one waste code. For the purposes of this analysis, wastes that carry the F032 waste code will
be classified as F032 wastes, regardless of the other waste codes they may carry. 'Similarly, wastes
generated from mixed creosote/inorganic formulations (i.e., wastes that carry both the.F034 and F035.
codes) will be classified as F034 wastes. - . <
However, the-Agency has proposed a redefinition of F032 wastes that would exclude from the
definition any wastes that carried the F034 and F035 waste codes. According to the BRS, several
facilities generate F032/F034 and F032/F035 wastes. Therefore, this redefinition, if finalized, could
potentially shift quantities away from F032 to F034 and F035. . ' s "
i
,For this capacity analysis, the 1993 BRS was used as the primary source of information on the
generation of the newly listed wood preserving wastes. EPA's methodology for determining the quantity
of newly listed wood preserving wastes generated annually is,described below. ]
First, EPA extracted from the 1993 BRS all waste streams that contained at least one of the
newly listed wood preserving waste codes (F032, F034, or F035). ' <
Next, using the waste form information provided by. the BRS, EPA determined whether each
waste stream was organic or inorganic, and the form of each waste stream (wastewater37,
nonwastewater, soil, or debris). ' . . , '
Wastes were then classified based on the combination of wood preserving waste codes each
stream carried. If the waste stream only carried a single wood preserving waste code, it was t
classified as that code. If the waste carried F032 in addition to another code, it was
considered an F032 waste. If the waste carried both the F034 and F035 codes, it was
classified as an F034 waste. ' .
. Any waste stream that contained a newly listed wood preserving waste code as well as a .
listed waste generated by an industry other than the wood preserving industry (as indicated
by the.waste code description) was classified as a mixed listed waste, and excluded from the
generation estimate.
38
35 40 CFR 261.35 provides an exemption from this definition for facilities that no longer use chlorophenolic
formulations and meet certain management requirements. . '
36 December 5,1991,56 FR 63848. . , ''.".'
37 Because there is no direct way of identifying liquid wastewaters from liquid non wastewaters using BRS data; EPA
assumed that all liquid wastes (i.e., wastes with the form code B1XX or B2XX) were wastewaters.
38 For.example, waste streams containing F037 and F038 wastes (sludges from the treatment of petroleum refining
wastewaters) as well as F034 wastes were classified as mixed listed wastes. EPA believes that mixed listed wastes
cannot represent primary generation of wood preserving wastes. In performing its capacity analyses, EPA only
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3-6
Next, EPA eliminated several streams from its generation estimate that EPA identified as
-non-primary generation based on the generator of the waste.39 For example, EPA deleted
waste streams generated by facilities such as DuPont Chambersworks and USPCI that carried
many other waste codes in addition to the wood preserving wastes codes. In deleting such
streams, the Agency relied on professional judgment.
Finally, to ensure that the analysis did not double-count waste streams, EPA eliminated
streams with an origin code indicating that the stream .was received from off site but not
. managed on site.40 . . . .
To determine waste generation, EPA then summed all remaining waste streams by waste
code classification; waste form, and organic/inorganic classification.41
/ '
. Exhibit 3-3 presents the quantities of waste generated, by waste code, according to the BRS.
(Detailed BRS results are presented in Appendix G.) These estimates are slightly lower than the
estimates provided in the proposed rule background document. This is due to EPA's refinement of the
methodology for eliminating non-primary streams from the generation estimate. However, this
information is subject to several limitations. First, the BRS may not include all generators of these
wastes, because small quantity generators are not required to complete the survey. Second, newly listed
wood preserving wastes that are recycled and are exempt from regulation as a hazardous waste are not
included in the BRS. Third, wastes that are generated as the result of treatment or recycling of a newly
listed wood preserving waste (i.e;, wastes that are derived from F032; F034, or F035) will be reported in
the BRS, so the estimates may include non-primary generation. Finally, the'data are for 1993 and may
not reflect changes in waste generation and management that have occurred since 1993.42
Given the limitations of the BRS data, EPA also estimated the generation of newly listed wood
preserving wastes using a second methodology. Using the 1985 RCRA §3007 Survey data, the listing
RIA derived average waste generation rates for each waste stream in terms of cubic meter of wood
treated. EPA used these waste generation rates in conjunction with the total volume of wood treated with
each
includes primary waste streams in its estimate of waste generation. Non-primary waste streams (e.g., treatment
residuals) are not included in the estimate of waste generation. However, in looking at the required treatment
capacity for a waste stream, EPA does consider the entire* treatment train. If the treatment residuals from the initial
step of post-regulatory treatment train will require additional treatment to meet the LDRs, EPA considers the
capacity required for both the initial treatment as well as the additional treatment. For example, if the treatment train
for a waste stream is combustion followed by.stabilization of the ash, EPA estimates both the required incineration
capacity for the primary waste stream as well as the required stabilization capacity for the treatment residual.
39 In general, EPA does not include treatment residuals in the estimate of waste generation because if management
practices change as a result of the LDRs, such residuals will no longer be generated. Also, in many cases treatment
residuals already meet the LDR standards. If the post-regulatory management practices will generate residuals that
require additional treatment, EPA will account for the treatment of these residuals in the estimate of required
capacity. .
40 Waste streams that are sent to a transfer facility and then sent to a hazardous waste management facility should.be
reported in the BRS twice, once by the facility generating the waste and once by the facility transferring the waste.
To avoid double-counting, waste with an origin code of 4 (indicating that the waste was received from off site and
not managed on site) were eliminated.
41 Because treatment standards for the newly listed waste streams depend on whether the stream contains organic or
inorganic constituents, waste streams are classified as either organic or inorganic.
42 The 199S BRS will not be available until the summer of 1997, and thus could not be used for this analysis.
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EXHIBIT 3-3
1993 GENERATION OF NEWLY LISTED WOOD PRESERVING WASTES
Waste Type
F032
Organic Nonwastewater
Inorganic Nonwastewater
Organic Wastewater
. Inorganic Wastewater
Soil .. -. ,
Debris
F034
F035
Total
Organic Nonwastewater
Inorganic -Nonwastewater
Organic-Wastewater
Inorganic Wastewater
Soil
Debris
Organic Nonwastewater
Inorganic Nonwastewater
Organic Wastewater
Inorganic Wastewater
Soil
Debris
Organic Nonwastewater
' Inorganic Nonwastewater
Organic Wastewater
Inorganic Wastewater
- Soil
Debris .
Quantity Generated (Tons)
7,333
10,246
25,872;
'129,766,
10,472'.
11
2,139
14
31,707
2,568,030'
9,448"
3
600
1,900
3,400
9,772
2,700
, '0
9,500
/ 11,000
58,000,
2,700,000
22,000
'14.0
Source: 1993 Biennial Reporting System, July 1995 version. Totals may not sum due to rounding.
preservative type in 1993 to estimate the quantities of wood preserving wastes generated. Exhibit 3-4
presents these estimates. However, these estimates do not correspond directly to waste codes, since the
determination of which code a waste stream carries depends on the type of preservatives used at a
particular facility! Nevertheless, even when summing the total amount of waste presented in Exhibit 3-4,
the quantity of waste generated is less than the quantity of waste estimated to be generated by the BRS.
For the capacity analysis, EPA estimated the quantity of wood preserving wastes generated based
on the BRS data rather than using the RIA and Micklewright data because the BRS also, provides ' .
information regarding the management of wastes, as described in the next section. Also, EPA assumed
that
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- 3-8
EXHIBIT 3-4
GENERATION OF WOOD PRESERVING WASTES USING
RIA AND MICKLEWRIGHT DATA
Type of
Preservative
Inorganic
Creosote
PCP
Total
Quantity of
Wood Treated
(Cubic feet)
470,504,000
92,132,000
36,155,000
598,791,000
Generation Rates
(Tons/cubic feet)
Wastewater
0
0.004333
0.004333
Residuals
0.000003
0.000017
0.000027 .
Quantity Generated
(Tons)
Wastewater
0
399,000 , .
157,000
556,000
Residuals
1,400
1,500
960
3,900
Totals may not sum-due to rounding.
Sources -..Regulatory Impact Analysis for the Final Listing of Certain Wood Preserving Wastes, December 1990 and
Wood Preserving Statistics, 1993 ,
all waste transferred to other facilities or reported as managed in unidentified system types would require
alternative treatment.43 These estimates are different from the estimates provided in the proposed rule
due to refinements in EPA's methodology for identifying non-primary generation and the worst-case
assumption that wastes managed in unidentified system types will require alternative treatment.
3.3.2 Waste Management
. * ' '
The 1993 BRS provides information on waste management, as well as information of waste
generation. The wood preserving RIA and the 1994 Micklewright Report did not provide sufficient
information on waste management practice. EPA estimated the quantity of waste requiring additional
capacity, assuming that all waste currently land disposed (i.e., where the BRS management system type
was landfill, land treatment, surface impoundment, deepwell injection, or other disposal) would require
treatment, and that all wastes already treated would not require additional treatment. Exhibit 3-5 presents
these estimates. In calculating these quantities, EPA assumed that waste that was currently being treated
would not require any additional treatment in order to meet the treatment standards.
As discussed further in Section 3.6, EPA is assigning wastewaters and nonwastewaters
contaminated with the newly listed organic wood preserving wastes to combustion, which will produce
treatment residuals that may require treatment prior to land disposal. These residuals include air
pollution control scrubber waters, wastewater treatment sludge, and incinerator ash. In the capacity
analysis of the First Third LDR rule (53 PR 31138) and several subsequent LDR rules, EPA determined
that facilities considered their ability to treat scrubber water on site when reporting the capacity of their
incinerators. As a result, EPA does not estimate the quantity of scrubber wasters that may require
alternative treatment capacity. EPA, however, augmented the estimated volumes of wastewaters and
nonwastewaters contaminated with wood preserving wastes by the residual volume of incinerator ash and
scrubber water treatment sludge. As discussed in the capacity analysis for the First Third rule, EPA
assumed that the
43 Given the manner in which transfers are reported, it,is not always possible to identify how transferred wastes are
managed. Therefore, as a worst-case scenario, EPA has assumed that all transferred wastes require additional
treatment to meet the LDRs. However, the quantity of waste transferred is not significant.
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EXHIBIT 3-5
QUANTITY OF NEWLY LISTED WOOD PRESERVING WASTES
REQUIRING ALTERNATIVE TREATMENT CAPACITY IN 1993
~ A "-»*Jv» f.aoac
F032
F034
Waste Type
Organic Nonwastewater
Inorganic Nonwastewater
Organic Wastewater
Inorganic Wastewater
Soil* ''.. .
Debris^
Organic Nonwastewater
Inorganic Nonwastewater
Organic Wastewater"
Inorganic Wastewater
Soil'
Debris'
Organic Nonwastewater
Inorganic Nonwastewater
Organic Wastewater
Inorganic Wastewater
, Soil'
Debris'
Quantity Requiring Alternative Capacity
(tons/Year) '
Total
Organic Nonwastewater ^
Inorganic Nonwastewater
Organic Wastewater..
Inorganic Wastewater
Soil'
Debris'
8,732
. 1,255
441
13,000
* 9,800
11
Soil'
Debris' _: _._.'_.._.'._ 1 _.-__ n
Source: 1993 Biennial Reporting System, July 1995 version. Totals may not sum due to rounding.
* The quantity of soil and debris wood preserving wastes requiring alternative treatment capacity is discussed more
fully in Section 3.4. The BRS does not include estimates of the over 100 million tons of contaminated media that may
require treatment as contaminated sites are cleaned up over the next several years.
These numbers include the estimated quantity of incinerator ash and wastewater treatment sludge derived from the
combustion of these organic wastewaters and nonwastewaters. See the text for further discussion.
" ' ''.'' '
' ' '"'.'.'.
volume of incinerator ash is 10 percent of the original volume and that the volume of scrubber water
treatment sludge is one percent of the original volume.44 As a result, the quantity of organic
nonwastewaters requiring alternative treatment capacity was increased by 90 tons per year to 8,732 tons
per year and the quantity of inorganic nonwastewaters was increased by 908 tons per.year to 1,255 tons
per year, as seen in Exhibit 3-5. ,
v The information provided by other sources on waste management practices supports the _
estimates derived from the BRS. According to the RCRA 3007 Survey that EPA conducted for the
' " ' , .'>..' ' "
tThird LDRrule.
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listing of these wastes, 63 percent of the facilities responding to questions about wastewater generation
and management discharged wastewaters to Publicly Owned Treatment Works (POTWs), while 13
percent stored or disposed of their wastewaters in land-based units (including land application units,
evaporation ponds, and surface impoundments). Furthermore, most F032 and F034 wastewaters are
currently pre-treated by oil/water separation in tanks and discharged under a NPDES permit and thus are
not subject to the LDRs as currently managed. Ten percent of the facilities also use some type of
aeration process and three percent use activated carbon filtration. During the listing process, EPA ,
assumed that inorganic wastewaters are reused in the process and-also are not subject to the LDRs as
currently managed. Industry sources have confirmed this assumption.45
3.4 SOIL AND DEBRIS CONTAMINATED WITH NEWLY LISTED WOOD PRESERVING
WASTES
'As shown in Exhibits 3-3 and 3-5, the 1993 BRS indicates that some soil and debris
contaminated with the newly listed wood preserving wastes were generated and managed in 1993. EPA
believes that remedial actions at wood preserving sites could generate large additional quantities of soil
and debris contaminated with the newly listed wood preserving wastes that are not accounted for in the
BRS. These wastes-will require additional combustion and other capacity for treatment.
For required combustion capacity for soil and debris, EPA examined Superfund Records of
Decision (RODs) signed between 1986 and 1993 for data on volumes of surfaced-disposed soil and
debris managed ex-situ at wood preserving sites (see Appendix H). From these data, the Agency initially
calculated a low-end estimate of the quantity of soil and debris from Superfund remedial actions that
would require additional combustion capacity. The low-end estimate assumed that only soil and debris
contaminated with dioxins or furans would be managed using combustion to meet the LDR treatment
standards, while wastes contaminated only with other constituents would be managed using non-
combustion treatment technologies such as bioremediation or stabilization/solidification. Based on these
assumptions (discussed in more detail in Appendix H), EPA estimates that between 100,000 and 260,000
tons of soil and debris generated during Superfund remedial actions alone at wood preserving sites may
require additional combustion capacity each year over the next two years. Soil and debris from wood
preserving sites is also likely to be generated during cleanup of non-NPL sites as well as from cleanups
under programs other than Superfund, such as through RCRA corrective actions and closures, State
cleanups, or voluntary cleanups. For example, Kerr-McGee has said that four of its seven facilities are
undergoing RCRA corrective actions.46 Beazer East also provides an analysis indicating that non-NPL ;
sites generate a substantial amount of contaminated soil (see Appendix H for further discussion of Beazer
East's analysis). As a result, the quantity of soil and debris contaminated with the newly identified wood
preserving wastes is likely to be much higher than the low-end estimate presented above. As discussed in
Section 3.6.2, however, EPA determined that the low-end estimate of required alternative treatment
capacity was greater than available capacity, and therefore the Agency did not conduct a rigorous
analysis to develop a high-end estimate of the quantity of contaminated soil and debris. Nevertheless, as
discussed in Appendix H, EPA believes that the high-end of this range is significantly higher than
100,000 tons per year. < .-
As seen in Attachment 1 of the February 14, 1997 memorandum presented in Appendix H, these
soil and debris volumes are contaminated predominantly with various mixtures of specific chemicals that
in turn indicate mixtures of F032, F034, and F035 wastes. Data gathered from the BRS supports this
conclusion (see Appendix G). Based on its review of Superfund RODs, the Agency believes that a
See communication logs in Appendix F. . ,
See February 19,1997 phone log in Appendix F detailing EPA discussions with Steve Ladner of Kerr-McGee.
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relatively small proportion of soil and debris.contaminated with wood- preserving wastes is contaminated''
only with FQ35 wastes. About 47,000'cubic yards of soil and debris was contaminated only with F035 :
waste compared to the approximately 85 1 ,000 cubic yards of soil and debris that was contaminated with
mixtures of F035, F032; and F034 waste (see Attachment 1 of the February 14, 1997 memorandum in
Appendix H). Where soil and debris are contaminated with both organic (i.e., F032 and F034) and
inorganic (i.e., F035) wood preserving wastes, treatment trains (e.g., combustion followed by
stabilization) will be required to effectively manage the contaminated soil and debris. As a result, the
. available treatment capacity for F032 and F034 wastes will affect the available treatment capacity for ,
F035-contaminated volumes of soil and debris that also contain F032 and/or F034 waste.
i , "
Commenters provided additional data regarding quantities of contaminated soil and debris. The
following summarizes commenters' responses:
In response to the NODA, Georgia's Department of Natural Resources commented that it
was in the process of cleaning up six abandoned wood treating facilities and expected to
generate a total of 130,000 tons of soil contaminated with F032, F034, arid F035 wastes from
these cleanups over the next two years.47 . '
/ , *
In response to the proposed rule, the Penta Task Force noted that approximately 10,500 tons
of F032-contaminated soil and debris are generated annually at wood processing.facilities,
- and large volumes (as high as 102 million tons) of contaminated soils from past operations
may require treatment; ' .
In response to the ANPRM, Beazer East submitted a study of 31 Superfund Records of
Decision .(RODs) on wood preserving that showed that a total of 2.2 million cubic yards of
contaminated soil (over 2.6 million tons) was removed at wood preserving sites. According
to this commenter, if this quantity is extrapolated to the entire universe of wood preserving
sites, a total of up to 85.3 million cubic yards (about 102 million tons) of contaminated soil
could be generated through remedial actions. This commenter also estimated the
contaminated soil and rock at an additional wood preserving site to be 75,000 cubic yards
(approximately 90,000 tons). ' -' ,
Another commenter to the ANPRM, the James Graham Brown Foundation, estimated
remedial actions at-one of its former sites will include cleanup of a total of 8,000 cubic yards
(about 9,600 tons) of contaminated soil. - ' ' ,
* , " . A ' ' ...
Through a telephone conversation with EPA, an EPA Region X representative said that about
5,000 tons of soil and debris contaminated with F032 and F034 waste will be excavated from
a wood preserving site in Washington.48 Another Region X commenter noted that there are a
number of site cleanups in Region X that are generating large quantities of
pentachlorophenol and creosote wastes from efforts to contain dense non-aqueous phase
liquids (DNAPLs).49 ' .
47 See January 16, 1997 phone log in Appendix F detailing EPA discussions with Jim.Brown of the Georgia
Department of Natural Resouces.
48 See January 21,1997 phone log in Appendix F detailing EPA discussions with Beth Sheldrake of EPA Region X.
49 See January 6,1997 letter in Appendix F from Judi Schwarz, Region X to Susan Slotnick.
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. One commenter noted that the Corrective Action Management Unit (CAMU) Rule allows
soil and debris contaminated with wood preserving wastes to be managed without application
of the LDRs, but the commenter noted that if the legal interpretation of CAMU is a concern,
potentially larger quantities of soil and debris contaminated with wood preserving wastes
could require alternative treatment.30 . i
Another issue concerning hazardous soil and debris is the closure of surface impoundments.
Prior to the listing of the wood preserving wastes as hazardous, many facilities stored these wastes in
surface impoundments. For the most part, facilities can no longer use these surface impoundments
because they do not meet the minimum technology requirements under the Hazardous and Solid Waste
Amendments (HSWA) of 1984.5I According to the American Wood Preservers Institute, facilities are not
retrofitting their impoundments. Instead, facilities are using drip pads or 90-day exempt tanks.
Therefore, the surface impoundments have been or will be closed. Closure of the surface impoundments
could potentially result in the generation of large quantities of soil and debris contaminated with F032,
F034, and F035. Kerr-McGee, for example, has stated that five,of its seven wood preserving facilities
have closed surface impoundments that may have large surrounding areas contaminated with F034
wastes because of possible extensive contaminant migration.52
1 f
Based on the data provided in the comments and the analysis described at the beginning of this
section, over 100,000 tons per year of contaminated media may require additional combustion treatment
alone. Larger amounts may require other types of alternative treatment to comply with the Phase IV
LDRs.
3.5 MIXED RADIOACTIVE WOOD PRESERVING WASTES
.. ' .'
The Agency has also sought data on mixed radioactive wood preserving wastes and at this time
.has not found any quantities. Nevertheless, any commercial capacity that is available for mixed
radioactive wastes must be used for mixed wastes that were regulated in previous LDR rulemakings and
whose variances have already expired.
3.6 CAPACITY ANALYSIS : '
EPA generally applies available capacity first to wastewaters and nonwastewaters and then to
soil and debris. The capacity analysis is therefore discussed separately for each category. Mixed
radioactive wastes also are addressed.
3.6.1 Wood Preserving Wastewaters and Nonwastewaters Contaminated with Newly
Listed Wood Preserving Wastes
As discussed in Section 3.3, EPA estimates that very small quantities of wood preserving
wastewaters (approximately 441 tons of organic wastewater and 13,000 tons of inorganic wastewater)
will require alternative treatment capacity in order to comply with Phase IV LDRs. As shown in Exhibit
3-5, EPA estimates that approximately 10,000 tons of nonwastewaters (8,732 tons of organic ;
50 See phone log in Appendix F detailing February 19, 1997 discussion between EPA and.Steve Ladner of Kerr-
McGee.
51 Facilities are given four years to retrofit surface impoundments, .once the wastes in them have been listed as
hazardous. If the surface impoundment is not retrofitted to meet MTRs, it cannot be used to manage hazardous
wastes.. Since these wastes were listed in December 1990, the four-year window has expired.
52 See February 19,1997 phone log in Appendix F detailing EPA discussions with Steve Ladner of Kerr-McGee.
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nonwastewaters and 1,255 tons of inorganic nonwastewaters)' will require alternative treatment as a result
of the Phase IV LDRs.-
,'- Based on the available capacity information provided in Chapter 2 and the required capacity
information presented above, EPA has determined that there is adequate capacity available to treat wood
preserving wastewaters and nonwastewaters (organic and inorganic). This conclusion is based on the
following comparison of available-and required capacity for the various wood preserving wastewaters
and nonwastewaters: .
. sufficient liquid combustion capacity (approximately 885,000 tons per year) is available to
. treat the required capacity of organic wood preserving wastewaters (about 441 tons per
: . ' year)53; . ' >
> ' i
sufficient stabilization capacity (over one million tons per year) ^and limited vitrification
capacity are available to treat the required capacity of inorganic wood preserving'.
nonwastewaters (about 1,255 tons per year); v
> sufficient pumpable/non-pumpable sludge, solid, and soil combustion capacity
(approximately 87,600 to 199,100 tons per year) is available to treat the required capacity of
organic nonwastewaters (about 8,732 tons per year); and '
. sufficient wastewater treatment capacity available (several million tons,.plus the ability of
systems to be optimized quickly) to treat the required capacity of inorganic wastewaters
(about 13,000 tons per year).54
However, because F032 residues resulting from Part 265 combustion units will have to meet applicable
numerical limits for dioxins and furans prior to disposal, and because the estimate of required capacity
excluded wastes managed in on:site captive thermal devices operated under 40 CFR Part 265 (i.e.,
interim status incinerators), the Agency, conducted additional analysis to be consistent with the analysis
of available commercial combustion capacity in Chapter 2 (which accounted for the commercial interim
status incinerators). That is, if the on-site captive combustion capacity is available to manage the waste
covered in today's rule, the amount of required commercial capacity would increase. Therefore, as an
upper bound, EPA assumed that all organic F032 waste that is generatedapproximately 7,333 tons/year
of nonwastewaters and 25,872 tons/year of wastewaterscould require alternative combustion capacity,
which would increase total required commercial combustion capacity to about 9,100 tons/year for
nonwastewaters and 26,312 tons of wastewaters. Even with this assumption, however, there clearly is
sufficient combustion capacity to treat the waste. Furthermore, the Agency expects that some of the
F032 wastes estimated above may also carry the D037 waste code and thus may be meeting the Phase II
LDRs. Because the Phase IID037 treatment standards are comparable to the Phase TV standards, many
of the F032 wastes will not require a significant amount of additional capacity. Therefore, these
estimates of required capacity are likely to overestimate the quantity of waste actually requiring
treatment. . - . . .
53 As discussed in FinaLBest Demonstrated Available Technology Background Document for Wood Preserving
Wastes - F032. F034. and FQ35. EPA has determined that wastewater treatment technologies such as-biological
treatment, steam stripping, carbon adsorption, or a combination of these technologies also can treat organics
regulated in F032 and F034 to the promulgated concentration limits.
54 EPA has determined that treatment levels can be readily achieved by lime addition followed by sedimentation and
filtration for arsenic, and by chemical precipitation followed by sedimentation for chromium.
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3-14
In light of this analysis, the Agency is providing only a 90-day national capacity variance for
newly listed wood preserving wastewaters and nonwastewaters (organic and inorganic) to allow facilities
sufficient time to arrange for treatment of their wastes and/or modify existing treatment systems (e.g.,
wastewater treatment systems) to meet the LDR standards for these wastes.
3.6.2 Soil and Debris. Contaminated with Newly Listed Wood Preserving Wastes
EPA does not believe that there is adequate combustion capacity available to treat soil and debris
contaminated with newly identified wood preserving wastes. As discussed in Chapter 2, the Agency
estimates that there is combustion capacity available to treat about 87,000 to 199,100 tons per year of ,
hazardous wastes. This estimate, however, encompasses capacity for sludges, solids, and soils. The .
Agency estimates that capacity available to treat only soils and debris that require combustion is about 25
percent of this range, or about 21,900 to 49,775 tons per year. In contrast, the Agency has estimated that
between 100,000 and 260,000 tons of .soil and debris from Superfund remedial actions alone that are
contaminated with mixtures of F032, F034, and F035 wastes may require additional combustion capacity.
The required capacity increases when soils and debris generated under RCRA corrective actions and
closures, State cleanups, and voluntary cleanups are included in the required capacity estimate.
Furthermore, logistics issues may severely hamper the ability of site managers to obtain adequate
alternative treatment in the near term. For example, as seen in Chapter 4, Beazer East stated that most
incinerators that can manage nonpumpable materials only accept such materials in small quantities, and
fewer than five of the RCRA-permitted incinerators can handle truckloads or railcar volumes of
contaminated media. Beazer East believes that, as a result, soils and similar remediation wastes will pose
material handling and capacity problems for most of the nonpumpable incinerators. Other commenters
indicated that facilities have no control over the timing of cleanups that must be approved by EPA or
states.55 Obtaining permits for on-site combustion and other waste management, and the redesigning of
specific on-site remedial actions, can take years to accomplish. Finally, as discussed in Section 3.4, the
Agency has found that the majority of soil and debris contaminated with F035 waste is also contaminated
with organic contaminants, including F032 and/or F034 wastes. Because of treatment train issues, F035
waste mixed with F032 and/or F034 waste will consequently not be able to be treated until the organic
portion of the waste has been treated. Thus, given the lack of available capacity and other issues
-associated with soil and debris contaminated with F032, F034, and/or F035 wood preserving wastes, the
Agency is granting a two-year-variance for these wastes.
3.6.3 Mixed Radioactive Wastes
As discussed previously, the Agency has not found any quantities of mixed radioactive wood
preserving waste. Nevertheless, as discussed in detail in the proposed Phase JV rule capacity analysis,
any commercial capacity that is available for mixed radioactive wastes must be used for mixed wastes
that were regulated in previous LDR rulemakings and whose variances have already expired. Therefore,
EPA is granting a two-year national capacity variance for any mixed radioactive wood preserving wastes
and for any soil and debris contaminated with mixed radioactive wastes that may exist.' ,
55
See February 19,1997 phone log in Appendix F detailing EPA discussions with Steve Ladner of Kerr-McGee.
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CHAPTER4
COMMENT/RESPONSE
4.1 INTRODUCTION
In the August 22,1995 proposed rule for the Land Disposal RestrictionsPhase IV: Issues
Associated with Clean Water Act Treatment Equivalency, and Treatment Standards for Wood Preserving
Wastes and Toxicity Characteristic. Metal Wastes (60 FR 43654), EPA proposed treatment standards for
certain wastes listed and identified since November 1984 that have not been covered in previous Land
Disposal Restriction (LDR) rulemakings. .In addition, EPA issued the Land Disposal Restrictions Phase
IV Proposed Rule-Issues Associated with Clean Water Act Treatment Equivalency, and Treatment
Standards for Wood Preserving Wastes and Toxicity Characteristic Metal Wastes: Notice of Data
Availability (NODA) on May 10, 1996 (61 FR 21418).
EPA received. 123 comments to the proposed rule and 21 comments to the NODA.56 This
chapter summarizes those comments related (either directly or indirectly) to the capacity analysis for the
newly listed wood preserving wastes.57 EPA received 8 comments to the Phase IV Proposed Rule and 6
to the Notice of Data Availability (NODA) on the capacity analysis for F032, F034, and F035 wastes: -
Beazer East (23); Rollins Environmental Services, Inc. (27, N19); Penta Task Force (32, N3); Utilities
Solid Waste Activities.Group et al (USWAG) (35); American Wood Preservers Institute (39); Chemical
Waste Management (48, N18); J.H. Baxter (58); The Hazardous Waste Management Association (97);
Georgia Department of Natural Resources (N13); DuPont Engineering (N16); and Dow (N9).S8
The comments address eight issues related to the capacity analysis for wood preserving wastes:
1. Discrepancy Exists in the Wood Preserving Waste Generation Estimates; .
2. Sufficient Combustion Capacity Exists for Newly Listed Wood Preserving Wastes-
Si Insufficient Incineration Capacity. Exists for F032 Wastes;
4. Capacity for F032 Will Not Increase; ' ,
' 5. No Alternative Dioxin/Furan Technologies Are Commercially Available; - '
6. Insufficient Vitrification Capacity Exists for Newly Listed Wood Preserving Wastes;,
7. Available Capacity Does Not Exist for Newly Listed Wood Preserving Wastewaters; arid
8. National Capacity Variance Is Needed for Soil and Debris Contaminated, with Newly Listed
Wood Preserving Wastes.
For each of these issues, we present a summary of the issue, EPA's response to the commenters'
questions and concerns, and photocopies of the actual comment letters. .
56 Lists of the commenters to the proposed rule and the'NODA can be found in Appendix B. Each comment has
been assigned a document number. In the rest of the chapter we will refer to the commenter both by name and by
document number. Comment numbers beginning with an "N" indicate the comment was received in response to the
NODA. Comment numbers with no "N" indicate the comment was received in response to the proposed rule.
57 Comments that pertain to other waste streams and/or issues not addressed in today's rule will be addressed'when <
; the respective rules are finalized.
58 Comment N9 addresses capacity for F024 under the mistaken assumption that EPA is revising the BDAT
standards for F024. Therefore, the Agency has not addressed this comment because it is not relevant to the capacity
analysis for this rule. ' < - .'".'. . .
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4-2
4.2 DISCREPANCY EXISTS IN THE WOOD PRESERVING WASTE GENERATION
ESTIMATES
Summary: . .
In the proposed rule, EPA provided two estimates of the generation of newly listed wood ;
preserving wastes, one for the purpose of the capacity analysis, and one for the purpose of the Regulatory
Impact Analysis (RIA). Two commenters, Penta Task Force (32) and American Wood Preservers
Institute (39), noted the discrepancy between these estimates. Penta Task Force stated that the estimate
provided in the capacity analysis is an order of magnitude higher than the estimate in the RIA for F032
wastes and stated that the capacity analysis methodology more accurately reflects, actual F032 waste
volumes (32:15-16). American Wood Preservers Institute requested revaluation and clarification of
contradicting capacity estimates for F032 wastes (39:20-21).
Response:
The focus of the capacity analysis is not the same as that of the RIA. Thus, there can be
differences in the estimates developed for these two separate analyses. The capacity analysis focuses on
the quantity of waste requiring alternative treatment capacity over the two years following promulgation
of the final LDR rule to evaluate whether a national capacity variance is required. The RIA focuses on
the quantity of waste affected by the LDR rule over,a much longer time frame following promulgation of
the rale to evaluate the costs and benefits of the rule; Furthermore, while the RIA invariably develops a
"best estimate" of the quantities of waste, the capacity analysis often uses an iterative process whereby
an upper-bound estimate is first developed in order to determine whether the available capacity would be
exceeded. If so, a more refined estimate is developed.
Also, as one of the commenters notes, EPA did not have data indicating whether wastes were
wastewaters or nonwastewaters. Therefore, for the capacity analysis, wastes were classified as
wastewaters or nonwastewaters based on the form of the waste that was reported to EPA in the 1993
Biennial Reporting system.
For the final rule, EPA has reevaluated both the capacity analysis and the RIA to resolve any
discrepancies that cannot be explained by the different foci of the two analyses. The quantity of wood
preserving wastes requiring alternative treatment capacity that is estimated in the revised capacity
analysis now lies within the low-end and high-end estimate presented in the RIA. In the RIA, EPA
estimates that between 3,860 tons and 18,808 tons of wood preserving nonwastewaters will require
alternative treatment capacity under the Phase IV LDRs (see Exhibit 2-3 of the RIA). In the revised
capacity analysis, EPA has estimated that about 10,000 tons of wood preserving nonwastewaters will
require alternative treatment capacity (see Section 3.3.2 of this document).
( . ,
Comments:. . -
t ^ , -
See next page.
-------
Commenter: >
Comment Number:
Page Number:
4-3
Penta Task Force
32
15 .
In its Regulatory Impact Analysis.
EPA has assumed that only some 1,200 tons of F032 nonwastewaters are generated each
" ' V.
year at the 49 wood processing facilities that would become subject to the F032 treatment
standards. RIA-. ES-12, Exh: 3-2 at 3-5, 3-6. But that estimate is flatly; inconsistent with
the 12,600 tons estimate found in the Capacity Analysis. As noted above, the Capacity
-------
4-4
Commenter:
Comment Number:
Page Number:
Penta Task Force
32
16
Analysis estimates the F032 waste volumes at 22,000 tons per year; that estimate is based
on data gleaned from the 1993 Biennial Reporting System ("BRS"). The RJA. on the
other hand, derives it estimate on the basis of 1993 production statistics multiplied by a
waste generation rate taken from a 1985 RCRA 3007 survey.
The methodology used in the Capacity Analysis more reliably reflects
.actual F032 waste volumes. The BRS data-used in the Capacity Analysis reflect recem
data reported by wood preserving sites on the actual quantities of wastes transferred off-
site for treatment or disposal during 1993. The 1985 RCRA 3007 survey, on the other
hand, was conducted at a time when most wood treating facilities were using surface
impoundments for waste management and therefore had limited ability to quantify waste
generation rates. Also, the RIA incorrectly asserts that the BRS report might reflect
double counting of waste streams. In point of fact, the procedures used by BRS to
collect the data were carefully designed to avoid double-counting. For these reasons, the
volume estimates in the Capacity Analysis are more accurate than those presented in the
RIA^ If EPA were to use these more accurate volume estimates to analyze costs, it is
clear as shown below that the cost of meeting the treatment standards at a six 9s
incinerator would be prohibitive.
-------
' ' ' - : V
- 4-5 :. -
1 Cornmenter: American Wood Preservers Institute
Comment Number: 39
Page Number: 20
EPA estimates some 40 tons of inorganic wastewater and 2,880 tons of
. ^ ~
inorganic non-wastewater will require alternative treatment capacity per year. EPA
representatives stated that these numbers come in part from the Biennial report/ .
i * ' -'"'
However, generators do not distinguish between wastewaters and non-wastewaters.
Therefore; it is unclear how EPA obtained these numbers. -
By EPA's capacity analysis estimation, 12,600 tons of F032 non-wastewater
sludges and residuals are generated at wood preserving facilities per year.37 However,
the Agency presents contradictory figures in its regulatory impact analysis where EPA
estimates only 1,200 tons of F032 non-wastewaters are generated per year.38 In
addition, the Agency estimates that millions of tons, of previously-contaminated soils
and debris may require treatment.3*
' f ' '
COMMENT: -
~^^-^"^^~ \ , , .
The Agency's methodologies for calculating capacity and waste generation are
i . ' - -^ '
unclear, inconsistent, and warrant explanation. The final rule should clarify how EPA
achieved the estimates for total inorganic wastewater and non-wastewater. EPA
" See. ^National Capacity Assessment Report: Capacity Planning Pursuant to CERCLA Section
l04(c)(9)M,EPA530-R-94-040. . .
""Best Demonstrated Available Tecnix>lc^(BDAT^ .
Wastes" (July 1995) and "Capacity Analysis", Section 3-8, EPA.
31 "Regulatory Impact Analysis of the Phase IV Land Disposal Restrictions (Draft)", (August 7,1995).
"Id. ''. .- ' .-
-------
4-6
Commenter: American Wood Preservers Institute
Comment Number: 39 .
Page Number: 21 ,
should explain which number reflects actual F032 waste generation volumes and use
-the correct volume throughout its analysis.
-------
4-7 .'.
4.3 SUFFICIENT COMBUSTION CAPACITY EXISTS FOR NEWLY LISTED WOOD
PRESERVING WASTES /
Summary:, , ." ',.-
In-the proposed rule, EPA stated that combustion would be able to meet the proposed treatment
standards for the organic newly listed wood preserving wastes (both wastewaters and nonwastewaters).
Based on EPA's assessment that there was over one million tons of available liquid combustion capacity
available and over 100,000 tons of available sludge/solid combustion capacity, EPA proposed not to
grant a variance for organic newly listed wood preserving wastes. Rollins Environmental Services, Inc.
(27, N19) supports EPA's determination that sufficient combustion capacity exists for these wastes.
Rollins stated that EPA's available sludge/solid capacity estimate does not include combustion capacity
at the ECOVA facility in Nebraska. Rollins provided capacity data for all of their combustion facilities
to EPA as Confidential Business Information (CBI). Rollins also stated that EPA overestimated capacity
requirements for Phase II wastes as 439,500 tons and that this estimate should be less than 100,000 tons
annually (27:3-4) (N19:1-3). In their comment to the NODA, Penta Task Force (N3) stated that the
proposed suboption 3 (which EPA is finalizing today) would increase the number of facilities that could'
accept these wastes and alleviate capacity shortfall problems (N3:3).
Response: . .
EPA acknowledges Rollins Environmental Services, Ihc.'s support and has incorporated the data
provided into its revised capacity analysis. Refer to Chapter 2 in this document for a detailed discussion
of how the data were incorporated into'the analysis. In response to the Penta Task Force comment, EPA
agrees that the number of facilities that could accept wood preserving wastes likely will increase and thus
has incorporated this increase into the assumptions used to develop available capacity estimates in
Chapter 2. . . ". - .
Comments: .
See next page. - , ''
-------
Commenter.
Comment Number:
Page Number
4-8.
Rollins Environmental Services
27 ,.
3
EPA's own capacity survey, used for this proposal, shows an available sludge/solid combustion
capacity of 115,900 tons. However, even this large volume of available capacity severely under
reports the true actual available commercial combustion capacity. The Agency's survey
demonstrates the following available combustion capacity numbers for sludge/solids:
Available Capacity
Capacity Required for Phase II Wastes
Capacity Required for Phase HI Wastes
Total Available Capacity
560,000 tons
(439,500)tons
(4,600) tons
115,900 tons
RES feels the 115,900 tons of available capacity for sludges/solids is under reported for several
reasons. The EPA's data did not include capacity figures from the ECOVA facility in Nebraska.
Also the estimate that Phase II wastes are utilizing 439,500 tons of available capacity is
extremely high. Anecdotal evidence, and records searches, indicate that the volume of additional
wastes requiring treatment after promulgation of the Phase Q treatment y»anH«trf« amounts to
well less than 100,000 tons annually. Therefore, the real thermal capacity for sludge/solids
should be significantly higher than the 115,900 tons the Agency estimates.
The commenterq primary concern about thermal treatment capacity appears to be of the available
capacity may not be available for F032 wastes if these wastes have a Dioxin/Furan treatment
standard. The commenters imply that only a small percentage of the available thermal capacity
will be open to wastes with a Dioxin/Furan standard. RES feels this is not a valid concern.
-------
Commenter
Comment Number
Page Number.
' . ... 4-9
Rollins Environmental Services
27
4
RES operates five incineration facilities in the U.S. (see Attachment A). Three of these facilities
(located in Kansas, Texas, & Utah) have demonstrated the ability to meet the Dioxin/Furan -
treatment standard under a variety of operating conditions. These facilities represent roughly
70% of the thermal treatment capacity of RES. We are confident the other two RES facilities
could also meet these treatment standards (because of design & operational similarities between
all RES incinerators) if there is sufficient demand to require utilizing these facilities. Within the
RES system alone there is sufficient capacity to handle the F032 wastes.
-------
4-10
Commenter:
Comment Number:
Page Number:
Rollins Environmental, Inc.
N19
1
OaaWlai
June 7.3 996
RCRA Information Center
U.S. Environmental Protection^Agency (5305W)
401 M Street SW ,
Washington, D.C 20460
Rollins environmental Service*, Inc. Connients on Land DisposaJ Restrictionj Phase IV
Proposed Rule-Issues Associated With Clean Water Act Treatment Equivalency,
Tr«atm«nt Standards for Wood Preserving Wastes and Toiieity Characteristic
Wfl«MM> Wn*« «*«-- *..-:-«-'"
^ .... w &iiiy «.aac
Notice of Dili AvailtbiUfy; Docket Number F-96-P42A-FFTFF
and
Metal
Dear Sir or Madam:
This letter constitutes the comments of Rollins Environmental Services. Inc.
Tt^t'TPVU'V*! Mrtfi^»
referenced notice.
On the above
Statement of Interest
Treatment Standard, for Wood Preserving Waste F032
In-tWs NODA, the EPA i* responding to rhc Wood P««rving Industry's concern that a
of RES
of
in
-------
4-11
Commenter: Rollins Environmental, Inc. .
. Comment Number: N19 . .
Page Number: : 2 '
^ , » T '
O'.S. As stated in our comments of 11/17/96, "three RES subsidiaries (located in Kansas, Texas,
and Utah) have demonstrated the ability to meet the" proposed F032 "Dibxin/Furan treatment
standard under a variety of operating conditions." "These facilities represent roughly 70% of the
thermal treatment capacity of RES. We are confident the other two RES facilities could also meet
these treatment standards if there is sufficient demand to handle the F032 wastes. Within the
RES system alone there is sufficient capacity to handle the F032 wastes." RES is convinced
these comments are still valid today, and there is no capacity shortage for the treatment of
F032 process wastes (see attached 6/5/96 announcement of "Campaign Mode" at Coffcyville
due to overcapacity). .
There is .a demonstratively sufficient amount of capacity to meet the proposed Dipxin/Furan
treatment standards for F032 process wastes. Additionally, RES contends there is sufficient
capacity to meet the proposed Dioxtn/Furan treatment standards for F032 contaminated media
wastes. However, since the data on the quantity of r032 contaminated media is incomplete, it is
conceivable there may be a large F032 contaminated media cleanup that exceeds the capacity of
facilities able to meet the Dioxin/Furan treatment standard. RES also acknowledges that some
incineration facilities may not be able to meet the Dioxin/Furan treatment standard, thereby
limiting the available capacity for large contaminated media projects.
Therefore, RES recommends the option of on alternative treatment standard for F032
contaminated media waste, available under limited circumstances. This option would allow an '
F032 contaminated media generator to utilize th« alternative treatment standard under the >
following condition; . .
The generator certifies to the EPA (hat a request to at least five incineration '
facilities indicates there is insufficient capacity to treat the F032 contaminated
1 - media while meeting the Oioxin/Furan treatment standard. -. '
RES further recommends that EPA adopt the combination of subbptions 2 & 3 as outlined in the
NODA as the alternative trctment standard. Under this recornmendation, after certiryiciT there is
insufficient capacity for treatment of F032 contaminated media, a generator could utilize the
alternative treatment standard of "Combustion in a Part B permitted facility that meets a
Dioxm/Furan emission standard ot0.20 ng/DSCF." ]''' .
Conclusion
There is sufficient existing treatment capacity to meet the Dioxin/Furan treatment standard for all
F032 process wastes. . . .
Also, there is sufficient existing treatment capacity to mc«t the Dioxia/Furaa trt*tm*nt standard
for most F032 contaminated media projects. However, the treatment standard for F032
contaminated media should allow an alternative standard of "Combustion in a Part B permitted
facility that meets a Dioxtn/Furan emission standard of 0.20 ng/DSCF." after the generator
certifies there is insufficient capacity to treat the F032 contaminated media while meeting the
-------
Commenter:
Comment Number:
Page Number:
4-12
Rollins Environmental, Inc.
N19
Dioxia/Turan treatment standard.
t ' >
Should you have any questions about these comments, please contact meat (302) 426-3471.
Sincerely, . .
Michael G. Fusco
Director, Regulatory Analysis
cc: P. Retallick
D. Scherger ,
-------
4-13
Conunenter Pentafask Force
Comment Number N3
Page Number 3
B. Option 3 - CMBST In RCRA-Permitted Devtcef,
The Penta Task Force recognizes that Option 3, which provides for
combustion in RCRA-permitted facilities, would increase the number of combustion
facilities that would accept F03 2 waste and, thus, is by far preferable to the proposed
dioxin/furan treatment standard. Option 3 also would fully satisfy the LOR criteria as an
appropriate treatment standard. Indeed, EPA's August, 1995 proposal was predicated on
the finding mat incineration is the best demonstrated available treatment ("BOAT") for
dioxins/rurans in F032 waste. And EPA has oft-stated that various types of incineration
have been demonstrated to treat high and low level dioxin/furan constituents in a variety
of organic wastes to levels below detection limits in incineration residues. Option 3 thus
would ensure that F032 waste is treated by BOAT technology without the attendant
stigma and capacity shortfall problems that would result from setting dioxin/furan
numerical limits in the treatment residue.
Although Option 3 is preferable to setting dioxin/furan numerical limits.
we do not believe there is a regulatory justification for limiting the treatment standard to
permitted combustion devices only. As recently as April, 1996, EPA has amended the
treatment standards for the various waste codes that were previously subject to an
incineration (INCIN) standard to allow combustion in all hazardous waste incinerators,
boilers and industrial furnaces under the new treatment code CMBST. Sfifi 61 Fed. Reg.
15,566,15,601-15,653 (April 8,1996). EPA has offered 02 justification for retreating
from that decision now in the case of F032 (and perhaps F024) wastes.
Under either option - Option 1 or Option 3 - the number of treatment
facilities toil would accept F032 wastes would be greatly expanded. The Penta Task
Force believes that all options being considered by the Agency are fully protective of
health and safety and, thus, consideration of practicability and cost should drive the
selection of the appropriate treatment option. As explained in our November, 1995
comments, the practical consequences of setting dioxin/furan numerical limits for F032
wastes would be to force wood preserving facilities to send their wastes to the only
commercial incineration facility - the Aptus Incinerator in Coffeyvtlle, Kansas - that is
permitted to treat dioxuvcontaining waste.
-------
4-14
4.4 INSUFFICIENT INCINERATION CAPACITY EXISTS FOR F032 WASTES
Summary:
1 .
Several commenters [Beazer East (23); Penta Task Force (32, N3); American Wood Preservers
Institute (39); Chemical Waste Management (48, N18); J.H. Baxter (58); the Hazardous Waste
Management Association (97); and the Dow Chemical Company (N9)] question whether there is
adequate available combustion capacity that can meet the proposed treatment standards for dioxins and
furans in F032 wastes. EPA proposed treatment standards for dioxins and furans in F032 wastes, which
precluded the use of incinerators that are not permitted to accept dioxin and furan wastes. However, in
its capacity analysis for the proposed rule, EPA'assumed that all incinerators would be able to treat these
wastes, found that there was sufficient incineration capacity available, and'thus did not propose a .
capacity variance for F032 wastes. - ,
Beazer East stated that the proposed LDR standards for dioxins and furans in F032 will create
insurmountable disposal problems because only one incinerator in the US is licensed to accept dioxin and
furan wastes (23:4,8-10). 'Penta Task Force stated that the available capacity at the one facility permitted
to incinerate dioxins and furans to the proposed standards, the APTUS facility, is less than 6,600 tons/yr
for non-PCB wastes. According to Pehta Task Force, this creates a shortfall in capacity for the estimated
12,600 tons of F032 nonwastewater process sludges and residuals (32:3-4; 13-17,26, N3:2,5). >. American
Wood Preservers Institute (AWPI) stated that the APTUS facility has 19,500 to 25,400 tons of capacity
per year, 70 percent of which is dedicated to TSCA-regulated PCB waste, leaving 5,850 to 7,350 tons per
year available for other waste streams. AWPI noted that even if all of this remaining capacity is
dedicated to F032 waste, there is not sufficient capacity to treat the actual volumes of F032 wastes, and -.
given the strong public resistance to new incinerators and the huge costs associated with permitting
facilities capable of meeting a destruction and removal efficiency (DRE) of 99.9999%, additional
incineration capacity for dioxin-containing wastes is not likely (39:24-26).
Chemical Waste Management stated that if an incineration facility must demonstrate a DRE of
99.9999%, then EPA must grant a national capacity variance for F032 wastes. However, the commenter.
notes that if incineration or combustion is established as the treatment standard, its facilities may be able
to accept F032 wastes (48:38, N18:2). J.H. Baxter stated that Laidlaw Environmental, the current
handler of Baxter's F032 waste streams, will no longer accept the wastes if the dioxin standard for F032
is adopted, and that it will be extremely difficult to obtain timely treatment for F032 waste streams.
Baxter also noted that the one commercial facility currently permitted to combust dioxin and furan
wastes has an annual capacity is 22,000 tons, 70% of which is devoted to incineration of TSCA-regulated
wastes contaminated with PCBs. According to Baxter, this leaves capacity for 6,600 tons of waste from
RCRA-regulated disposal activities, which will create a capacity shortfall (58:1-3). ,
The Hazardous-Waste Management Association (HWMA) believes that the Agency's statement
regarding the only permitted facility to combust F032 wastes with dioxin and furan constituents (60 FR
. 43682) contradicts its capacity analysis, which indicates there is sufficient capacity. HWMA stated that
there may be sufficient incineration capacity for F034 wastes, but not for dioxins and furans proposed as
BDAT for F032, and recommended that EPA either promulgate a two-year national capacity variance or
remove dioxins and furans from the F032 treatment standards (97:17-18). The Dow Chemical company
-believes that EPA has not sufficiently analyzed the available treatment capacity for these wastes
(N9:2,3).
-------
4-15
Response: , . '
In today's rule EPA is not requiring the combustion of F032 wastes in a "six 9's" destruction and
removal efficiency combustion device. Therefore, facilities may combust F032 wastes at any RCRA
facility regulated under CFR Part 266 or 264, Subpart O without having to monitor the concentrations of
dioxins and furans left behind in the combustion residues. This alternative should eliminate the "stigma"
types of concerns raised by commenters. In addition, facilities may combust F032 wastes in combustion
devices regulated under CFR Part 265, Subpart O units, provided the residues meet the applicable
standards for each regulated dioxin or furan constituent, or make a demonstration that their combustion is
at least equivalent to that required of permitted incinerators or Part 266 BIFs, in which case these interim
status incinerators would also have the option of not monitoring for dioxins in combustion residue. EPA
has determined that approximately 885,539 tons/year of available capacity exists for liquid Phase IV
wood preserving wastes and the approximately 87,600 to 199,000 tons/year of available capacity exists
for pumpable/nonpumpable sludges, solids, and> soils at combustion facilities permitted to accept F032
wastes (see Section 2.1.2 of this document), while required capacity is only a fraction of these amounts.
Therefore, there is sufficient capacity to treat F032 to the final LDR standards, and EPA is not granting a
national capacity variance for.these wastes.
t * .
Comments:
i j . . ^ . .
See next page. , , - ' .
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4-16
Comrnenter:
Comment Number:
Page Number:.
Beazer East
23
4
As discussed in greater detail below, the Agency's proposed LDR for
dioxin/furan congeners (hereinafter referred to as "dioxin/furan") as constituents of
F032 LDR lacks scientific justification and will create insurmountable disposal
problems. -For example, EPA has determined .that its proposed one part per billion
("ppb") concentration limit for dioxin/furan can be achieved by incineration, without
considering the consequence of only one incinerator being licensed-in the UnitSd
States to accept such waste. Furthermore, EPA has intentionally, through its Draft
Combustion Strategy For Combustion of Hazardous Waste, May 1993 ("Combustion
Strategy"), created significant impediments to the issuance of new permits for
additional hazardous waste incinerators. Moreover, as Beazer has consistently
\ 1 * ' '
maintained in its previous comments, the public simply refuses to tolerate the risks of
new incineration, particularly with respect to the more controversial substances, such
as PCBs or dioxins. Under these circumstances, any thought of obtaining a new
permit for an incinerator which would be used to incinerate dioxin/furan is
'
unfathomable;
-------
4-17
Commenter:
Comment Number:
Page; Number:
Beazer East
23
8
U. EPA HAS FAILED TO CONSIDER THE TECHNICAL. ECONOMICAL AND
PRACTICAL IMPACTS OF THE PROPOSED LDRs ON REMEDIATION
EPA's Proposed Rule fails to consider a number of critical issues related to the
remediation of wood treating sites. These issues involve LDRs for FQ32, F034 and
' ' ~v. i - , '
F035 as discussed below.
Insurmountable Disposal Problems.
i ' . ' ^ "* '
1. Dioxin/Furan should not be regulated constituents under the F032
~' ,' LDR. ' . - _;-..
/' : Regulation of dioxin/furar as constituents under the F032 LDR is
scientifically unwarranted. One of the first LDRs for dioxin/furan-containing wastes
was established by EPA for F027.2 EPA established the F027 LDR at 1 ppb. (in
' ! '
leachate) and is now arbitrarily applying the 1 ppb standard to F032. .
""" ' . '
EPA's characterization of F027 as acutely hazardous was based
on trace levels of hexachlorodioxins. See Toxicological Profile for Pentachlorophenol,
2 EPA established LDRs for the "dioxin-wastes' F020-23 and F026-28 in one rulemaking on January
14,1986. 51 Fad. Reg. 1602.. \ '
-------
4-18
Commenter: Beazer East
Comment Number: 23
Page Number: 9
May 1994, Agency for Toxic Substances and Disease Registry (ATSOR). EPA
considers hexachlorodibxins as potent animal carcinogens. Jo\ This characterization
of hexachlorodioxins is not technically founded and is even refuted by the results of
a bioassay performed by the National Toxicity Program ("NTP") in 1989, the results
, » ,
of which were reported in NTP-TR-349 and in NIH Publication 89-2804 (the "NTP
cancer bioassay"). As noted in a November 27, 1991 letter from Vulcan Chemicals
to EPA (the "Vulcan Letter") (obtained from the RCRA docket), the NTP cancer
bioassay on penta conclusively demonstrated that any cancer response observed in
exposed laboratory animals was due to the toxic overexposure of the test animals to
penta and not to the trace amounts of hexachlorodioxin present. See the Vulcan
Letter, p.3.
Moreover, the EPA's Science Advisory Board's ("SAB's") recent
evaluation of EPA's draft dioxin risk reassessment documents has sharply criticized
',' - - . * ~ .N,
EPA's reliance on the standard default assumption of a linear non-threshold model for
carcinogenic risk and has called for a substantial rewrite of the assessment. The SAB
concluded that one major weakness of the assessment was that the presentation of
scientific findings portrayed in the draft conclusions was not balanced and exhibited
r ", .
a tendency to overstate the evidence of danger. -. .
Accordingly, Beazer believes that EPA currently is without
sufficient scientific bases for regulating dioxin/furan as a constituent of F032.
-------
4-19
Commenter:
Comment Number:
Page Number:
Beazer East
23
10 .
RECOMMENDATION:.. . '
Given that EPA has yet to scientifically demonstrate and support the risk from
low level exposure to dioxin/furan, Beazer recommends that EPA exclude dioxin/furan
from regulation as part of the F032 LDRs until agreement on the scientific
, . ' ' '
underpinnings of this regulatory action is achieved.3
Beazer has serious doubts, regarding the Agency's rote reliance on technology-based standards :o'
meet LDRs. .The Agency, has discretion to utilize either a risk-based or technology-based standard,
American Petroleum Institute v. EPA. 906 F.2d 729 {D.C. Cir. 19901 and in the case of dioxin/furan, Beazer
believes that a site-specific risk-based standard is more appropriate on both a scientific and practical basts.
If EPA retains dioxin/furan as an indicator parameter for F032. the standard should not be identical for all
congeners. 'EPA has determined that 2.3,7,8-TCDD is the most toxic of the dioxin/furan congeners. 51
Fed. Reg. 1732. In order to assess the risks posed by dioxin/furan other than 2,3,7,8-TCDO, EPA'adopted
an interim procedure for assessing the risks to human hearth based on toxicrty equivalency factors ("TEFs")
which permits the conversion of any dioxin/furan congener into an equivalent concentration of 2,3,7,8-
TCDD or Toxicrty Equivalents l"TEQs"l. Id. In 1989, EPA adopted the International JEFs which are
presented below for the six dioxin/furan congeners in the proposed LORs for F032.
Compound Toxicrtv Equivalent Factor
Tetrachlorodibenzo-p-dioxins (2.3,7,8-TCDDsl
Pentacrtlorodibenzo-p-dioxins (2,3,7,8-PeCDDsl
> Hexachlorodibenzo-p-dioxins (2,3,7,8-HxCDOs)
Tetrachlorodibenzo-p-furans (2,3,7,8-TCOFs(
Pentachlorodibenzo-p-furans (2,3,4,7,8-TCOFs)
Hexachlorodibenzo-p-furans (2,3,7,8-HxCDFsl
.1.0
0.5
0.1
0.1
0.5
0.1
See Interim Procedures for Estimating Risks Associated With Exposures to Mixtures of Chlorinated Dibenzo-
p-dioxins and -dibemofurans fCDOs end CQFs). U.S. Environmental Protection Agency, Risk Assessment
Forum, Washington O.C. EPA/625/3089/016 (1989).
All of trwdioxin/furan congeners shown above exhibit significantly less toxicrty than 2,3,7,8-TCDO.
The one congener that is associated with pantachlorophenol, HxCDDs, is 10 times less toxic than 2.3,7,8-
TCDD. Clearly, the proposed LDR treatment standard for nonwastewaters of 1 ppb for all the listed
didxins/furans other than possibly 2,3,7,8-TCDO is .not consistent with the risks identified in the recent
scientific literature associated with each of the congeners. Moreover, EPA has acknowledged that
dioxin/furan wastes are immobile. 51 Fed. Reg. 1602 (January 14, 1986). Thus, the risk associated with
F032 wastes placed in a secure Subtitle C landfill is dramatically different than the residential risk scenario
.EPA has utilized to develop dioxin/furan action levels. ,
-------
Commenter:
Comment Number:
Page Number:
4-20
. Penta Task Force
32 .
3
The Penta Task Force is aware that there is one commercial incineration ,
t
facility that is permitted to treat dioxin-containing wastes and that the stigma issue does
not apply to that facility. But that facility - the Aptus Incinerator in Coffeyville, Kansas
1 i
- is a unit operating at 99.9999 percent ("six 9s") DREs and was designed to handle
"acutely hazardous" dioxin-containing wastes. Because EPA has already decided,, after an
extensive review of the matter, that it is not appropriate to classify F032. wastes as acutely
hazardous, any treatment strategy that relies on the management of the wastes in a six 9s
incinerator would be improper: , - . ;
The refusal of treatment facilities to accept F032 wastes will lead to severe
shortfalls in treatment capacity. The Goffeyville facility simply does not have sufficient
capacity to handle the volumes of F032 wastes that will become 'Subject to the treatment
standard. Moreover, even if there were sufficient capacity for six 9s incineration of F032
wastes, the costs compared to incineration at a four 9s unit would be exorbitant By the
Agency's own reckoning, some 12,600 tons of F032 nonwastewater process sludges and
residuals are generated each year at wood preserving sites. In comparison, the available
capacity of the Coffeyville facility for non-PCB wastes is less than 6,600 tons per year.
-------
4-21
Commenter: Penta Task Force
Comment Number: 32
Page Number: .4 ;
. or only one-half that which would be needed to handle the volumes of F032 wastes that
would require treatment. As shown below., incineration of the. 12.600 tons of F032 " ,' "'
process wastes in a six 9s incinerator would'cost in excess of SI 13 million dollars per
year compared to the cost of only $12 million dollars tor incineration in a four 9s unit.
This cost would need to be bome -by relatively few companies - there are only 49 wood
' preserving plants that generate F032 waste and,many of these plants are small- to
i
moderate-sized businesses. .(Indeed, even-if four 9s incinerators would take the waste, but
were fprced to charge the' same, cost as six 9s incineration because of added analytical
. ; ' , 'l
costs or the need for multiple bums to meet the 1.0 ppb standard, the economic tmpaqi on
Wood preserving sites would have the same devastating impact.) ' '
-------
4-22
Commenter:
Comment Number:
Page Number:
Penta Task Force
32,
13
B. The Stigma Problem Will Lead To Treatment Capacity
Shortages. i
The Capacity Analysis prepared in connection with this rulemaking
estimates that some 12,600 tons of F032 nonwastewater sludges and residuals are
/
generated at wood preserving facilities each year. See Capacity Analysis. 3-8. See also.
-------
4-23
Commenter: . Penta Task Force
Comment Number: 32
Page Number:' 14
.Final Proposed Best Demonstrated Available Technology (BOAT) Background Document
' ' . >
for'Wood Preserving Wastes F032. F034-F035. Table 3-6, at 3-53 (July 26, 1995)
(hereinafter "F032 BDAT Background Document").' If commercial hazardous waste
incinerators refuse to take the waste, it will need to go to the Aptus facility in :
Coffeyville, Kansas « the only incinerator permitted to accept dioxin-containing wastes..
Indeed, EPA's Regulatory Impact Analysis ("RIA") for the proposed rule assumes that the
wastes are treated at Coffeyville, which indicates EPA's tacit recognition of the
problem.- . . ' . - ' . ' ;
The- annual capacity for the Aptus facility is on' average roughly 22,000 "
tons per year. Telephone Interview with Rollins. Environmental Services (Oct., 23, 1995).
Of that amount, 70 percent of the incinerator's capacity is dedicated to TSCA-regulated
PCB wastes. See Memorandum from Jose Labiosa, USEPA/OSW, Re: Conversation with
t ' -i
Chris Logelin, APTUS, (March 16,' 1993) (Diet. No. PH4P-S0127). As such, only 22.0t.. -,
tons x 0.3i or 6,600 tons, of the facility's total annual capacity is available for .
- It should be noted that although EPA's Capacity Analysis relies on the total
combustion capacity provided by all foiir 9s incinerators and. BIFs, its Regulatory Impact
Analysis assumes that the F03 2 wastes will be treated at the Coffeyville'faciliry. See,
Regulatory Impact Analysis of the Phase IV Land Disposal Restrictions (Draft). 3-6 n.12
(Aug. 7, 1995) (hereinafter "RIA"). Moreover, the volumes of F032 wastes assumed in
EPA's Capacity Analysis are 10 fold greater than that assumed in the RIA. Compare
rapacity Anafr^ at 3-8 (12,600 tons) with RIA. at ES-12, Exh. 3-2 at 3-5 (1,200 tons).
In short, the Capacity Analysis is based on one set of assumptions incineration of some
12,600 tons of F032 rionwastewaters in four 9s incinerators and BIFs - and the RIA. is
based on another series of assumptions - incineration of 1,200 tons of F032
nonwastewaters in the only six 9s facility permitted to handle such wastes. Sge RIA, 3-6
n.12. This glaring discrepancy in the methodologies used to support the rulemaking
serves to highlight the significant conceptual problems with the Agency's overall .
approach to establishing the F032 treatment standards.
-------
Commenter:
Comment Number:
Page Number:
4-24
Penta Task Force
32
15
incineration of non-PCB wastes. (And some portion of that capacity presumably is
already being used to burn dioxin-containing wastes.under the waste codes F020. F021,
'F022. F023, F026. F027 and F028.) In short, the capacity of the Coffeyville facility is
onh one-half that which would be needed to handle the F032 nonwastewater process
wastes. .
' Moreover, some 10,520 tons of F032-contaminated soil and debris are
generated annually at wood processing facilities and large volumes (perhaps as high as
102 million tons) of contaminated1'soils from past operations may require treatment. See
Capacity Analysis. 3-10 to 3-11. Although EPA has proposed a two-year national
", ' '
capacity treatment variance for F032-contaminated soil and debris, neither the Capacity
Analysis nor the Regulatory Impact Analysis provide any indication of the significant
*
costs and capacity issues that necessarily will arise after the variance period ends and
these contaminated soils require treatment. EPA's failure to squarely address this
problem is another example of the significant conceptual problems associated with the
current proposal.
-------
Commenter:
Comment Number:
Page Number:
4-25
Penta Task Force
32
15
.
C The Treatment Costa Will Be Prohibitive.
EPA has seriously understated the treatment costs for the volumes of F032
nonwastewaters that will become subject to the rule. In its Regulatory Impact Analysis.
EPA has assumed that only some 1,200 tons of F032 nonwastewaters are generated each
year at the 49 wood processing facilities that would become subject to the F032 treatment
standards. RIA. ES-12, Exh. 3-2 at 3-5, 3-6. But that estimate is flatly inconsistent with
the 12,600 tons estimate found in the Capacity Analysis. As noted above, the Capacity .
-------
4-26
Commenter:
Comment Number:
Page Number:
Penta Task Force
32
16
Analysis estimates the F032 waste volumes at 22,000 tons per year; that estimate is based
" /~
on data gleaned from the 1993 Biennial Reporting System ("BUS"). The RIA. on the
other hand, derives-it estimate on the basis of 1993 production statistics multiplied by a
waste generation rate taken from a 1985 RCRA 3007 survey.
The methodology used in the Capacity Analysis more reliably reflects
actual F032 waste volumes. The BRS data used in the Capacity Analysis reflect recent
data reported by wood preserving sites on the actual quantities of wastes transferred off-
site for treatment or disposal during 1993. The 1985 RCRA 3007 survey, on the other
hand, was conducted at a time when most wood treating facilities were using surface
impoundments for waste management and therefore had limited ability to quantify waste
generation rates. Also, the RIA incorrectly asserts that the BRS report might reflect
double counting of waste streams. In point of fact, the procedures used by BRS to
collect the data were carefully designed to avoid double-counting. For these, reasons, the
volume estimates in the Capacity Analysis are more accurate than those presented in the
RIA. If EPA were to use these more accurate volume estimates to analyze costs, it is
clear as shown below that the cost of meeting the treatment standards at a six 9s
incinerator would be prohibitive. .
In estimating costs, EPA has evaluated the incremental cost of requiring
combustion of F032 nonwastewaters by a six 9's ORE incinerator against the cost under a
"no treatment option." RIA. 3-7. We believe that a more illustrative measure of costs
would be to compare the cost of incineration at a six 9s unit with the cost of incineration
at a four 9s unit Our consultant, H.M. Rollins, recently contacted representatives of the
-------
Commenten
Comment Number:
PageNumbeir
4-27
Penta Task Force
32
17.
Apms facility, and learned that the unit cost of incinerating dioxin-containing wastes at
that facility is currently $4.50/lb ($9,000/ton).- By comparison, the unit cost for
incineration at a four 9s incinerator is roughly S0.48/lb ($960/ton). The incremental cost
v -. . . '
of six 9s versus four 9s incineration thus is roughly S8,000/ton ($9,000 - $960 = $8,040).
The cost of incineration of the 12,600 tons of F032 nonwastewaters would be roughly
$113 million per year at the Coffeyville facility and roughly S12 million per year in a .
\ '
four 9s incinerator. The incremental cost of six 9s versus four 9s treatment of the F032
wastes is thus some $101 million per year. These prohibitive and unnecessary costs
-id need *o S: borne b* ±e relatively few wood preserving sites - 49 in all - that
would become subject to toe rule.
-------
4-28
Commenter
Comment Number
Page Number
Penta Task Force
32
26
A. EPA Should pstablish Incineration As An Alternative Treatment
Standard. ... ' ''
Incineration in a four 9s combustion unit currently is the only practicable
technology for treating F032 waste streams. Because of the stigma problem, that
(
technology will be Unavailable if the Agency sets treatment standards for dioxin/furan
constituents in the waste*
-------
4-29
Coramenter:
Comment Number
Page Number:
Penta Task Force
N3 ' v .'
2 X
As explained.in our comments on the August, 1995
Phase IV LDR proposal, numerical limits for dioxin and furan constituents of F032 waste
will raise treatment costs to prohibitive levels, will foreclose the only practicable avenue
for treatment --thermal treatment in combustion units that are subject to subtitle C
standards, and is inconsistent with EPA's past regulation of other similar chlorinated -_
waste that contain dioxins and furans (i.e.. F024 waste):
-------
4-30
Commenter:
Comment Number:
Page Number
Penta Task Force
JN3.
5
In short. Option 2 does not address the principle problem with the proposed dioxin/furan
treatment standard ~ the lack of available treatment capacity for such waste and the
exorbitant cost of treatment in those limited circumstances where the capacity does exist.
-------
.4-31 ' ..
I " . '
Commenter American Wood Preservers Institute ;''..
Comment Number: 39 ., '
Page Number: .24 ' . - .
EPA IGNORES THE STIGMA ASSOCIATED WITH DIOXIN AND FURAN WASTES
/ ' t ,--,.
EPA states that incineration should be able to meet the proposed treatment
standards for organic wastewaters and non-waste waters.*3 However, this ignores the
- . ;
stigma associated with dioxin and furan wastes.
EPA is aware of the dioxin and furan waste stigma and has acknowledged this it
i
directly and indirectly on several occasions, in 1991, the Agency noted that "the
commercial hazardous waste treatment industry tends to shy away from these (dioxin-
111 ' "
> i
containing) wastes, thus resulting in unnecessary delays in such treatment.'* The
Agency also acknowledged that incineration capacity is limited and "the possibility of
increased capacity in the future is constrained by EPA's 'Draft Strategy for Combustion
of Hazardous Waste', issued in May 1993.47
Presently, there is only one incinerator permitted to accept dioxin-containing
wastes in the United States - Rollin's APTUS facility in Coffeyville, Kansas. EPA has
"* '
not issued standards dealing with particuiate matter and dioxins/furans under its
. i * *. ,
combustion strategy. Given the strong public resistance to new incinerators, and the
huge costs associated with permitting a six-9's facility (several millions of dollars),
. ' ' ' ' v '
additional incineration capacity for these wastes is not likely.
45 60 FR 43685 (August 22,1995).
* See. Advanced Notice of Proposed Rulemaking (ANPR) "Laud Disposal Restrictions: Potential
Treatment Standards for Newty Identified and Listed Wastes and Contaminated Soils", 56 FR 55160,
55179 (October 24,1991X
*' See. "Presumptive Remedies for Soil, Sediments, and Sludges at Wood Treater Sites Quick Fact Sheet
(Draft)" (November 1994). .
-------
Commenter:
Comment Number:
Page Number:
COMMENT:
4-32
American Wood Preservers Institute
39
25
AWPI believes that sufficient incineration capacity does not exist to meet the
actual volumes of F032 wastes.
ALTERNATIVE TECHNOLOGIES TO INCINERATION DO NOT EXIST '
EPA states that "any available technology can be used to meet the LOR level,48
All of the so-called "alternatives" were evaluated by,the Office of Technology
Assessment (OTA) in 1991 Of the thirteen identified dioxin and furan treatment
technologies, only one (rotary kiln incineration) had been developed, permitted and-
used on a site cleanup.49 ;
COMMENT: ' -
AWPI is unaware of any alternative technology that has been developed to
commercial scale, permitted to receive, and capable of meeting the 1 ppb PCDD and
PCDF UTSs.
INCINERATION FOR F032 IS NOT'AVAILABLE'
EPA has based its treatment standards for F032 on incineration. The Agency
r -
estimates that the 49 plants using pentachloropheriol generate 12,600 tons of F032
non-wastewater process sludges and residuals per year. In addition, these plants will
generate some 10,500 tons of F032 soil and debris annually.
* 60 FR 43680 (August 22, 1995);
49 See, "Dioxin Treatment Technologies-Background Paper", U.S. Congress, Office of Technology
Assessment, < TA-BP-0-93, p. 13 (November 1991). ' , '
-------
4-33
. Commenter:.- . American Wood Preservers Institute
Comment Number: 39
Page Number. 26 . ,,,
' While not disputing that the technology has been demonstrated, AWPI questions
.how EPA can state that it is "available." Only one site (APTUS) is permitted to accept
dioxinrcdntaining wastes with a 19,500 to 24,500 tons per year capacity. Of that
amount, 70 percent is dedicated to;TSCA-regulated PCB waste leaving 5,850 to 7,350
tons per year capacity available for other waste streams.50
f ...'''. '
COMMENT: ' '.. ' , ' ' "
If one assumes that the APTUS' facility will dedicate the remaining 30 percent
capacity exclusively to burning F032 waste, and assuming the high end of the capacity
range (7,350 tons per year), the APTUS facility comes up short by 15,750 tons per -
.year. One six-9's facility does oot constitute "available" technology. .
-------
Commenter:
Comment Number:
Page Number:
4-34
Chemical Waste Management
48
38 .
Furthermore, it is not clear to CWM how the Agency's Combustion Strategy
will alleviate this problem at the Agency states it will. The establishment of
stricter dioxin and furan requirements on combustion facilities will still not
alleviate the dioxin myth in tht eyes of the public that has been perpetuated
by the Agency.
-------
Conimenter:
Comment Number:
Page Number:
- 4-35
Chemical Waste Mangement
N18 ^
2 . . ' '
CWM believes that the easiest approach to implement would be to establish INC1N
or CMBST as the treatment standard for the D/F constituents in the F032 wastes.
If F032 dioxihs and furans are regulated in this manner then CWM incineration
facilities will be much more likely to accept F032 waste streams than if specific
D/F constituents are regulated individually. ,
-------
4-36
Commenter
Comment Number
Page Number:
J H. Baxter
58.
1
J
Along with other members of the wood preservation
industry, J.H. Baxter is concerned about the impact of the pro-
posed 1.0 part per billion treatment standard for dioxins and
furans in the F032 wastestream* . J.H. Baxter believes there is
not adequate capacity for treatment of F032 wastes if a treatment
standard is established for dioxin constituents. Even with
adequate^apacity, the high cost of incineration would make the
economieMtoact on our company and other affected wood treating
We also have provided comments on the current classifi-
cation of wood preserving production waste waters as solid waste.
J.H. Baxter bel aves EPA should amend the regulations to exempt
recycled wood preserving waste,, waters .from the definition of
solid waste.
-------
4-37
Commenier:
Comment Number:
Page Number:
J.H. Baxter
58
2.
I. Treatment Standards for F032 Wood Preserving wastes
A'. EPA'a Proposal Does Not Address Capacity Shortfall
issues - ; ' ' ^ .-?-.
J.H. Baxter uses pen*:achlorophenol (penta) to treat
wood products/ primarily utility poles and utility pole cross-
arms, that are exposed to extreme weather conditions for extended
periods of service. The treating solution for these wood
products consists of penta and oil/ usually fuel or diesel grade.
Consequently, F032 wastestreama have high energy values. They
are.accepted at permitted incineration facilities as alternative
energy sources. If the proposed regulation with the associated
dioxin standard is adopted, the wood preserving industry no
longer will be able to utilize the facilities currently permitted
to burn F.032 wastes. , ,-'':'
_ *"
In 1991 EPA requested data and comments on treatment
standards for many newly listed RCRA wastes, including F032
wastes. At that time, the Agency,noted that in its experience
when dioxin and furan constituents are proposed for regulation in
waste-specific treatments, the hazardous waste industry "tends to
shy away" from the treating such wastes, creating delays in
treatment. 56 Fed. Reg.,55160, 55179 (Oct. 24, 1991). The
proposal stated that the delays result "due to the acute sensi-
tivity of the public to these constituents and the increase in
liability resulting from handling them." ££. In effect, these .
wastes are pariahs as far as the public and the hazardous waste
treatment industry are concerned. EPA, therefore, solicited
ideas on how FO32 treatment standards could be constructed, so as
to avoid anticipated bottlenecks in treatment for these wastes.
, , In the current proposal, EPA notes that many commentors
to its 19*4 notice expressed, concerns that facilities would not
accept tb«r032 waste if the treatment standards include a dioxin
limitatifljpT J.fl. Baxter shares these concerns. J.H. Baxter has
been informed by Laidlaw Environmental, the commercial hazardous
waste facility currently handling bur F032 wa»testreams, that
Laidlaw will not accept these wastes if the dioxin standard for
F032 wastes is adopted. J.H. Baxter has no doubt that it will
be extremely difficult, if not impossible, to obtain timely
treatment for F032 wastestreams, should dioxin constituents be
regulated. ^
-------
4-38
Commenter:
Comment Number:
Page Number:
J H.Baxter
58".
3
in contrast to the concern about treatment delays it
viewed as serious in 1991, EPA now curtly dismisses the'issue in
one sentence, stating that the1Agency's ""Combustion Strategy"
will alleviate this problem. 60 Fed. Reg. at 43682. In
reviewing the proposed regulation there is no discussion of the
"Combustion Strategy" or whether facilities legally will be able
to accept and treat wastes with the associated dioxin standard
using this "Combustion Strategy.", ,
Presumably, the "Combustion Strategy* refers to a draft
policy statement issued by EPA on May 18, 1993, that discusses ,
both short and long-term goals for incinerators and industrial
furnaces. It is impossible to ascertain how this policy state-
ment can alleviate the unwillingness of the hazardous waste
industry to accept F032 wastes if a dioxin standard is imposed.
As noted earlier by EPA, refusals by commercial hazardous waste
treaters to accept wastestreams with specific dioxin standard's
are based on public sensitivities.and concerns about increased
liability. Changes in permitting requirements or incinerator
capacity applicable to a iioxin standard for F032 may be goals of
EPA'a draft policy. These goals currently have not changed
public perceptions or decreased liability concerns for waste
treaters. No treatment standard should be tied to these changes
until they are realities.
r
In the newly proposed regulation, EPA has identified
only one commercial facility currently permitted to combust .
wastes that may have PCDO and PCDP constituents with concen-
trations above the treatment standard proposed for F032 wastes.
60 Fed. Reg. at 43681. It is our understanding that this
incineration facility has- an annual capacity of only 22,00" tons.
Seventy percent of this annual capacity is devoted to incinera-
tion of TSCA-regulated wastes contaminated with polychlorinated
Therefore, this facility has additional annual capa-
city tof" 6,600 tons of wastes from RCRA-regulated disposal
this predictable, extreme capacity shortfall is not
all by EPA in the proposal.
-------
Commenter:
Comment Number:
Page Number:
4-39
Hazardous Waste Management Association
97
17
The Agency is proposing a national capacity variance for soil and debris contaminated with
Phase IV newly listed wastes. HWMA supports this proposal in principal; however, it is not
clear whether this includes D004-D011 newly identified wastes. The Agency states that. "EPA
is proposing a national capacity variance for soil and debris contaminated with Phase IV newly
listed wastes" (60 FR 43686). This statement implies that the capacity variance is for all newly
identified Phase IV soil and debris, a universe which does include D004-D011 newly identified
wastes. However, the Agency does not indicate that this national capacity variance is being
-------
4-40
Commoner:
Comment Number:
Page Number
Hazardous Waste Management Assocation
97 .
18 ' .
Furthermore,
it is not clear how the Agency's Combustion Strategy will alleviate this problem as asserted by
the Agency. The establishment of stricter dioxin and ftiran requirements on combustion facilities
will still not alleviate the myth in the eyes of the public that dioxin is the most toxic compound
known to man and that no exposure is acceptable.
-------
4-41
Commenter: DOW
Comment Number: N9.
Page Number: 2 .
2 and 3 also raise n
capacity questions which EPA must addrei
before further coniidjratigiLoLadop.ting such constraint; on procied
-------
4-42
Commenter: DOW
Comment Number. N9
Page Number: 3
In considering the additional limitations described in Suboptions 2 and 3, EPA has not
addressed whether sufficient available capacity would remain which is licensed to treat the
volume of F024 and F032 currently generated. Dow alone currently generates over
50,000 tons per year of F024 at its U.S. facilities. Implementation of Suboptions 2 or 3
would require a significant portion of that waste volume to be managed offsite in
commercial units. Before proceeding, EPA must analyze the U.S. wide generation of the
potentially impacted waste codes considering how much available treatment capacity '
would be available after such requirements would go into effect
-------
4-43
4.5 CAPACITY FOR F032 WILL NOT INCREASE
Summary:
' In the proposed rule, EPA stated that although some commenters to the ANPRM (56 FR 55160)
had expressed concern that treatment facilities would not accept F032 waste if the treatment standards
include a dioxin concentration, EPA believed that its Combustion Strategy would alleviate this problem.
Many commenters to the proposed rule stated that new available capacity for F032 wastes will not . '
. become available due to the stigma associated with dioxins and requested that EPA explain how the
Combustion Strategy will address the stigma associated with dioxins and furans [Beazer East (23); Perita
Task Force (32); American Wood Preservers Institute (39); Chemical Waste Management (48); J.H.
Baxter (58); HWMA (97)]. Beazer East and American Wood Preservers Institute both believe that given
the current public sentiment a new permit for incineration of dioxins and furans will never be issued
(23:4,8-10; 39:24-26). Penta Task Force stated that dioxin emissions are not the real problem behind the "
treatment industry's reluctance to accept dioxin/furan containing-wastes, but that the real issue is a
reluctance by incineration facilities to analyze their ash and residuals for dioxin/furans because they are
likely to exceed the'l ppb standard stated in the proposed rale (32:2-3). Chemical Waste Management,
J.H. Baxter, and the Hazardous Waste Management Association all stated that the Agency's Combustion
Strategy will not alleviate public concern over dioxins (48:38; 58:4-5; 97:18).
Response: ' ' , ' *
In today's rule EPA is not requiring the combustion of F032 wastes in a "six 9's" destruction and
removal efficiency combustion device. Therefore, facilities may combust F032 wastes at any RCRA
facility regulated under .CFR Part 266 or 264, Subpart O without having to monitor the concentrations of
dioxins and furans left behind in the combustion residues. This alternative should eliminate the stigma
types of concerns raised by commenters. In addition, facilities may also combust F032 wastes in
combustion devices regulated under CFR Part 265, Subpart O units, provided the residues meet the
applicable standards for each regulated dioxin or furan constituent, or make a^dembnstration that their
combustion is at least equivalent to that required of permitted incinerators or Part 266 BIFs, in which
case these interim status incinerators would also have the option of not monitoring for dioxins. in
combustion residue. Under EPA's Combustion Strategy, EPA has directed permit writers to determine ,
whether the combustion of low level dioxin wastes is being conducted in a manner that is protective of .
human health and the environment. EPA believes that the final approach to F032 wastes is consistent
with this Combustion Strategy by providing a compliance alternative for those units required to comply
with standards assuring gpod combustion efficiency, or that demonstrate such efficiency. Furthermore,
as seen in Chapter 2 of this background document, the Agency accounts for the potentially lower
available combustion capacity resulting from the treatment standards chosen for F032 wastes and still
'finds ample capacity available. -.''
l r
Comments: . ,
' ' ' ' . i
See next page. . ' .'::
-------
4-44
Commenter:
Comment Number:
Page Number:
Beazer East
23
4
As discussed- in greater detail below/ the Agency's proposed LOR for
dioxin/furan congeners (hereinafter referred to as "dioxin/furan") as .constituents of
F032 LDR lacks scientific justification and will create insurmountable disposal
problems. -For example, EPA has determined that its proposed one part per billion
C'ppb-") concentration limit for dioxin/furan can be achieved by incineration, without
considering the consequence of only one incinerator being licensed in the UnitSd
.States to accept such waste. Furthermore, EPA has intentionally, through its Draft
Combustion Strategy For Combustion of Hazardous Waste, May 1993 ("Combustion
Strategy"), created significant impediments ,to the issuance of new permits /or
additional hazardous waste incinerators. Moreover, as Beazer has consistently
maintained in its previous comments, the public simply refuses to tolerate the risks of,
I
new incineration, particularly with respect to the more controversial substances such
as PCBs or dioxinsi Under these circumstances, any thought of obtaining a new
permit for an incinerator which would be used to incinerate dioxin/furan is
unfathomable.
-------
4-45
Commenter: BeazerEast
Comment Number 23
Page Number 8 .
II. EPA HAS FAILED TO CONSIDER THE TECHNICAL. ECONOMICAL AND
PRACTICAL IMPACTS OF THE PROPOSED LDRs ON REMEDIATION
r -
EPA's Proposed Rule fails to consider a number of critical issues related to the
remediation of wood treating sites. These issues involve LDRs for F032, F034 and
F035 as discussed below. :
A. The Proposed LDRs for Hazardous Waste No. F032 Will Create
Insurmountable Disposal Problems. ' ' _. ..
s '
1. Dioxin/Furan should not be regulated constituents under the F032
. Regulation of dioxih/furar as constituents under the F032 LOR is
** . *
scientifically unwarranted. One of the first LDRs for dioxin/furan-containing wastes
was established by EPA for F027.2 EPA established the F027 LDR at 1 ppb (in
leachate) and is ndw arbitrarily applying the 1 ppb standard to F032. .
,'..-:. (.-', r " " ' .' '
; ' EP,A's characterization of F027 as acutely hazardous was based
on trace levels of hexachlorodioxins. See Toxico/ogical Profile for Pemachlorophenol ,
2 EPA «stablish«d LORs for the "dioxin-wattw" F020-23 and F026-28 in one rulamaking on January
14. 1986. 51 F«d. Reg. 1602.
-------
4-46
Commenter
Comment Number:
Page Number:
Beazer East
23
9
May 1994, Agency for Toxic Substances and Disease Registry (ATSDR). EPA
considers hexachlorodioxins as potent animal carcinogens. Id^ This characterization
V > .. "_ '
of hexachlorodioxins is not technically founded and is even refuted by the results of
a bioassay performed by the National Toxicity Program ("NTP") in 1989,'the results
of which were reported in NTP-TR-349 and in NIH Publication 89-2804 (the "NTP
cancer bioassay"). As noted in a November 27, 1991 letter from Vulcan Chemicals
to EPA (the "Vulcan Letter") (obtained from the RCRA docket), the NTP cancer
bioassay on penta conclusively demonstrated that any cancer response observed in
exposed laboratory animals was due to the toxic overexposure of the test animals to
penta and not to the trace amounts'of hexachlorodioxin present. See the Vulcan
Letter, p.3,.
Moreover, .the EPA's Science Advisory Board's ("SAB's") recent
evaluation of EPA's draft dioxin risk reassessment documents has sharply criticized
EPA's reliance on the standard default assumption of a linear non-threshold model for
carcinogenic risk and has called for a substantial rewrite of the assessment. The SAB
concluded that one major weakness of the assessment was that the presentation of
scientific findings portrayed in the draft conclusions was not balanced and exhibited
.a tendency to overstate the evidence of danger. .
Accordingly, Beazer believes that EPA currently is without
sufficient scientific bases for regulating dioxin/furan as a constituent of F032.
-------
Commemer:
Comment Number
Page Number:
4-47
Beazer East
23
10
RECOMMENDATION:
Given that EPA has yet to scientifically demonstrate and support the risk from
low level exposure to dioxin/furan, Beazer recommends that EPA exclude dioxin/furan
from regulation as part of the F032 LORs until agreement on the scientific
, /
underpinnings of this regulatory action is achieved.3'
Beazer has serious doubts regarding the Agency's rote reliance on technology-based standards to
meet UDRs. The. Agency has discretion to utilize either a risk-based or, technology-based, standard,
American Petroleum Institute v. EPA. 906 F.2d 729 (O.C. Cir. 1990} and in the case of dioxin/furan. Beazer
believes that a site-specific risk-based standard is more appropriate on both a scientific and practical basis.
If EPA retains dioxin/furan as an indicator parameter for F032. the standard should not be identical for all
congeners. EPA has determined that 2,3,7,8-TCDD is the most toxic of .the dioxin/furan congeners. 51
Fed. Reg. 1732. In order to assess the risks posed by dioxin/furan other than 2,3,7,8-TCDD, EPA adopted
an interim procedure for assessing the risks to human health based on toxicity equivalency factors ("TEFs")
which permits the conversion of any dioxin/furan congener into an equivalent concentration of 2,3,7,8-
TCDD or Toxicity Equivalents CTEQs"). IgY In 1989. EPA adopted the International TEFs which are
presented below for the six dioxin/furan congeners in the proposed LDRs for F032. .
Compound ' . " Toxicitv Equivalent Factor' ,
Tetrachlorodibenzo-p-dioxins 12,3,7,8-TCDOs)
Pentachlorodibenzo-p-dioxins (2,3,7,8-PeCOOs)
Hexachlorodibenzo-p-dioxins (2.3,7,8-HxCDDs)
Tatrachlorodibenzo-p-furans (2,3,7,8-TCDFs)
Pantachlorodibenzo-p-f urans (2,3,4,7,8-TCDFs)
Hexachlorodibenzo-p-furans (2,3,7,8-HxCDFs)
1.0
0.5
0.1
0.1
0.5
0.1
See Interim Procedure* for Estimating Risks Associated With Exposures to Mixtures of Chlorinated Otbenzo-
p-dioxins end -dibenzofurans {CODs end CDFsi. U.S. Environmental Protection Agency, Risk Assessment
Forum, Washington D.C. EPA/625/3089/016 (1989).
, All of the dioxin/furan congeners shown above exhibit significantly let* toxicity than 2,3.7,8-TCDD.
The one congener that» associated with pentachlorophenql. HxCDDs, is 10 times less toxic than 2,3,7,8-
TCOD. Clearly, the proposed LDR treatment standard for nonwastewaters of 1 ppb for all the listed
dioxins/furans other than possibly 2,3,7,8-TCDD is not consistent-with the risks identified in the recent
scientific literature associated with each of the congeners. Moreover, EPA has acknowledged that
dioxin/furan wastes are immobile. 51 Fed. Reg. 1602 (January 14. 1986). Thus, the risk associated with
F032 wastes placed in a secure Subtitle C landfill is dramatically different than the residential risk scenario
EPA has utilized to develop dioxin/furan action levels.
-------
. 4-48
Commenter: American Wood Preserves Institute
Comment Number: 39
Page Number: , . 24
EPA IGNORES THE STIGMA ASSOCIATED WITH DIOXIN AND FURAN WASTES
EPA states that incineration should be able to meet the proposed treatment
standards for organic wastewaters and non-wastewaters.49 However, this ignores the
stigma associated with dioxin and furan wastes.
EPA is aware of the dioxin and furan waste stigma and has acknowledged this it
directly and indirectly on several Occasions. In 1991, the Agency noted that "the
commercial hazardous waste treatment industry tends to shy away from these {dioxin-
containing) wastes, thus resulting in unnecessary delays in such treatment.'40 The
Agency also acknowledged that incineration capacity is limited and "he possibility ef
increased capacity in the future is constrained by EPA's 'Draft Strategy for Combustion
of Hazardous Waste", issued in May 1993.47
Presently, there is only one incinerator permitted to accept dioxin-containing
wastes in the United States - Rollin's APTUS facility in Coffeyville, Kansas. EPA has
not issued standards dealing with particuiate matter and dioxins/furans under its
combustion strategy. Given the strong public resistance to new incinerators, and the
huge costs associated with permitting a six-9's facility (several millions of dollars),
additional incineration capacity for these wastes is not likely.
4160 FR 43685 (August 22,1995). .
46 SfiS, Advanced Notice of Proposed Rulemakiiig (ANPR) "Land Disposal Restrictions: Potential
Treatment Standards for Newly Identified and Listed Wastes and Contaminated Soils", 56 FR 55160,
55179 (October 24, 1991).
47 See. "Presumptive Remedies for Soil, Sediments, and Sludges at Wood Treater Sites Quick Fact Sheet
(Draft)" (November 1994).
-------
Commenter:
Comment Number:
Page Number:
4-49
American Wood Preserves Institute
39 ' -
25 ' , -
COMMENT:
" - f * " ' *
AWPI believes that sufficient incineration capacity does not exist to meet the
actual volumes of F032 wastes.
-------
Corrimencer:
Comment Number:
Page Number:
4:50
American Wood Preserves Institute
39
26
While not disputing that the technology has been demonstrated, AWP! questions
* . .
how EPA can state that it is "available.' Only one site (APTUS) is permitted to accept
.' . f ' .
dioxin-containing wastes with a 19,500 to 24,500 tons per year capacity. Of that
amount, 70 percent is dedicated to TSCA-regulated PCB waste leaving 5,850 to 7,350
tons per year capacity available for other waste streams.90
" . ' X
COMMENT:. . . ^ ,-
If one assumes that the APTUS facility will dedicate the remaining 30 percent
capacity exclusively to burning F032 waste, and assuming the high end of the capacity
range (7,350 tons per year), the APTUS facility comes up short by 15,750 tons per -
year. One six-9's facility, does not constitute 'available" technology.
-------
4-51
Commenter: Penta Task Force
Comment Number: 32
Page Number 2
''... . ' ' . As EPA
is aware, there is a'stigma associated with wastes containing dioxins and'turans. In the
past, when the Agency has attempted to set treatment standards for dioxin and furan
*. ' v, '
" . ' ' , ' ','"-
constituents in wastes, commercial treatment facilities have refused to ^accept the wastes
and the result has been a severe shortfallin treatment'capacity.. In the case of chlorinated
aliphatic hydrocarb9n manufacturing ("F024") wastes, the situation was sufficiently grave'
to require EPA to.alter the regulatory standard to delete the dioxin and furan limits and to
offer incineration as an alternative treatment standard. .
: i EPA now suggests that its proposed combustion strategy will solve the
stigma problem. The Penta Task Force disagrees. The standards contemplated under the
combustion strategy have not yet been proposed and, even under the most ambitious
rulemaking schedule, would not be in place in time to address the capacity shortages that
. - ' ' *»''
are expected to result from the present rulemaking. More importantly, the combustion
-' , ' ' \ "
strategy is targeted at reducing dioxin emissions and, as such, does not address the real
problem behind the treatment industry's refusal to accept wastes that are governed by
(
dioxin and fiiran treatment standards - the > reluctance of incineration facilities to analyze
their ash and other combustion residuals for dioxins and furans. As EPA is aware, the
residuals from combustion of certain chlorinated wastes that are currently handled by
* "'
i ' ~ .-"' ' ' * "",
' these facilities are likely to contain dioxins and furans at appreciable levels far above the
1 part-per-billion ("ppb") standard for dioxin and furan constituents contemplated in the
-------
4-52
Commenter:
Comment Number:
Page Number:
Penta Task Force
32
3
proposed rule. It is this fact, not the levels of dioxins and ftirans in incinerator emissions,
that accounts for .the treatment industry's reluctance to accept wastes regulated by
t f
dioxia furan treatment standards. Moreover, as we show, even after combustion units are
- \ -
upgraded to meet the new standards contemplated by EPA's combustion strategy, the
residues contained in the air pollution control devices at the. "upgraded" units are still
likely to exceed the I ppb dioxin/'furan limits. ,
-------
4-53
Commenter:
Comment Number:
Page Number:
Chemical Waste Management
48
38
Furthermore, it is not clear to CWM how the Agency's Combustion Strategy
will alleviate this problem as the Agency states it will, the establishment of
stricter dioxin and furan requirements on combustion facilities will still not
alleviate the dioxin myth in the eyes of the public that has been perpetuated
by the Agency. . ,
-------
4-54
Commenter:
Comment Number:
Page Number:
J.H. Baxter
58
4
EPA currently does not have adequate information about
the economic impact of thia proposal on the wood treating indus-
try. There have been,several requests made to EPA to defer or
forego the regulation of PCDD and PCDF in F032 wastestreams based
on the belief that regulation of surrogate constituents such as
pentachlorophenol, total suspended solids and oils and greases,
in F032 will provide adequate treatment. EPA received no data in
support of these proposals and, therefore, has proposed to regu-
late dioxin constituents. .
. . ' j * '
Mow EPA in the discussion of its compliance with the
regulatory impact analysis requirements of Executive Order 12866
has requested better information on potentially impacted facili-
ties, waste volumes and constituents, concentrations, additional
treatment: requirements and treatment costs. Further, other cost
estimates|t.iMfid by EPA in its regulatory analysis of the impact of
the Phasefijf Land Disposal Restrictions are based on industries
that us* iSwtewater treatment surface impoundments and other
wastewater practices not used in the wood preserving industry,
and consequently which have no applicability to the economic
impact on .the wood preserving industry of these regulations.
J.H. Baxter requests that SPA defer a decision on
regulating dioxin constituents in f o2 wastestr:.ic;s until it
obtains better information to esti..,*te accurate-/ the economic
impact on the wood preserving industry, and particularly on the
small facilities in that industry/ Additionally, EPA should
-------
4-55
Commenter: J.H. Baxter
Comment Number: 58
Page Number: 5
defer this decision until it haa information to determine whether
the extraordinary increases in disposal costs that would be
associated with a dioxin standard.would be commensurate with any
additional protection for the public derived from the standard.
-------
4-56
Commenter
Comment Number-
Page Number:
Hazardous Waste Management Association
97
18 , .
Secondly, the Agency has not adequately considered the extent of the existing capacity to
combust this waste as.supported by the Agency's own statement that, "EPA has identified one
commercial facility currently permitted to combust wastes that may have PCDD and PCDF
constituents with concentrations one to two orders of magnitude higher than those levels found
in F032" (60 FR 43682). This statement contradicts the Agency's capacity analysis which
indicates that there is sufficient incineration capacity for wood preserving waste streams
Currently, there may be incineration capacity for the F034 wastes; however, that capacity does
hot include capacity for dioxins and rurans that are proposed as BOAT for F032. Furthermore,
it is not clear how the Agency's Combustion Strategy will alleviate this problem as asserted by
the Agency. The establishment of stricter dioxin and ruran requirements on combustion facilities
will still not alleviate the myth in the eyes of the public that dioxin is the most toxic compound
known to man and that no exposure is acceptable. As a result, the Agency should reevaiuate this
.position and either promulgate a two-year national capacity variance or remove the dioxins and
furans from the F032 treatment standards.
-------
4^57
4.6 NO ALTERNATIVE DIOXIN/FURAN TECHNOLOGIES ARE COMMERCIALLY
AVAILABLE
Summary: . . ; . .
Several commenters noted that none of the alternative technologies proposed by EPA for dioxin
and furan wastes have been developed to a commercial scale, are permitted, and are capable of meeting
the standards for these constituents [Beazer East (23); Penta Task Force (32); American Wood Preservers
Institute (39)]. Beazer East described problems associated with each proposed technology (BCD
technology, Shirco infrared thermal process, Hubber supercritical oxidation process, pyrolitic
destruction, APEG and KPEG processes, ultraviolet photolysis," bibtreatment) (23:12-17). Penta Task
Force stated that EPA is unjustified in reliance on non-demonstrated, innovative technologies to resolve
capacity shortfall for treatment of dioxin and furan wastes, and provided a detailed evaluation of
alternative non-combustion technologies for the treatment of F032 wastes (32:19-21, Att.A). American
Wood Preservers institute stated that of the 13 identified dioxin and furan treatment technologies, only
one (a rotary kiln incinerator) has been developed, permitted, and used on a site cleanup (39:25).
' \
Response: / . ". . . .
Given the treatment standards being finalized today, EPA has determined that adequate capacity
exists to treat the newly listed wood preserving wastes (other than soil and debris; see Section 4.9). In
addition to traditional combustion treatment technologies, facilities may also use alternative non-
combustion technologies to meet these standards. Any non-combustion treatment capacity that can meet
the LDRs for the newly listed wood preserving wastes will serve to increase the available treatment
options for these wastes. However, even if there is no capacity available for the alternative technologies
cited in the proposed rule, there should not be a capacity shortfall for the newly listed wood preserving
wastes (see Sections 4.3 through 4.5).
EPA does agree, however, that a capacity shortfall will exist for soil and debris contaminated
with the newly listed wood preserving wastes. As described in Chapter 2 of this document, EPA.
estimates that the required treatment capacity for contaminated soils arid debris is over 100,000 tons per
year while the maximum available treatment is likely less than 50,000 tons per year. For this and other
reasons'(discussed in Chapter 3), EPA is granting a two-year variance for soil and debris contaminated
with the newly listed wood preserving wastes.
Comments:
' ' ' '
See next page. . .. >
-------
. 4-58
Cornmenter:
Comment Number:
Page Number:
Beazer East
23
12 ,.
3. The proposed LDR for FQ32 will force incineration as the only
treatment alternative.
Beazer believes the selection of incineration as the Best
Demonstrated Available Technology ("BOAT") is arbitrary and erroneous, because
although the technology may be "demonstrated,".it is clearly "not available." EPA's
forced incineration mandate does not realistically consider the issues associated with
public resistance', capacity, cost, or commercial viability. Although EPA states in the
Proposed Rule that the LDR level can be met using "any available technology," 60
Fed.,Reg. 43680, Col. 3., and although Beazer believes that flexibility in treatment
technology selection is imperative for both wastewaters and nonwastewaters, as
« i ^ w
discussed in these comments, just sayinjg it "doesn't make it so." The reality of the
performance capabilities of alternative treatment technologies (other than incineration)
associated with dioxin/furan'treatmerit leads to the unescapable conclusion that the
only arguably "available" technology to meet the proposed Universal Treatment
Standards ("UTSs") is incineration and its "availability" is seriously limited or non-
existent as discussed more fully below.. , .
1
To Beazer's knowledge, no alternate technologies have been
i ' " . .
developed to commercial scale that are permitted and capable of meeting the
nonwastewater dioxin/furan UTSs of 1 ppb. The alternate technologies noted in the
Proposed Rule are not options for remediation. These technologies are evaluated in
the Dioxin Treatment Technologies-Background Paoer (U.S. Congress, Office of
Technology Assessment ("OTA"), OTA-BP-O-93, Nov. 1991) (the "Dioxin Treatment
Document") wherein OTA notes that of thirteen identified types.of dioxin/furan
-------
4-59
Commenter: ' Beazer East
Comment Number: 23
Page Number: 13
treatment technologies jn development, only one, rotary kiln incineration, has been
*' *.
tested, .permitted, and actually used on a site clean-up for dioxins/furans. Dioxin
Treatment Document, p. 13. Two other technologies (liquid injection incineration and
.fluidized bed incineration) were built and tested, but both are incineration technologies
. . * <
r . ' ' " .
i , *'
and.neither has been used in a dioxin/furan site clean-up. ]d_.. pp. 17 & 19. Neither
\
technology has been directly available to U.S. sites because the former is a sea-based
process for treating b.nly thin slurries and combustible liquid wastes and the other is-
a European developed and tested technology that has not yet been permitted for
: * ' f ' -
destruction of dioxins/furans. Id. The remaining thermal and non-thermal technologies
noted in the Dioxin Treatment Document (which include those noted in the Propcrsed
Rule) were all in either, the research, bench scale, or.pilot scale stages of development-
and have significant limitations as noted below.
a. BCD Technology
EPA has asked for comment on the use of BCD technology
'...-. ^. *.,'' . /
and other technologies to treat dioxin/furan. 60 Fed. Reg. 43681, Col. 3. Beazer
does not believe that the BCD technology has been sufficiently demonstrated to
I ' ' '
warrant its inclusion in the list of candidate nonwasiewater treatment technologies.
Our information suggests that EPA researchers, at its Risk Reduction and Engineering
, \ *
Lab ("RREUORD"), advised that demonstration tests at two sites have-resulted in
evidence that the dechlorination process in the "liquid reactor" is not successfully
performing, specifically for dechlorinating dioxin/furan. A test in 1993 indicated that
-------
4-60
,Commenter: ,
Comment Number:
Page Number: :
BeazerEast
23-
14
dioxin/furan could.be removed from soils, but the off-gas stream treatment could not
Devaluated due to analytical interferences.4 A recent 1 995 test in Region X was
* .
terminated due to the inability of the process to meet the air emissions standards for
i'
dioxins/furans. Id. ,
b.
Shirco Infrared thermal Process
The Agency has suggested in the Proposed Rule tnat the
Shirco infrared thermal process can be used to treat dioxin/furan. 60'Fed. Reg.
V i .
43681. This process was tested by EPA in 1987 for destruction of PCBs. ig^
However, Beazer found no data in EPA's Superfund Innovative Technology on-line
database regarding use of the technology for destruction of dioxins/furans. Indeed,
j
the Dioxin Treatment Document indicates that although infrared destruction has
advanced to commercial use in Germany, no permitted facilities exist in the United
States for destruction of dioxins/furans. Dioxin Treatment Document, p. 26.
c'.
Hubber Supercritical Oxidation Thermal Process
The Agency also suggests that the Hubber supercritical
oxidation process can be used to treat dioxin/furan wastes. 60 Fed. Reg. 43681, Col.
3. According to the Dioxin Treatment Document, however, the Hubber supercritical
oxidation thermal process referred to in the Proposed Rule can only be used to treat
liquid wastes and perhaps finely ground, thin slurries. Dioxin Treatment Document,
Teleconferences with Terrance Lyons of ORD/RRELon 8/15/95 and 10/25/95.
-------
4-61
Commenter: - Beazer East
Comment Number: 23
Page Number: 15-
p. 60. It has not been tested at a commercial scale on any solid wastes or even the
proposed thin slurries, thus further limiting its appropriateness as a viable technology.
Id* _ - '.'-'.
d. Pyrolitic Destruction - .
/ Pyrolitic destruction is anothertechnology that EPA believes
is capable of treating dioxin/furan wastes. Id. Like the Hubber process, pyrolitic
r *
'destruction of dioxin/furan has the same limitations in that it can only treat liquid
% i ' " '
wastes and perhaps finely ground, thin slurries (with a viscosity similar to 30 wt.
' ( . ...
motor oil). The technology is being pursued by only one company and has not been
demonstrated at commercial scale for destruction of dioxin/furan, Dioxin Treatment
" - * ' "" '
Document, p. 60. ,
' - '' e. APEG and KPEG Processes
.In the Proposed Rule, EPA requests comments on whether
the APEG or KPEG processes can be used to meet the dioxin/furan LDRs. Id. The
APEG and KPEG processes were introduced in the 1980s and found application at
commercial scale for dechlorinating organic fluids and oils. However, the treatment
of nonwastewaters has not progressed successfully since its introduction. As an
- ^ . . . . ' ' '
example, a Region VI CERCLA site in Houston .mobilized a full scale APEG treatment
system owned by Galson Research Corporation six or seven years ago and was unable
-------
4-62,
Commenter: Beazer East
Comment Number: . 23 . ' . .-'
Page Number: 16
to meet the treatment requirements for PCBs. The unit was demobilized and Galson
has not pursued the technology, further.
f.
Ultraviolet Photolysis
. EPA has also requested information on,the use of ultraviolet
photolysis in treating dioxin/furan/ 60 Fed. Reg. 43682, Col.. 1. The use of ultraviolet
1 "*.'.
photolysis .for destruction of dioxin/furan'in soils requires dissolution of the
dioxin/furan from the soil into a solvent extract and subsequent destruction of the
dioxin/furan in the liquid solvent. This technology will face the same developmental
difficulties impeding the development of critical fluid extraction for soils {material
handling and agglomeration) and for the BCD liquid reactor (destruction of the
dissolved dipxins/furans in the solvent extract to levels low enough to allow recycle
of the solvent). Further, the process has not yet been demonstrated at commercial
scale.
g. Biotreatment . :
Finally, the Agency proposes the use of biotreatment for
waste water. 60 Fed. Reg. 43681, Col. 1. Beazer contacted several water treatment.
equipment manufacturers to verify that the proposed treatment standards could be-
achieved with the specified technologies. Zimpro, the manufacturer of one of the
most effective waste water biotreatment systems available had no data to support
removal of dioxin/furan to the proposed UTS levels. Because the ability of
biotreatment to achieve the very stringent dioxin/furan UTS levels for wastewater was
-------
Commenter:
Comment Number:
Page Number:
4-63
Beazer East
23
17 ;
not confirmed by Beazer's contacts with equipment vendors, Beazer requests that EPA
provide performance data to confirm the assertion made above regarding biotreatment
of wastevyaters. - , . :
RECOMMENDATION: ';.'.- ^ . - .
"Beazer recommends that EPA critically and' realistically! re-evaluate" the
technologies, which it has suggested are alternatives .to incineration. These
technologies have -not been demonstrated as effective treatment for dioxin/furan
congeners and EPA should not imply that they are "available." By setting standards
that can only be met using incineration, EPA is improperly excluding other viable
treatment systems for wood preserving site remediation waste, and placing the
regulated community in the untenable position of having no workable options for
managing remediation waste containing F032.
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4-64
Commenter: Penta Task Force
Comment Number: 32
Page Number: "19
E. EPA Can Not Property Relv Upon Alternative Technologies To
Solve The Capacity Problem.
: EPA's contractor has acknowledged that because incineration capacity for
dioxin/furan wastes is severely limited, EPA has sought to identify alternatives to
-------
4-65
Commenter: Penta Task Force . -
Comment'Number: 32 . , . '
Page Number: .20 ^ . .
r . '
incineration as BDAT.for F032 wastes. See Memorandum from J. Castellanos, Versar.-to
- ; - /
\ ' '
L Labiosa, EPA, Evaluation of Management Alternatives to Incineration for
Dioxin/Furan-Cohtaminated F032 Wastes (June 30, 1992) (Dkt. No. F33P-S0318). As
part of that effort, EPA has. considered various chemical, non-incineration thermal,
*
physical, and biological methods as potential BOAT alternatives. None of the alternate .
treatment methods evaluated by EPA can serve as BOAT for F032 wastes, because not a
single one of these alternatives is a "demonstrated" treatment technology. As EPA has
explained:
its [BOAT] determinations should not be based on emerging
and innovative technologies. This would be in .violation of
the intent of the statute as indicated in the legislative .
history . ... To be considered a "demonstrated" treatment
technology for purposes of the final rule, a full scale facility
must be known to be in operation for the waste or similar
; wastes. " " . ' . -
' .1 .
\ : , .
51 Fed. Reg. 40,572, 40,588 (Nov. 7, 1986). ...
Because, as the background documents make clear, the various alternative
technologies are not in commercial operation, they cannot be BOAT for F032 wastes.
Indeed, in each case, the data considered by the Agency on a given alternate technology
pertains only to laboratory or bench-scale tests or pilot scale tests on dissimilar waste ,
streams (generally PCB-contaminated soils). See June 30, 1992 Castellanos Memo
(summaries of tests on APEG method (laboratory tests only); SEA MARCONI method
(experimental); pyrohydrolytic dechlorination method (bench-scale experiments); UV
photolytic methods (pilot-scale experiments); UV oxidation method (bench-scale); in-situ
verification method (bench, pilot and field tests); in-situ stabilization method (laboratory
-------
4-66
Commenter:
Comment Number:
Page Number:
Penta Task Force
32
21
.. ' -21 - . '
study); thermal desorption method (bench-scale); infrared heating method (mobile pilot
unit); and electric pyrolysis method (field test)). As the Office of Technology
Assessment has noted: "[although some alternatives look promising and have been
shown effective in laboratory settings (or in application to other pollutants), none have
received enough development and testing to make them viable for large-scale treatment of
dioxin contamination today." Office of Technology Assessment, Background Paper -
Dioxin Treatment Technologies, at 8 (Nov. 1991); see, id., Table 1-5 at 8 (table
summarizing development status of dioxin treatment technologies). (These matters are
more fully discussed in the attached report entitled "Evaluation of.Non-Combustion
Technologies for the. Treatment^ Pentachlorophenol Wood Treating Wastes" (Tab 1).)
In short, reliance on these emerging technologies to solve the significant cost and capacity
problems associated with the proposed standards would be unjustified.
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4-67 - ' - . <
Cotnmenter: Penta Task Force , -
Comment Number: 32 . ' ,
Page Number: , . Art. A
Evaluation of Non-Combustion Technologies for the Treatment of
Pentachlorophenol Wood Treating Wastes
. Barry Dellinger, Ph.D.
10520 Watch Hill Lane
Centerville, OH 45458
-' ''"'
Prepared for:
. Mr. Carleton Degges
Vulcan Chemicals . . .
P.O. Bo* 530390
Birmingham, AL .35253*0390
November 16; 1995
. . > .
Background ' ' ' ,
As a result of implementation of the Phase IV Land Disposal Restriction Rule, the US-EPA
is considering promulgation of standards for tetra-, penta-. and hexa-chlqririated dibenzo-p-dioxins
and dibenzofurans (PCDD/F) in the residues from the treatment of pentachlorophenol wood
treating wastes (F032). A maximum of 1 ppb for the total concentration of all listed isomers in the
treatment residue has been proposed as the standard. Thermal treatment via cement kiln recycling
or incineration has long been the treament of choice for these wastes. However, this standard will
be difficult for thermal treatment methods to achieve due to formation of PCDD/F as combustion
by-products. Consequently, costly retreatment and reanalysis of each waste residue will likely be
required. The US-EPA has identified other technologies that they believe are capable of achieving
the Ippb standard. They are: ,
.«' - ' . v . '
, Infrared Incineration . - .
Pyrolysis
Supercritical Oxidation
Base Catalyzed Decomposition
UV Photolysis.
Unfortunately, some of these processes are quite old but have not been widely
implemented, others have been shown to be effective on specific waste streams, while others are
still in the developmental stages. The purpose of this review is to evaluate the potential
effectiveness of each of (diese technologies for reducin g the concentration of PCDD/F in
-------
. 4-68 ,
pentachlorophenol wood treating wastes to less than 1 ppb. . - -_ .
Infrared Incineration ', /
So-cailedinfraredincinerationwas.originaJly introduced by Shirco Infrared Systems. In
the late 1980's they filedfor bankruptcy and sold or licensed their units to various organizations
including the ECOVA Corp. of Richmond Washington; In the Shirco Infrared Incineration
System, solid waste materials are fed on a metering conveyor where they are heated by infrared
heating elements to volatilize, oxidize, or pyrolyze the more volatile or reactive components of the
waste. Originally, the system was designed to operate without an afterburner for treatment of non-
RCRA soils and wastes. However, concern over emissions of toxic pollutants resulted.in an
addition of an afterburner to the system design. The temperature of the metering conveyor is
typically varied from 900 to 1600 F depending upon the volatility or stability of the components of
the waste feed material that heeds to be created.
The advantage of the Shirco design is that it can treat a wide range of types of solid wastes
in a cost effective manner because of the low energy costs associated with the metering conveyor.
However, its chief advantage and main reason for its continuing viability, is its transporatability for
on site treatment of contaminated soils. When the wastes have high moisture contents, the process
becomes slower and more cosdy because de Catering is required before treatment.
Because the technology has been available for some 10 years, there is considerable
treatment data available, including data on treatment of PCDD/F containing materials. A summary
of the avaiible data is presented in table 1. '
Table 1 '
PCDD/F Treatment Results for the Shirco Infrared Incinerator
Site
Florida Steel
Twin-Cities
Tibbets
Times Beach
PCDD/F in Residue fppb>
16.3
- 82.8
<0.385
<0'.035
Removal Efficiency
>94.4
>99.98
Examination of this data reveals that the proposed regulatory standard of Ippb was achieved in
only two of the four case studies. In addition, the concentration of PCDD/F in the waste was
typically 10 to 100 ppb which is much lower than the anticipated levels in F032 which could be
greater than 1000 ppb. Thus it is not clear that the removal efficiency for PCDD/F is sufficient for
-------
4-69 ,
i ' .*,,'--
the F032 waste. - .
However, a possibly even more severe limitation apparently exists which makes the
discussion of treatment efficiency almost academic. The sludge and treatment solution wastes have
high liquid contents and thus are not suitable candidates for treatment by infrared incineration.
While it is,possible that a "drying" unit could be added to the process, .this is not a proven
v
technology and certainly not routine or cost effective. Thus it does not appear that infrared
incineration can be used for treatment of pentachlorophenol wood-treatment wastes.:
Pyrolysis ' . ' .
Pyrolysis is a variation of thermal treatment in which the waste materials are thermally
degraded under oxygen starved or oxygen depleted conditions. This is contrast to combustion in
which the waste is oxidized under stoichiometric or oxygen rich conditions resulting the in the
support of a visible flame. One of the more successful variations on this process is the.Texaco"
Syngas Inc. Entrained-Bed Gasification System. .
' -
The process operates at high temperatures, 2200 to 2800 F.and pressures above 20
au.-.ospheres. Wastes are pumped in a slurry form to a gasification chamber which converts the
waste to a gas consisting of mainly carbon monoxide and hydrogen in the case of a hydrocarbon
waste and. additionaly, hydrogen chloride in a chlorine containing waste. Slag is produced that is
collected in a- lockhopper. . ,
, - k - ' . -
The process, in principle, is supposed to produce no hydrocarbons heavier than methane..
In fact analysis of emission data from the MRL tests indicate that significant quantities of reaction
by-products were observed. These products were principally PAHs with concentrations typically
in the range of 1 to 100 ug/m3 in the syngas. Total PCDD/Fs of 0.042 ng/m3 were also observed
in the effluent Data on the slag residue was not available; however, the presence of PAHs and
PCDD/F in the effluent gas are indicative of the presence of the same chemicals in the slag residue.
i
Conclusive data on the effecuve'ness of the process for acheiving < Ippb of PCDD/F in the
residue is not available. However, the technology does not appear to be useful for treating
woodtreating wastes. The developers state that the waste must be a Liquid or slurry of fine,
suspendable particles containing 30 to 60 percent liquid. The nature of woodtreating wasr-s thus
* ' , ' '
appears to preclude their treatment by this technique, as these wastes contain larger particles and
wood splinters that would require major pretreatment and grinding to be a usable feed.
-------
4-70 . '.
Supercritical Oxidation . . ' .
Supercritical water oxidation (SCWO) is a process in which waste materials are oxidized in
a reactor containing supercritical water and an oxidant such as air. oxygen, or hydrogen peroxide.
Since the critical point of water is 374 C at 221 atmospheres, the temperature and pressure in the
reactor must exceed these values. The process has been the focus of numerous academic studies
and .consequently, the fundamentals of the process and the kinetic behavior are relatively well
characterized. ... ,
.. - ~ ' ' '-
SCWO processes have the advantages that supercritical water is an excellent solvent for
many chemicals and oxidation rates are extremely rapid. The solvation properties are due to the
. nature of water above its critical point which transform it into a moderately polar, dense eas. The
rapid oxidation properties are due to the increased number of free radicals that are formed.
Both continuous and batch processes have been designed. However, scale-up of the
process has some rather, severe limitations. Since the waste material has to be.introduced into a-
supercrirical reactor, preheating in a pressure sealed line is required; This limits the nature and
amount of material that can be processed. Corrosion of the reactor is a severe problem. High
chlorine wastes exacerbate the problem even further. A major engineering challenge has been the
solubility of salts. Above the critical point of water, inorganic salts are not very soluble and
methods for removal to prevent their buildup in the reactor must be instituted.
Performance data on real wastes for SCWO appears to be scarce; especially for chlorine
containing waste streams. The process has gained prominence as a method for treating nerve
agents and rocket fuels which are non-chlorinated. High destruction efficiencies (>99.9%) have
been reported for pentachlorophenol and PCBs. Limited data is availble fro PCDD/F. In a
treatability on pulp and paper mill sudge, residue concentrations and destruction efficiencies were
determined for operation at 450 C and 500 C. At the -lower temperature, the PCDD/F concentration
in the residue was 0.090 ppb (destruction efficiency of >96%). At the higher temperature, the
residue concentration was only 0.011 ppb. These residue concentrations are obviously very low;
however, the starting concentration was only 0.674 ppb, which is already below the proposed
regulatory limit Thus it is not clear if the technology is capable of creating wastes with 10 to 1000
ppb of PCDD/F in the waste material. > .
/ '
Based on the lack of data demonstrating the effectiveness in destroying PCDD/Fs and the
difficulty in handling chlorinated wastes, this technology cannot be considered as demonstrated or
appropriate for treatment of wood treating wastes.
-------
4-71
Base Catalyzed Decomposition ' .
Base catalyzed decompostion (BCD) is a general term applied to treatment of wastes using
an inorganic alkali to strip chlorine and other halogens from organic waste materials. This
\ "
technology is based on the use of potassium/polyethylene glycolate (KPEG) reagent to destroy
PCBs which was subsequently also applied to destruction of other waste materials using either
potassium or sodium alkali and polyethylene glycolate (APEG) as the reagent The function of the
polyethylene glycolate was to protect the alkali from hydroysis by any water that was present in the
waste materials. However, it was found that APEG reagents only partially, dechlorinated organic
wastes (i.e. producing lower less chlorinated PCBs, chlorpbenzenes, PCDD/Fs, etc.).
Consequently, "non-PEG" containing reagents were developed that resulted in improved '
destruction efficiencies. These new "BCD" technologies operated at 300-350 C to volatilize water
and increase their reaction rate. . . . .
The claims of developers concerning the efficiency of this process in destroying -
haiogenated wastes and .PCDD/Fs are promising. Soils spiked with PCDD/Fs had the
concentration reduced from 2000 ppb to below 1 ppb using KPEG for treatment times of 1 to 2
hours. Identical results were reported for another TCDD spiked soils treated with KOH/DMSO
reagent for 1-7 days. TCDD in a 2,4-D/2,4,5-T waste was reduced from 1300 ppb to non-
detectable levels using KPEG and reaction times of 2 days. Some failures have also been reported.
Proprietary K-400, KMr350, and Krl20 reagents only reduced TCDD at the Timberline Stables
and Denny Farm Sites in Missouri by 12 to 45% for treatment times of 7 to 28 days.
Although the process appears to be generally quite efficient in destroying halogenated
chemicals, it applicability is severly limited by its inability to destroy non-halogenated wastes.
This is a severe limitation for the pentachlorophenol wood treating wastes that also contain a
number of polynuclear aromatic hydrocarbons (PAHs). Thus if BCD is used for these wastes, it
will have to be used in conjunction with other treatment technologies for the non-halogenated
pollutants. Sequential treatment by at least two technologies will severly increase the cost and time
associated with the treatment of these wastes. If both treatment technologies are not present at the
t same site, additional on-road transportation will be required. Considering the complexity and
. variability, of the F032 wastes streams, the used of BCD in combination with other treament
technologies appears inappropriate. .
6V Photolysis
' Over the past 10 to 15 years a number of innovative waste treatment technologies have been
introduced based on UV photolysis. The basic process involves irradiating the waste with light
-------
. '- 4-72 ' '
with wavelengths in the 190 to 300^nm range and inducing photochemical decbmpostion. A '
photoactive catalyst or oxidizer is necessary for the destruction of most organic wastes. This is
because most waste chemicals either do no efficiently absorb light at the wavelength emitted by the.
radiation source, or they do not decompose efficiently once they are photoexcited.
Catalyst/oxidizer systems include: ozone, hydrogen peroxide, ozone/hydrogen peroxide, iron (TO
complexes/hydrogen peroxide (i.e. Fenton's Reagent), titanium dioxide, and titanium
dioxide/hydrogen peroxide/ozone. In addition, it has been shown that mildly elevated gas-phase
temperatures (200-500 C) can significantly increase the rate of photodecpmpostion in the gas-
phase. . . . , .
Some of these processes are reasonably effecient for destruction of chlorinated
hydrocarbons which decompose by elimination of chloride ion or radical. Certain PCDD/F
isomers are also quite photo-chemically labile. Hydrocarbons tend to be much less
photochenrucally reactive, especially in non-catalyzed systems. -
One can debate the merits of each type of photochemical process that has been developed or
proposed and document the measured efficiencies of each process variation on each waste type.
However, these technologies are inherently non-applicable to -ood treating wastes because these
wastes do not transmit light For a photocatalytic process to work, one must design a reactor that
allows the waste molecule, the light, and the catalyst to be at the same place at the same time. This
is a difficult task for a transparent waste but is impossible for a highly turbid waste. Wood treating
wastes contain large quantities of dirt and wood fiber. Without severe dilution they are opaque to
light Dilution may make some of the wastes marginally treatable; however, the waste volume
! - ' I
would need to be increased on the order of 100 fold and consequently the throughput and cost of
treatment would concomittantly increase.
In summary photochemical treatment methods are only applicable to non-turbid waste
waters or air streams. They are clearly inappropriate for non-waste water F032 wastes.
-------
4-73,
Commenter: American Wood Preservers Institute
Comment Number: 39
Page Number; 25
ALTERNATIVE TECHNOLOGIES TO INCINERATION DO NOT EXIST
EPA states that "any available technology can be used to meet the LDR level.48
Air of the so-called "alternatives" were evaluated by the Office of Technology
- j
Assessment (OTA) in 1991. Of the thirteen identified dioxin and furan treatment
technologies, only one (rotary kiln incineration) had been developed, permitted and -
used on a site cleanup.48
*'
COMMENT: . ' . -
AWPI is unaware of any alternative technology that has been developed to
commercial scale, permitted to receive, and capable of meeting the 1 ppb PCDD and
PCDFUTSs.
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4-74
4.7 INSUFFICIENT VITRIFICATION CAPACITY EXISTS FOR NEWLY LISTED WOOD
PRESERVING WASTES
Summary:
The proposed treatment standards for arsenic in wood preserving wastes are based on
vitrification. Two commenters [Beazer East (23) and American Wood Preservers Institute (39)] v .
expressed concern that there is no available vitrification capacity for wood preserving wastes. Beazer
East stated that only one facility in the U.S., Marine Shale Processors, uses vitrification in a tested, full
scale process and that this facility's regulatory status is in question. Beazer East believes that the
availability of vitrification as a treatment technology is uncertain and that stabilization should be the
BOAT for arsenic in the newly listed wood preserving wastewaters (23:29-33). American Wood
Preservers Institute requested that EPA identify the source for commercial vitrification (39:16).
Response:
The Agency acknowledges the commenters' statement that there is little commercially available
vitrification capacity for these wastes (e.g., MSP has now ceased operation until it can obtain a hazardous
waste incineration permit). However, as indicated in Chapter 2' of this document, stabilization can also
meet-the proposed UTS limits for arsenic. Because the treatment standards are numeric limits, facilities
will be able to use stabilization to meet the LDRs for the newly listed wood preserving wastes and are not
required to use vitrification as a treatment technology. Nevertheless, as discussed in Chapter 2, some
vitrification capacity likely exists for wastes with high concentrations of arsenic. Therefore, as discussed
in Chapters 2 and 3 of this document, EPA has determined that there is adequate stabilization capacity
for wood preserving wastes.
Comments: f . ' .
See next page. , -( ,
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. ^ 4-75
1 f ^
Commenter: BeazerEast " < . '
Comment Number: 23
Page Number: 29
11 ' '
C. The Proposed LDR for Hazardous Waste No. F035 Should Not Include
Vitrification.
'.'' v
Iji^;.^. Stabilization should be BOAT for FQ35.
EPA is proposing that F035 be treated using vitrification to meet
LDRs. Review of the ROD Summary reveals that slag vitrification has not been
specified in any of the 37 wood treating site RODs evaluated by Versar. To Beazer's
' * '
knowledge, only one facility in the United States -- Marine Shale Processors ("MSP")
of Morgan City, Louisiana- utilizes vitrification in a tested, full-scale process. MSP's
"* ' ' . '
future regulatory status, however, remains in question. Currently, MSP is appealing
EPA's rejection of MSP's Part B interim status boiler and industrial furnace permit.
Due to the uncertain nature of MSP's regulatory status and potential future lack of anv
other vitrification facility, vitrification is not an "available" or appropriate treatment
-V- " r '
technology. , .
Vitrification was chosen for immobilization for arsenic presumably
because conventional stabilization of arsenic can be somewhat problematic. As
presented at the June 1995 AWMA National Meeting, studies by EPA's RREL on
stabilization have shown that the variable solubility of arsenic in high and low pH
ranges is easily overcome by treatabi I ity testing and proper pH control of the
cement/lime mixture in the field. In this,study, EPA successfully stabilized 13,000
cubic yards of arsenic soils using conventional stabilization techniques.
\ ' Stabilization of arsenic wastes is much more controllable than
thermal processes because arsenic.has been shown to volatilize in high temperature
atmospheres such as an incinerator or slag furnace. The treatment alternatives
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4-76 ".''
/ '
Commenter: Beazer East ' . . '
Comment Number: 23
Page Number: 30 ;
specified in the Proposed Rule will transfer arsenic to a vapor stream where it is not
accounted for as closely. See Table 3-B, Data Requirements for Thermal Desorption,
in EPA's Presumptive Remedies for Soil. Sediments, and Sludges at Wood Treater
Sites Quick Fact Sheet (Draft-Nov. 1994) ("[vjolatile metals (As, Cd, Cr, Pb, Zn)
vaporize and are difficult to remove from emissions;")
i ,
The complexity of arsenic volatility is also noted in EPA's Summary
of Generation. Disposal, and Treatment Practices for Wood Preserving Wastes F032.
FQ34. and F035 {SAIC, May 1990). The SAIC document notes: "(blecause arsenic
volatilizes at high temperatures, incineration may not be an applicable treatment for
F032 or F034 wastes contaminated with arsenic." The arsenic volatility process
\ .
limitation is applicable to both vitrification and incineration and should be addressed
by the EPA before the Proposed Rule is finalized.
. p f
. , Moreover, vitrification technology is more complicated than
i ^ .
portrayed in the Proposed Rule. Vitrification of arsenic wastes may require two
additional treatment steps not specifically identified in the Proposed Rule. These
additional steps are described in EPA's Vitrification Technologies for Treatment of
* . ' '
Hazardous and Radioactive Waste Handbook (May 1992). The Vitrification Handbook
' >
notes: "[clertain waste feeds may require chemical or thermal pre-treatment to convert
arsenic oxide to less volatile forms before vitrification..." Vitrification Handbook, p.
4-7. The Handbook explains that the process required is to convert the arsenic to
a calcium oxide in another thermal process and then re-introduce the thermally treated
mixture into the slag furnace. lcL This process is notably more complex than
-------
. , 4-77
Commenter: Beazer East " ,
Comment Number: 23
PageNumber: 31 . -
indicated in the Proposed Rule and further supports the use of the much less complex,
conventional cementitious stabilization methods for arsenic wastes.
/ *
"^Finally, EPA's Presumptive Remedy document does not
acknowledge the use of vitrification as a candidate immobilization technique. Rather,
it specifically identifies "cementitious materials, including Portland cement, fly
1 ' . .'-,'' '
ash/lime, and fly ash/kiln dust" as the solidification methods.
RECOMMENDATION: ^ -
EPA should propose stabilization as the BOAT for arsenic based on a lack of
"demonstrated and available" full-scale vitrification facilities. Stabilization of arsenic
in wood treating wastes has been proven by EPA to be effective and has been
previously selected by EPA as a presumptive technology for treating arsenic in F035
i"*", i
*N ' " '
wastes. EPA should avoid the inevitable confusion that will arise in the field as a
'result of the conflicting programs and promulgate stabilization as BOAT for the F035
LDRs. .
2. . The UTS for F035 nonwastewaters should be based on leachate
concentration.
EPA has established vitrification as BOAT for arsenic and
stabilization as BOAT for chromium. 60 Fed. Reg. 43681. EPA has proposed that
each constituent proposed for regulation in F035 (arsenic and chromium) comply with
its applicable UTS in the treatment standard table at 40 C.F.R. § 268.40 as a
' - i ' '"-'.
prerequisite for land disposal. 60 Fed Reg. 43680. However, the UTSs for chromium
and arsenic at 40 C.F.R. § 268.40 are designated as leachate levels, whereas, the
-------
4-78
Conunenter:
Comment Number:
Page Number:
BeazerEast
23
32
UTS for chromium and arsenic in F035 as proposed are total concentrations. 60 Fed.
Reg. 43682.
: Beazer's experience indicates that the proposed UTSs for
chromium and arsenic cannot be achieved with the specified immobilization
technologies. Immobilization technologies are not designed to reduce total
concentrations of metals in the waste, so the F035 LDR as drafted, cannot be met.
In studies by EPA's RREL/ORD, 13,000 cubic yards of arsenic soils at the Selma Wood
Treater CERCLA site were successfully immobilized using conventional stabilization
techniques. In the Selma site full scale stabilization study performed by EPA's
RREL/ORO, leachable standards for the metal constituents were specified in the ROD
in lieu of total concentration standards- Further, the study addressed the use of
leach tests other than TCLP, such as Synthetic Precipitation Leachate Procedure
("SPLP") (pending SW846 Method 1312) and distilled water leach. Beazer supports
the use of these more appropriate leach tests.
EPA's RREL/ORD researchers have shown that the variable
solubility of arsenic in high and low pH ranges is easily overcome by treatabiiity
testing and proper pH control of the cement/lime mixture in the field. The alternate
leach tests noted above reduce the incentive of remediation contractors to create a
less environmentally-sound stabilized mixture. The misguided incentive created by the
TCLP test method is that by deliberately raising the pH of the stabilized waste, the
contractor ensures that when the acid is added in the TCLP test, the resultant pH of
the test material falls into the mid pH range where the arsenic is not water soluble.
-------
4-79
Conunenter:.. . BeazerEast '
Comment Number: 23
Page Number: '33 .
Thus, the stabilized waste passes the TCLP at, the deliberately elevated pH level.
However, because the pH of the stabilized waste is elevated, it is now in the range
-"OS.-:;**" ' ' .
of higher solubility in water. This pH management for stabilized arsenic wastes
actually results in a waste that leaches more in a natural water environment than it
does in the TCLP acid leach test. The alternate leach procedures discussed above
would mitigate the incentive to manipulate the treatability testing and result in a more
environmentally protective means of managing the waste.
RECOMMENDATION: -
EPA must revise the UTSs for the metal constituents to a teachable standard for
all metals. Further, Beazer recommends EPA consider the use of the SPLP or distilled
water leach procedure in lieu of the TCLP method to ensure the stabilized material is
truly not teachable in its final environment.
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4-80
' Commenter: American Wood Preservers Institute
Comment Number: 39
Page Number: 16
AWPI is puzzled at EPA's selection of vitrification as BOAT for arsenic. The
Agency has recognized the potential for arsenic to volatize at high temperatures.31
- ... - ' *
COMMENT:
\
EPA should explain why it disregards this,potential problem before
recommending vitrification for arsenic wastes. The Agency should also explain why it
disregards stabilization when EPA has successfully used this technology for arsenic at
j '
a wood treating site. AWPI is unaware of a single full-scale vitrification facility and ,
requests that the EPA identify the source for commercial vitrification.
-------
4-81
4.8 AVAILABLE CAPACITY.DOES NOT EXIST FOR NEWLY LISTED WOOD
PRESERVING WASTEWATERS
Summary: ".
Two commenters [Beazer East (23) and American Wood Preservers Institute (39)] stated that the
proposed treatment standards for wood preserving wastewaters are not achievable in current treatment
systems. Beazer East stated that the wastewater treatment standards are too low and will require
construction of new wastewater treatment systems capable of meeting the standards. Beazer stated that
this will result in a shutdown of remedial actions at these sites (23:5). American Wood Preservers
Institute stated that standards for F032 wastewater are unachievable (39:28-29).
Response:
As discussed in detail in the BD AT'background documents for this final rule, EPA has . ;
determined that the LDR treatment standards for the newly listed wood preserving wastewaters are
achievable using readily available wastewater treatment practices. The Agency notes, however, that
current wastewater treatment systems may have to be optimized or upgraded to meet these treatment
standards, or waste may require a sequence of treatment trains to meet the standards.. To allow facilities
time to.modify their wastewater treatment systems to be able to meet the LDR standards, EPA is granting
a 90-day capacity variance for the newly listed wood preserving wastes, or on a case-by case basis if no
treatment capacity exists. (EPA, however, does not believe many wastewater treatment operators will be
affected by the rule. If treatment occurs in tanks, there is no land disposal. If it occurs in a surface
impoundment, LDR standards need not be met assuming the impoundment meets the requirements of
3005(j)(ii), which almost all currently operating surface impoundments do.) .
Comments: . . '
. See next page. . . " '
-------
4-82
Commenter:
Comment Number:
Page Number:
Beazer East
23
5
Another ramification of EPA's proposed LORs involves the extremely low
wastewater treatment standards for wood treating wastes. EPA's stringent
waste water treatment requirements (e.g., dioxin/furan levels of 0.00063 mg/l) will
have,a profound impact on the management of remediation of groundwater at sites.
According to the regulation, the. regulated, community will be forced to expend
'valuable resources to design and construct wastewater treatment facilities capable of
meeting these low limits for any waste waters generated at sites where
-------
Commenter:
Comment-Number:
Page Number:
4-83
American Wood Preservers Institute
39
28
ALTERNATIVE TREATMENT STANDARDS FOR F032 WASTES
EPA has previously acknowledged that incineration effectively destroyed dtoxiri
and furan constituents. The Agency offered incineration as an alternative technology in
i ,* >
the F024 rulemaking although this was In response to "industry recalcitrance" and "the.
\ ' ,
Agency's desire to have industry resume treatment [of F024].58
COMMENT: . ' : ' -
Recognizing the stigma associated with incineration of dioxins and furans, the
limited capacity, and the inherent difficulties in analyzing for dioxin and furan ''
55 Internal Memorandum, Jose Labiosa to FL KIncb and L. Rosengrant, USEPA/OSWER (undated).
* 53 FR 53282, 53291-53308 (December 1988) and 55 FR 50450 (December 1990).
57 "The NTP study provides carcinogenic potency values for pentachlorophcnol products... which are in the
range of values associated with other wastes listed as toxic." 55 FR 50467. , ,
51 55 FR'2258! (June 1,1990). .'.-'.
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4-84
- f
. Commenter:. American Wood Preservers Institute ,
. Comment Number: 39 -
Page Number: 29 ' , .
constituents, EPA should promulgate an alternative standard based on incineration in a
four-9's combustion unit .
DIOXIN AND FURAN LIMITS FOR F032 WASTEWATERS ARE UNACHIEVABLE
EPA has proposed treatment standards for F032 wastewaters that were
transferred from the UTSs for dioxins and furans in organic wastewater. These UTSs
are based on biological treatment of wastewaters containing very low concentrations of
dioxins and furans ranging from 0.00004 u,g/L to 0.0118 ng/L59 The average
. i
concentrations of dioxin and furans in F032 wastewaters are much higher ranging (Tom
0.9 u.g/L to 60 pgJL ' . ' -
COMMENT:
Given that the removal efficiency for biological treatment of the lesser
concentrated was only 78 percent, AWPI does not believe that EPA can support the
' . ' \
claim that the UTS can be met with the higher concentrations of dioxins and furans
found in F032 wastewaters.
59
See, "Universal Treatment Standards BOAT Background Document". Vol. A, Section 5.6
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4-85
4.9 NATIONAL CAPACITY VARIANCE IS NEEDED FOR SOIL AND DEBRIS
CONTAMINATED WITH NEWLY LISTED WOOD PRESERVING WASTES
Summary:
'Many commenters support a national capacity variance for soil and debris contaminated with
newly listed wood preserving wastes: Beazer East (23 ), Utilities Solid Waste Activities Group et al
(USWAG) (35); American Wood Preservers Institute (39); Merck (47); Chemical Waste Management
(48); Safety-Kleen.(65); the.Hazardous Waste Management Association (97); Chemical Manufacturers
Association (113); Georgia Department of Natural Resources (DNR) (N13); and DuPont (N16).
Georgia DNR stated that they are cleaning up six sites under the State Superfund program that
are projected to generate 150,000 tons of F032 contaminated soil, and asked that EPA consider these.
quantities in its capacity analysis (N13:l). DuPont also supports a capacity variance for soil
contaminated with wood preserving wastes, and provides data on soil at its facilities (N16:l).
Based on an independent study, Beazer East estimates that 85.3 MM tons of soil contaminated
with wood preserving wastes may require treatment to meet UTS. Beazer stated that this volume far
exceeds available incineration capacity. Additionally, Beazer stated that most incinerators that can
manage nonpumpable materials only accept such materials in small quantities, and fewer than five of the
RCRA-permitted incinerators can handle truckloads or railcar volumes of contaminated media. Beazer
believes that soils and similar remediation wastes pose material handling and .capacity problems for most
of the nonpumpable incinerators, and that only APTUS, USPCI Utah, and Rollins Environmental
Services, Inc. Texas can handle significant soil volumes (23:17-22).
Rollins Environmental Services, Inc. acknowledges the data on the quantity of F032.
contaminated media are incomplete and the quantity may exceed available capacity. Rollins suggests an.
alternative treatment standard be available, under limited circumstances (N19:2). American Wood
Preservers Institute requested that the soil and debris variance be tied to the pending Hazardous Waste
Identification Rule (HWIR) (39:14). Penta Task Force requested that EPA address cost and capacity
issues that will-arise .at the end of the national capacity variance for contaminated soil and debris
(32:4,15). The USWAG added that extensions to the variance should be granted if treatment capacity
does not materialize in the future (35:15). Chemical Waste Management (48:36) and the Hazardous
Waste Management Association (97:17-18) support a national capacity variance for soil and debris
contaminated with Phase IV newly listed wastes and state that D004-D011 wastes should also be
included in the capacity variance. Merck (47:2), Safety Kleen (65:6), and Chemical Manufacturers
Association (113:24) expressed general support for a national capacity variance. -
.Response: . -
<- ' . , -
In the proposed rule, EPA requested comment on the potential quantities of soil and debris
contaminated with F032, F034, and F035 that exist at wood preserving facilities, including potential
quantities that will be generated from the closure of surface, impoundments at these facilities or by the
remediation of previously closed surface impoundments and the surrounding contaminated areas.
Although EPA did not have an estimate of these"quantities for the proposed rule, it believed the
quantities to'far exceed available capacity and therefore proposed a two-year capacity variance. EPA
acknowledges the commenters' support and has incorporated the data provided into its revised capacity
-------
4-86
analysis. Furthermore, EPA has conducted additional analysis on soil and debris data obtained from
Superfund Records of Decision (RODs). This analysis is presented in Chapter 3.
EPA notes that the Hazardous Waste Identification Rulemaking is on a separate schedule from
this rulemaking. In determining whether to grant a national capacity variance and the appropriate
duration of such a variance, if necessary, EPA considered only existing regulations. Any modifications
to a variance that become necessary as a result of future rulemakings will be made as part of that
rulemaking. EPA has determined that there is insufficient capacity to treat soil and debris contaminated
with newly listed wood preserving wastes, and is therefore granting a two-year variance. EPA notes that
as a part of this two-year variance, it will not require generators to certify to EPA that they have made a
request to incineration facilities and have found that there is insufficient capacity to meet the .
dioxin/furan treatment standard. EPA also notes that if, at the end of the two year variance additional
time is necessary, for treatment capacity to become available, EPA may consider case-by-case capacity
extension requests. . .
Comments: . , .
See next page. , ,
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4-87
Commenter:
Comment Number:
Page Number:
Georgia Department of Natural Resources
N13 ' , " " .
1 . . '
Under our state superfund program, EPD is in'the process of cleaning up six abandoned
wood treating facilities that unit eventually generate approximately 150,000 tons of soil
contaminated with F032 wastes. Even though we have not yet begun transporting these wastes
for dispoai. we have already entered into substantial contractual obligations just to prepare these
wastes so they can be removed for disposal. This is a significant amount of material and we are
concerned that any company possessing a suitable treatment technology for F032 wastes (e.g.,
commercial hazardous waste incinerators) will likely be overwhelmed by such a targe amount of
waste., - ." ' - ' _.'
As such, the State of Georgia respectively requests the EPA to consider this substantial
amount of F032 wastes when determining whether a capacity variance for soils contaminated
with FO32 wastes will be granted. Your consideration of this matter is greatiy appreciated. If
you have any questions regarding this matter, please contact me at 404-656-7802.
-------
Commoner
Comment Number:
Page. Number:
4-88
^Utilities Solid Waste Activities Group
35
15
V. USWAG SUPPORTS THE PROPOSED CAPACITY VARIANCE FOR SOIL AND
DEBRIS ASSOCIATED WITH WOOD PRESERVING WASTES.
The Agency is proposing a capacity variance for two years, for soil and debris
that are contaminated with wastes from newly listed wastes from wood preserving
processes. 60 Fed. Reg. at 43686. USWAG agrees with EPA that there is a lack of
adequate treatment capacity to meet the demand for this wastestream, and supports
the Agency's proposal to grant a capacity variance. As with mixed waste, USWAG also
requests that the Agency express its willingness to grant additional variances in the
future should disposal options remain limited.
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4:89
Commenter:
Comment Number:
Page Number:
Beazer East
23
17
4. Selection of incineration as BOAT will necessarily bring cleanups
to a hatt due to lack of capacity and skyrocketing treatment costs.
a. Capacity for incineration is simply not available.
Significant quantities of soil and groundwater impacted by
previous wood treating-operations may require treatment and disposal, further
overburdening existing waste management capacity to unmanageable levels, if media
is not exempted from the proposed LDR rules. EPA's approach in the Proposed Rule
serves to reveal EPA's lack of a sense of reality in addressing treatment/storage
capabilities. EPA's own National Capacity Assessment Report: Capacity Planning
Pursuant to CERCLA Section 104(c)(9) (the "CAP document"), EPA530-R-94-040
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4-90
Commenter:
Comment Number:
Page Number:
Beazer East
23
E8
concludes that sufficient capacity currently exists for current and projected hazardous
wastes through the year 2013, This assessment grossly overestimates capacity due
to the potentially large volume of additional remediation waste requiring treatment and
disposal as proposed in the LDR rules and not accounted ,for in the CAP document.
Specifically, EPA's capacity estimates do not account for the treatment and disposal
of FQ32, F034 and F035 wastes or media as specified in the proposed LDR rules.
EPA estimates that approximately 30% (310,000 tons/year) of surplus commercial
capacity exists for nonpumpable incinerator wastes through the year 201 3. EPA
estimates that the total current nonpumpable incineration capacity is approximately
1.1 MM tons/year. Based on an independent study, performed by the'National
Environmental Technology Application Corporation ("NETAC") for Beazer, an estimated
85.3 MM tons of soil impacted by previous wood '"^ting operaTIorTSvrnay require*
treatment to UTSs under the proposed regulations. See Attachment Ay Clearly, if
media is not exempted from the Proposed Rule and if incineration is the only
s
demonstrated technology, then capacity is not available to treat this quantity of
material. It would take over 200 years to treat this quantity of material based on the
'existing incineration capacity. Even if only one quarter of the estimated 85.3 MM
tons/year of soil were to be managed at off-site commercial facilities and ail the
remaining hazardous waste capacity was used for this material, it.would take over 60
years to complete the task.
Further, EPA's "nonpumpable" capacity estimate cited in the
CAP document of 1.1 MM tons/year fails to account.for remediation wastes handling
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4-91
Commenter: BeazerEast
Comment Number: 23
Page Number: 19
limitations. Most of the RCRA-permitted incinerators which manage nonpumpable
materials accept these materials only in small quantities. Based on Beazer's research,
fewer than five of these facilities can actually manage truckload or railcar volumes of
1 ' ' '
contaminated media. Soils and similar remediation wastes pose material handling and
capacity problems for most, of the nonpumpable 'incinerators, such as high inert
content, low heating value,'conveyance, and shredding. To pur knowledge, only
"v , - . .
APTUS in Coffeyville, Kansas, US PCI in Utah, and Rollins' facility in Texas can handle
significant soil volumes and their combined total capacity (noj surplus capacity,
assuming any exists) is on the order of 250,000 tons/year. Thus, even if the US PCI
and Rollins incinerator in Texas were' permitted- to accept F032 wastes, adequate
'capacity for remediation wastes containing F032 would still be unavailable.
' . The Agency admitted in the Advanced Notice of Proposed
Rulemaking (ANPR) Land Disposal Restrictions; Potential Treatment Standards for
Newlv Identified and Listed Wastes and Contamjnated Soils (October, 1991) that "the
commercial hazardous waste treatment industry tends to shy away from these [dioxin-
containing] wastes, thus resulting in unnecessary delays in such treatment." 56 Fed.
Reg. 55160, 55179 (October 24, 1991). EPA indicated in the >^NPR that there is a
high level of public concern over wastes containing the chlorodioxins and requested
ideas regarding the development of F032 standards which would lessen public
concern and the associated delays in treatment and disposal. Apparently, EPA has
ignored these concerns. Clearly, the effect'of the proposed LDR rules will heighten
-------
'4-92
Commenter;
Comment Number:
Page Number:
BeazerEast
23
20
the public's concern regarding dioxin/furan thermal treatment and slow, if not halt
effective remediation waste management. ' '
As stated by EPA in the Proposed Rule, only one incinerator
is permitted in the United States to accept and, thermally treat dioxin-containing
wastes - Rollins' APTUS facility. Recent trends have shown a decrease in incinerator
permit applications/ permits issued and resulting capacities. Due to public concern
regarding dioxin/furan treatment, the cost of permitting and the restrictions placed by
EPA on incinerators in its Combustion Strategy, it is probable that the APTUS facilir
will be the only facility permitted to treat dioxin-containing wastes for some time.
As stated in Presumptive Remedies for Soil. Sediments.-and
Sludges at Wood Treater Sites Quick Fact Sheet (Draft-Nov. 1994):
incineration of large volumes [greater than 5,000 cubic yards] of contaminants
may be prohibitively costly....There,may be significant considerations with
respect to compliance with ARARs and other laws....Space availability and
public opposition may make this option infeasible. Consideration must be given
to public reaction concerning the use of incineration because the Agency has
encountered significant opposition at some sites. Commercial incineration
facilities (i.e., units permitted for the incineration of hazardous wastes) may be
used when off-site incineration is desirable. However, only a limited number of
these facilities are available nationwide, and the possibility of increased capacity
in the future is constrained by EPA's Draft Strategy for Combustion of
Hazardous Waste, issued in May 1993. .
Based on data collected by EPA and contained in the
i
Resource Conservation and Recovery Information System (RCRIS) database as of
May 1, 1994, 164 incinerators were permitted or in interim status. Of these facilities,
only 28 were commercial facilities; 7 of which were operating under interim status.
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4-93
Commenter: BeazerEast
Comment Number: 23 ,
Page Number: 21
More significantly, of these 28.commercial facilities, only one (APTUS) will be able to
accept F032 wastes as currently proposed in the rule. Significantly, between July 1,
1993 and May 1, 1,994, 7 commercial facilities canceled plans to develop new
' ' \ ~
capacity and 1 commercial facility in interim status terminated operations. During this
same timeframe, only 1 commercial facility submitted a new permit application. More
critically, 17 facilities (both commercial and non-commercial) were closed and plans
to build new facilities were canceled during this period. . / -, ,..'"
tn order fora treatment facility to incinerate dioxins/furans,
. ' *x . . ,
the facility must demonstrate a destruction and removal efficiency (ORE) of 99.9999
i
percent. The permitting process is extremely costly and cost prohibitive for most
incineration facilities. These facilities must demonstrate the 99.9999.percent ORE in
1 " " *' i "
a trial burn in order to obtain such a permit. Based on discussions with Rollins
Environmental, these costs can range from $2,000,000-$4,000,OQO.
The APTUS, facility^ will be the lone BOAT facility for
destruction of dioxins/furans for some time in the future; EPA's Combustion Strategy.
restricted incineration facilities from obtaining Part B permits to treat dioxin-containing
wastes by mandating site-specific risk assessments for all Part B facilities and placing .
Part B applications on hold. Further, EPA has not yet proposed emission standards for
particulate matter and dioxins/furans from Hazardous Waste Combustors (HWCs) as
i ' '
i .
mandated in EPA's Combustion Strategy. Once proposed, these standards must be
made available to the public for review and comment prior to the time any regulatory
proposal js developed. Clearly, the timeframe required for EPA to implement this
-------
4-94
Commenter.
Comment Number:
Page Number:
Beazer East
23
22 '
portion of its Combustion Strategy is significant based on the current negative public
s
perception regarding dioxin/furan incineration as well as current Combustion Strategy
t .
restrictions and lack of EPA guidance. ,, .
With regard to the selection of incineration as the primary
treatment for organics, there are tremendous, and in all probability, insurmountable
complexities'imposed by incineration of'a waste with a dioxin/furan effluent
performance'standard similar to the performance standard applicable to the APTUS
incinerator. This difficulty was demonstrated recently in EPA Region IX, where the
Agency revised'the treatment method for a dioxin/furan containing waste at a CERCLA
wood .treater site in California to an on-site landfill because of the insurmountable
<* ' i '
problem of public resistance to incineration of the material on-site. The foregoing
studies and analysis! demonstrate clearly that incineration capacity is simply not
"available" for wood treating site remediation wastes even today, before the large
volume of materials resulting from the proposed LDRs would have to be incinerated.
Further, there is absolutely no reason to believe that any greater capacity will become
available in the foreseeable future. -
-------
Commenter:
Comment Number:
Page Number:
4-95
Rollins Enivironmental, Inc.
N19
2 ;
There is a demonstratively sufficient amount of capacity to meet the proposed Dioxin/Furan
treatment standards for F032 process wastes. Additionally, RES contends there is sufficient
capacity to meet the proposed Dioxin/Furan treatment standards for F032 contaminated media
wastes. However, since the data on the quantity of 1*032 contaminated media is incomplete, it is
conceivable there may be a large F032 contaminated media cleanup that exceeds tbe capacity of
facilities able to meet the Dfoxin/Furaji treatment standard. RES also acknowledges chat some
incineration facilities may not be able to meet the Oioxin/Furan treatment jtandard, thereby
limiting the available capacity for large contaminated media projects.
Therefore, RES recommends the option of an aJtcmativc.trcatnicm standard for F032
contaminated media waste, available under limited circumstances. This option would allow an
F032 contaminated media generator to utilize the alternative treatment standard under the
following condition:
The generator certifies to the EPA that a request to at least 'five incineration
facilities indicates there is insufficient capacity to treat the F032 contaminated
media while meeting the Oioxin/Furan treatment standard.
RES further recommends that EPA adopt the combination of suboptions 2 & 3 as outlined in the
NODA as the alternative treatment standard. Under this recommendation, after certifying there is
insufficient capacity for treatment of F032 contaminated media, a generator could utilize the
alternative treatment standard of "Combustion In a Part B permitted facility that meets a
Dioxia/Furan emission standard of 0.20 ng/DSCF." . . . '-
-------
Commenter:
, Comment Number:
Page Number:
4-96
American Wood Preservers Institute
39 , . '.,
14 .
V. TREATMENT STANDARDS FOR SOIL CONTAMINATED WITH NEWLY
LISTED WASTES (60 FR 43680)
. AWPI agrees with EPA's presumption that the treatment standards for as-
generated wastes are generally inappropriate or unachievable for soils contaminated
with hazardous wastes within the meaning of 40 CFR 268.44(a).M AWPI supports the
, .
proposed national capacity variance for soil and debris contaminated with Phase IV
newly listed wastes. '"'". , . .
' i -
However, the Agency has not clearly demonstrated the relationship of
contaminated soil under the Phase IV LDR's and the pending Hazardous Waste
Identification Rule (HW1R) for soil and debris: Will the treatment standards be
compatible? Based on this potential conflict, the capacity variance for soil and debris
should be tied to the implementation of the pending HWIR rule.'
The Agency should ensure that the proposed treatment standards for soils will
\ '-
not conflict with EPA's 'Presumptive Remedies for Wood Preserving Sites." AWPI
believes that ttie proposed Universal Treatment Standards (UTSs) for F032 wastes are
not consistent with the proposed presumptive remedies nor is the vitrification of arsenic
wastes.' . - - ... '.
55 FR 8759-60 (March 8, 1990).
-------
Commoner: -
Comment Number:
Page N'umber
4-97
Penta Task Force
32
4'
Also, the same 49 wood preserving sites generate some. 10,520 tons of
F032-contaminated soil and debris annually and there may be untold millions of tons of
s
contaminated soils from past operations at these sites and at former wood'preserving sites
that may require remediation and treatment. Although £PA has proposed a two-vear
national treatment variance for contaminated soil and debris, the Agency has not squarely
-addressed either the capacity or cost issues that necessarily will'arise at the end of the
variance period.' . . . .
-------
4-98
Commenter:
Comment Number:
Page Number: ,
Penta Task Force
32 .
15
Moreover, some 10,520 tons of F032-contaminated soil and debris are
' generated annually at wood processing facilities and large volumes (perhaps as high as
102 million tons) of contaminated soils from past operations may require treatment. See
v -
Capacity Analysis, 3-10 to 3-11. Although EPA has proposed a two-year national
capacity treatment variance for F032-contaminated soil and debris, neither the Capacity
Analysis nor the Regulatory Impact Analysis provide any indication of the significant
costs and capacity issues that necessarily will arise after the variance period ends and .
these contaminated soils require treatment. EPA's failure to squarely address this
problem is another example of the significant conceptual problems associated with the
current proposal.
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4-99
Commoner
Comment Number:
Page Number:.
DuPont Engineering
N16
1
DuPont supports a capacity variance for TC metal wastes.
DuPont is actively engaged in remediation activities involving metal contaminated soils and debris at five locations
and has identified more than 100.000 cubic yards of potentially impacted soil. Perhaps 50.000 cubic yards of this
material will be managed in the next few years. Pending implementation of the recently proposed HWIR-media
rule, some or all of this soil would need to managed under LDRs. In order to not create Impediments to
remediation, DuPont requests that the Agency grant a variance. -.-',.
-------
Commenter:
Comment Number:
Page Number:
4-100
Chemical Waste Management, Inc.
48
36
The Agency is proposing a national capacity variance for soil and debris
contaminated with Phase IV newly listed westes.
CWM supports this proposal In principal, however, it is not clear to CWM
whether this includes newly identified newly identified wastes. The Agency
states "EPA Is proposing a national capacity variance for soil and debris
contaminated with Phase IV newly listed wastes.' (See 60 Fed. Reg. at
43,686) This statement implies that the capacity variance is for all newly
identified Phase IV soil and debris. This should include the newly identified
D004-D011 wastes.
-------
Comrnenter:
Comment Number:
Page Number:
. , 4-101 .
.Hazardous Waste Management Association
97 '
17
Treatment Standards for Soil Contaminated With Newly Listed Wastes (60 FR 43680)
The Agency is proposing a national capacity variance for soii and debris contaminated with
Phase IV newly listed wastes. HWMA supports this proposal in principal; however, it is not
clear whether this includes D004-DOI1 newly identified wastes. The Agency states that, "EPA
is proposing a national capacity variance for soil and debris contaminated with Phase IV newly
listed wastes" (60,FR 43686). this statement implies that the.capacity variance is for all newly
identified Phase IV soil and debris, a universe which does include, D004-D011 newly identified
wastes. However, the Agencyvdoes not indicate that this national capacity variance is being
-------
Commenter:
Comment Number:
Page Number:
4-102
Hazardous Waste Management Association
97
18
granted to D004-DOM newly identified wastes. Neither the table in the preamble discussion (60
FR 43686) or proposed §268.30 (60 FR 43694) state that D004-D011 newly identified wastes
are subject to the capacity variance.
D004-D011 newly identified wastes should also be included in this capacity variance based on
the logic for granting the capacity variance for F032, F034, F035, and D004-D011 mixed with
radioactive wastes. The Agency states, "It has been the Agency's experience that contaminated
soils are significantly different in their treatability characteristics from the wastes that have been
evaluated in establishing the BOAT standards, and thus, will generally qualify for a treatability
variance for soils ". HWMA does not see any logical reason for not granting this capacity
variance for D004-D011 newly identified soil and debris while granting it for the other waste
streams. . .- -
-------
4-103
Conunenter: Merck
Comment Number: 47
Page.Number: 2
1) The Agency is proposing a national capacity variance for soil and debris contaminated with
Phase IV newly listed wastes. We support this proposal fully. The Agency's assertion that
treatment of constituents in debris and soil streams is significantly different than treating as
generated waste streams. We concur with that assertion and therefore believe that the Agency
will need to carefully evaluate treatment standards for these new streams especially since they
are metal bearing streams and as such are very difficult to treat as a soil or debris wastestream.
-------
4-104
Cotnmenter:
Comment Number:
Page Number: '
Safety-Kleen
65
6 ' '
13. Safety-Kleen supports the Agency's intent to provide a national capacity variance for soil
and debris contaminated with Phase IV newly listed wastes. ' . ', .
Safety-Kleen agrees that the treatment standards for as-generated wastes are inappropriate for soil and
debris contaminated with hazardous wastes. Imposing treatment that is not available in the short term
will delay or interrupt remediation efforts under RCRA corrective action and other remediation and
construction programs. In addition, 90-day generators of hazardous waste soils and debris would be in
jeopardy of not-being able to comply with regulations because viable treatment alternatives do not exist
Safety-Kleen therefore supports granting a national capacity variance for contaminated soil and debris
for the maximum time allowable.
-------
Commenter:
Comment Number:
Page Number
4-105
Chemical Manufacturer's Association
113
24
F. CMA Supports National Capacity Variances For The Phase IV Rule.
CMA agrees with the Agency that National Capacity Variances are appropriate and
necessary to allow uninterrupted manufacturing capability at many sites. The Agency's
estimate of wastewaters affected by the Phase IV rule may be unrealistically low, considering
that many facilities have not previously determined quantities of wastewaters which are
characteristically hazardous at the point of generation. This concern emphasizes the need for
national capacity variances. \
-------
-------
APPENDIX A
DATA ON AVAILABLE COMBUSTION CAPACITY
-------
-------
APPENDIX A
TO:
The RCRA Docket
SUBJECT: Meeting Notes with Rollins and Rollins' Highway 36 . .
re: Rollins Incineration Capacity and Treatment of Selenium Wastes
DATE: May?, 1996
Participants:
Mike Fusco, Rollins Environmental
Richard Grondin, Rollins' Highway 36
Mike Petruska, OSW/HWMMD/WTB
Mary Cunningham, OSW/HWMMD/WTB
Elaine Eby, OSW/HWMMD/WTB
Anita Cummings, OSW/HWMMD/WTB
C. Pan Lee, OS W/HWMMD/AIB
Suzanne Wade, Versar
DRAFT
This meeting note mainly summarized the part discussing incineration capacity and
treatment problems. Rollins expressed repeatedly that there is much incineration capacity -
available in Rollins facilities and they can handle both process, wastes and contaminated media.
The second issue brought up by Rollins was the concern of not being able to meet UTS for
selenium. .
Rollins submitted CBI for their incineration capacity (EPA has retained two copies and
the rest gave back to Rollins). Both copies had been handed to CBI Document Control Officer of
OSW. Rollins stresses that they have not been utilizing the maximum available operating
capacity for handling both liquids and solids wastes for recent years. They are not seeing much
wastes come to incinerators, especially from Phase II wastes - they do not dispute over our
capacity analysis methodology, but express that generators may redirect materials handling in the
processes and do not generate as much wastes as LDR estimated.
Rollins states that adding more binders to achieve selenium UTS is just dilution and does
not incur a treatment if other metals (e.g., lead, cadmium, nickel) are also present in the wastes.
They are not able to find proper agents to treat selenium down to UTS level for the wastes they .
received. Also, they have been seeing more concentrated wastes come to incinerators for the past
7 to 8 years because some generators may use dryer instead of filter press to reduce the waste
volume and actually the wastes become more toxic due to waste minimization and present
treatment problems for treaters.
i * /
Attached please see the notes prepared by WTB's contractor (Versar) for the overall .
discussion in the meeting. . ' ,
-------
DRAFT SUMMARY OF MEETING WITH REPRESENTATIVES OF ROLLINS
ENVIRONMENTAL SERVICES (RES) TO DISCUSS COMMENTS ON PHASE IV
May?, 1996, 10:00-11:30 a.m.
-2Wtrystal Station
' / Srlington, VA
2nd Floor, Conference Room B
ATTENDEES
Elaine Eby, EPA/OSWAVTB
Mary Cunningham, EPA/OSWAVTB
Michael Petruska, EPA/OSW/HWMMD
C. Pan Lee, EPA/OSW/HWMMD
Anita Cummings, EPA/OSWAVTB
Suzanne Wade, Versar
, Mike Fusco, RES
Richard Grondin, RES
DRAFT
The purpose of this meeting was for EPA and RES representatives to discuss RES comments on
the Proposed Phase IV rule (proposed treatment standards for characteristic metal wastes). The
primary concerns were that there currently is sufficient thermal treatment capacity for wood
preserving wastes and contaminated media (in contrast to generator's claims that there is
insufficient capacity), and that they cannot consistently meet the UTS for selenium and arsenic
for certain wastes.
First RES stated that they currently have excess capacity that would be suitable for thermal
treatment of wood preserving wastes and contaminated media. A recent (1995) H Digest survey
also shows excess capacity industry-wide. This should allow the treatment standard to be issued
without a capacity variance, according to Mike Fusco of RES.
RES has a major difficulties with stabilization of selenium to UTS levels, especially when other
constituents are present The solubility of selenium is lowest at a pH of 6.5 to 7.5, but other
metals such as cadmium, nickel, and lead, are highly soluble at this pH. Currently, they treat
2000 - 3000 T per yr. of all selenium-containing wastes (listed and characteristic), including
K061, and with the current treatment levels must turn away some of the waste because the waste
cannot be treated to the UTS concentration. RES believes 1.0 mg/L is a reasonable number for
Se instead of 0.16 mg/L. This issue is bigger than TC; it is a problem for all selenium wastes
(except shampoo which contains percent levels of Se but few other constituents). Other
representatives from the major companies in the waste treatment industry were informally
surveyed by RES. They ail said Se was a problem but the volume was not high enough for them
to comment.
RES also has a problem with treatment of mercury wastes that is not related to Phase IV. When
the untreated concentration is greater than 260 mg/kg, the regulations require treatment by
-------
\ "
retort; however RES would prefer to treat it using stabilization. The residue from retorting is'
high in chloride content, so it cannot be stabilized because of current EPA regulations; RES
must send it to Canada for stabilization. They are in the process of submitting a treatability
variance for this waste.
Organometallics (such as organoarsenates) can also be difficult to treat because of restrictions
on combustion of metals and stabilization of organic*. RES feels that arsenic is difficult but
possible to stabilize. They have rejected some creosote type waste because of high organics.
\ ' ' * ,
RES does not have major concerns with meeting metal treatment standards for UHCs for
nonwastewaters. In general, they feel that UTS for characteristic wastes are technically feasible
but will cost more because of associated development and optimization costs. They also believe
there will be a volume increase in treatment residuals. RES is seeing more concentrated wastes
in their feed streams because of waste minimization, which can be difficult to treat Sand (as
in foundry wastes) might actually help the stabilization, like slag.
DRAFT
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-------
APPENDIX B
DATA ON AVAILABLE WASTEWATER CAPACITY
This appendix has two sections:
B-l: Discusses available treatment capacity at Centralized Waste Treatment facilities. The information
was collected in the 1991 Waste Treatment Industry Questionnaire by the Office of Water and represents
1989 data.
B-2: Wastewater treatment systems data from the 1991 Biennial Reporting System .
-------
-------
Appendix B-l
'*£**! UimCO STATES ENVmONUENTAtPROTtCndNAGalNeY
iSSBJ WASHINGTON, D.C. 20460
t**r ' , ' ' ". -.'
To:
'
From:
Benjie Carroll (OS-321W)
Debra DICianna
Engineering and Analysis Division (WH-552)
Date: April 30, 1993
Subject: Treatment Capacity Information from Waste Treatment Industry Project
Attached is the information you requested regarding available treatment capacity at
Centralized Waste Treatment facilities» This information was collected in the 1991
Waste Treatment industry Questionnaire by the Office of Water and represents 1989
data. Names and addresses of facilities are also listed.
All of the fecilrties included have received a final or interim RCRA Permft. None of the
information provided pertains to waste which Is underground injected. Some facilities
did not supply the capacity information requested due to complex operations*
Therefore, two totals are presented. One total represents the actual Values reported.
The second total Is scaled-up to included facilities which did not submit data. Below
ere listed the overall totals: ,
1939 Reported Capacity Total: 9,669,611,960 gals/year
1989 Scaled-Up Capacity Total: 11,341,084,753 gals/year
( » Reported Capacity Total + 11 x Average Capacity)
, * - ~ / *
If yqu wish to obtain any additional information or have any questions, please contact
me at (202) 260-7141.
cc:
Tudor Davies (WH-551)
Ramona Trovato (WH-5SOG)
Woody Forsht (WH-552)
Bruce Kobelski (WH-560G)
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APPENDIX C
' '
DATA ON CURRENTLY AVAILABLE STABILIZATION CAPACITY
This appendix has three sections: . ,
C-l: Describes the information the Agency collected from selected treaters on available stabilization
capacity for Phase IV mineral processing and TC metal wastes. It includes an overview of the Agency's
approach, summarizes-the results; and provides phone logs.' -
C-2: Discusses available capacities for metal waste stabilization and metal recovery for meeting the
Phase IV TC metal and mineral processing waste LDR standards. '
C-3: Provides a phone log of calls to TSDs who stabilize D008 and other TC-metal hazardous wastes.
-------
-------
Appendix C-l
ANALYSIS OF AVAILABLE STABILIZATION
CAPACITY FOR PHASE IV WASTES
This appendix describes the information the Agency collected from selected treaters
on available stabilization capacity for Phase IV mineral processing and TC metal wastes. The
appendix is divided into three parts. Section 1.0 provides an overview of the Agency's
approach, Section 1.2 summarizes the results, and Section 1.3 provides phone logs.
1.0 Approach . - , .
\ " r ,'.." ' ,
. The Agency's approach for evaluating available stabilization capacity for Phase IV TC
metal and mineral processing wastes involved six main steps: ,
' 1. Develop interview guide; - ,
2. Identify interviewees (e.g., commeriters);
3. ..-Conduct preliminary interviews for a few interviewees;
4.' Modify interview guide to address problem areas identified in conducting
preliminary interviews;
5. Finish interviews; and
6. Incorporate other information and conduct follow-up activities.
v In Steps 1 and 2, EPA developed a preliminary interview guide and identified several
commercial treaters and organizations who-submitted comments to the proposed Phase IV
rule.1 Also, some treaters were identified from BRS data reviews2 and previous
interviews.3 In Step 3, EPA conducted a few preliminary interviews and, based on the
results, refined the draft interview guide to clarify questions and target key areas. The final ,
phone interview guide used questions such as the following (individually tailored somewhat
depending on data supplied previously): .
1. How, much waste do you treat? How much of this waste is hazardous, as
defined under RCRA (i.e., RCRA Subtitle, C wastes)? How much of the waste
that your facility receives is non-hazardous, as defined under RCRA (i.e.,
RCRA Subtitle!) wastes)? How much treatment capacity is commercial'and
how much is captive (i.e., your own company's)? Do you treat Phase IV
mineral processing and TC metal wastes? If not, do you plan to treat these
These treaters were interviewed as follow-up to comments and thus did not count toward the limited number
of non-federal" employees who can 6e contacted pursuant to the Paperwork Reduction Actv .
Raghuvan, Raghu, and Jim Laurenson, Memorandum to Bill Kline and.C. Pan Lee: Status Report on the
Available Capacity Assessment for TC Metal and Mineral Processing Wastes. ICF Inc., June 1996.
Schwartz, Stephan. Memorandum to Stan Moore and Suzanne Wade: Phone Calls to TSDs Who Stabilize D008
and Other TC-metal Hazardous Wastes. Versar Inc., May 1996. ,
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wastes in the future? ' . '
2. Approximately what percentage of the Phase IV wastes that you treat are
treated on site ,at your facility and what percentage is treated off site at the
generator's facility (e.g., large volumes of mineral processing wastes)? What
percentage of the wastes that you accept for treatment is part of a treatment
train that began on a generator's facility (e.g., combustion at generator's site
followed by stabilization of residuals at your facility site)?
3. What quantity (T/yr) of these Phase IV wastes can be treated to proposed UTS
' off site or at your facility at the present time and what quantity cannot? What
quantity (T/yr) of these Phase IV wastes can be treated to UTS off site or at '
your facility in the future (please specify time period (e.g., within one year))! '
. 4. Would there be any problems treating to individual standards? Would there be
any problems when constituents are in a mixed constituent Phase IV waste
. stream (e.g., mixed metals)? With organic UHCs? Why? What waste streams,
(please specify waste codes), if any, do you expect will cause you to make
modifications in your treatment processes? What quantity (T/yr) of the.total .
Phase IV wastes that you treat do these wastestreams comprise?
5. How extensive and difficult to implement would the modifications to your
treatment processes be? How much time would be necessary for modifications
to your treatment processes? '
6. How much of which kind of additional Phase IV wastes (e.g., one of the
wastes that may be problematic) can your facility treat? When?
7. Can you provide data,to support any of the above.answers?
^ EPA then conducted follow-up activities to fill in data gaps. To assess difficulties in
meeting concentration levels, for example, EPA asked the contacts about the feasibility of
meeting several hypothetical values.
Questions were faxed vhen requested, and follow-up calls were made through January
13, 1997.
<
1.2 Results
f
Exhibit 1 summarizes several observations that can be made from the results of this
data gathering effort. These results are discussed in more detail below:
« ,
Overall treatment capacity
All facilities treat TC metal or de-Bevilled mineral processing wastes.
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Ten facilities-Environmental Enterprises, Environmental Quality, EnviroSafe,
GNI, Heritage Environmental Services, PDC, Rollins, and both of the CWM
facilities-conduct 100 percent of the treatment on site at their facility. One
facility, Environmental Technologies, Inc., conducts about half of its treatment
off site. . f .
Current treatment at facilities ranges from 15,000 tons/year to 300,000
tons/year. ! '
Current available capacity of facilities ranges from 140,000 tons/year to
1,159,000 tons/year.
1,159,000 tons/year,
Modifications to treatment processes.
All but the, smallest two4 treaters interviewed-both of the Chemical Waste
.Management (CWM) facilities, Environmental Quality, Environmental
Technologies, Inc., EnviroSafe, GNI, LWD Inc., PDC, and Rollins
Environmental Services-commented that no modifications would need to be
made to their treatment processes or minimal time (e.g., four weeks) is required
for very minor modifications. .Environmental Enterprises and Heritage
Environmental Services noted that it may take two to five years, primarily due
to changing their permits.
Most facilities commented that the exact time needed and difficulty to
implement changes in treatment processes will vary depending on the degree of
changes. ^
Both of the CWM facilities noted that it would cost approximately $1,000 per
waste stream to develop .new treatment recipes. .
Additional treatment needed
Both of the Cheinical Waste Management (CWM) facilities, Environmental
Enterprises, GNI, and Heritage Environmental Services gave a range of 20 to
100 percent of their TC metal waste streams that have constituents above TC
or UTS levels that require additional treatment.
Heritage Environmental Services and GNI noted that meeting the original
proposed standard for cadmium would require treatment modification because it
is difficult to stabilize it in a mixed constituent waste stream:.
Heritage Environmental Services and CWM in Carlyss, LA indicated that
, In terms of known or estimated utilized or available capacity.
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meeting the original proposed standard for lead would require treatment .
modification because it is difficult to stabilize it in a mixed constituent waste
stream and leaching rates vary depending on pH. ;
GNI, Rollins Environmental Services, and CWM in Carlyss, LA indicated that
meeting the original proposed standard for selenium would require treatment
modifications because it is hard to stabilize it in a mixed constituent waste
stream and leaching rates vary depending on pH.
Heritage Environmental Services, Rollins Environmental Services and CWM in
Carlyss, LA indicated that meeting the original proposed standard for
chromium would require treatment modifications because it is hard to1 stabilize
it in a mixed constituent waste stream and leaching rates vary depending on
pH.
1 ' , .'.'
Three facilities noted that treating organic UHCs would require treatment
modifications. Heritage Environmental Services will incinerate those, waste
streams while Environmental Enterprises and PDC will send it to another
facility for treatment. Two facilities-Environmental Quality and LWD mc.-
specifically stated that organic UHCs can be readily treated to UTS.
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1.3 Phone Logs
Mr. Chuck Grant ,
Environmental Manager
Chemical Waste Management
Location: Carlyss, LA /
Phone: 318-583-3774
Fax: 318-583-4615 >
Interview conducted by: Gillian Foster
Date of interview: August 23,1996
Mr. Grant responded that their facility does treat Phase IV wastes, and plans on
continuing treatment in the future. Approximately 25 percent of the wastes are treated
to LDR standards, while 75 percent of the wastes are incinerated to meet organic LDRs,
but need metals stabilization. Approximately 200,000 gallons/day of waste can be treated
to UTS on site at the facility. Their facility will need to implement modifications to the
types and quantities of reagents needed ,to treat various waste types in their stabilization
facility. The time heeded to modify recipes for treatment should be minimal. They
estimate that it will cost approximately $1000 per waste stream to develop new recipes.
It is also estimated to increase treatment costs from $5 to $20 per'ton. Approximately 20
to 30 percent of TC metal only waste streams have constituent concentrations above TC
or UTS levels that would require additional or modified treatment. For these waste
streams, meeting individual standards for selenium, chromium, and lead are going to be
problematic. They recommend that the limit be set at S.Oppm TCLP for all three
metals. They will not be.able to treat TC metal-only wastes with organic UHCs because
of Subpait CC; -, '- ' . "-
Mr. Mitch Hahn
Chemical Waste Management ' <
Location: Oakbrook, IL
Phone: 630-572-8800
Interview conducted by: Gail Shaw
Date of interview: September 10,1996
Date of follow-up interview: January 2,1997
Mr. Hahn responded that only hazardous waste is received for treatment at their
facility, and Phase IV wastes are treated, treatment is 100 percent on site. They have
fixed stabilization tanks at their landfills. The quantity of Phase IV wastes that can be
treated to UTS depends on the treatment method. Approximately 70 to 80 percent of
the wastes can meet the lower UTS levels for metals, while 20 to 30 percent will require
development of new treatment recipes (e:g.,different ratios of stabilization agents). Of
these 20-30%, 5-10% can not meet the lower standards and will not be accepted by this
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facility. Applying 1LJHC standards will increase the rnetal bearing waste streams going to
incinerators (i.e., for organics), but there is ample capacity. There will be problems
treating some of the wastes to individual standards. Difficulties with a mixed constituent
waste stream depend on the metals, which have different stabilization levels and varying
rates of leaching depending on pH. The facility does not know exactly what the impact
of organic UHC will be on metal bearing waste streams because those waste streams
have never needed to be identified. There will be no modifications made to the physical
treatment process. However, all of the waste codes with lowered treatment levels will
need to have thier treatment recipies looked at to determine if any modifications need
made. The difficulty of implementing modifications will vary depending on the difficulty
of changes. First, a bench-scale test will be performed in the lab (requiring several days),
then at the production level. It could take approximately 6 months to implement recipe
modifications depending on when the facility receives the waste streams. The estimated
cost is $1000/profile to re-evaluate and develop a new recipe. Refer to the comments on
the proposed rule submitted to EPA for supportive data.
In a follow-up" call, Mr. Hahn said that they will not have to change any of their
actual physical processes. The lower the standards are, the more difficult it will be to
modify the recipes. He noted that meeting the hypothetical UTS levels for barium
(D005), chromium (D007), lead (D008), selenium (D010), antimony, nickel, thallium, and
vanadium would be easier than what was proposed in the August 1995 proposed rule.
Only minor modifications to the treatment recipes, requiring several weeks, may be
needed. The facility is working on new data.
Mr. Gary Davis . % .
Vice President
Environmental Enterprises
Phone: 513-541-1823
Fax:513-54M638
Interview conducted by: Gail Shaw v
Date of interview: September 23,1996
Date of follow-up interview: January 7,1997
'.-";»"- '
Mr. Davis responded that their facility treats approximately 15,000 tons/year.
Approximately 50 percent is hazardous, while the other 50 percent is non-hazardous. He
noted that 100 percent of treatment capacity is commercial. They treat Phase, IV wastes;,
100 percent are treated on site at the facility, and no wastes are part of a treatment train.
Less than 50 percent of these Phase IV wastes can be treated to; UTS at the present
time. In the future, Mr. Davis estimated it could take three to five years to be able to
treat to UTS (primarily because the permit would need to be changed). He noted that
generally there would be .no problems treating to individual standards. Treating a mixed
constituent waste stream that has no organic UHCs is not problematic; however, treating
a mixed constituent waste stream with organics will be difficult, they will need to be.
-------
sent off site to an incinerator. Mr. Davis could not estimate what modifications, if any,
would need to be made to treatment processes. He estimated it could take several years,
primarily due to changing the permit for part B. The facility can accept very little or no
additional Phase IV wastes because they are currently' close to capacity. The facility can
provide supporting data if requested;
In a follow-up call, Mr. Davis noted that meeting the hypothetical UTS levels for
barium. (D005), chromium (D007), and lead (D008) would require modifications to both
the treatment process and the treatment recipes. Each constituent would require six
months to one year to implement the, changes. Meeting the UTS levels for antimony and
vanadium would need modifications to their treatment recipes, requiring one year to
implement. The proposed UTS level for cadmium (D006) could not be met by the
facility. Those waste streams would have to be sent off site for treatment. Mr. Davis
noted that a UTS level of 0.20 mg/L for cadmium would not be achievable; however, a
UTS level of 0.50 mg/L could be met. '
Mr. Scott Maris
Technical Manager . . .
Environmental Quality
Location: Detroit, MI
Phone:313-699-6230
Fax:313-699-3499
Interview conducted by: Gail Shaw
Date of interview: September 17,1996
Date of follow-up interview: January 8,1997
Mr. Maris responded that their facility'treats 300,000 tons/year. Approximately 50
percent is hazardous, while the other 50 percent is non-hazardous. He noted that 100
percent of the treatment capacity is commercial. They do treat Phase IV waste; 100
percent of what is received on site is treated, and no percentage of the wastes are part of
a treatment train. All of the Phase IV wastes can be treated to UTS at the present time
and the same is expected in the future. The facility expects no problems treating to
individual standards or a rr;xcd constituent waste stream. Also, there will be no
problems treating organic UHCs; their facility uses the process of chemical oxidation,
with bleach being a common oxident. No modifications will need made to the treatment
process. The facility can accept another 20-50 percent of additional Phase IV wastes,
increasing available capacity to 360,000-450,000 tons/year.
In meeting the hypothetical UTS levels, Mr. Maris confirmed in a follow-up call .
that the facility would have no difficulties. The levels are all the same or higher than the
UTS levels they are currently meeting.
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. . ' * *
Mr. Joseph DeSipio and Mr. Rick Valiga
Principal ,
Environmental Technologies, Inc.
\ Location: King of Prussia, PA
Phone: 610-354-9050
Fax:610-354-9851 .
Interview conducted by: Gillian Foster and Gail Shaw
-Date of interview: August 27,1996
Date of follow-up interview: January 2,1997
i. >
Mr. DeSipio responded that the facility treats 65 percent de-Bevilled wastes and
25 percent TC metals. They also treat a small amount of biological wastes. The facility
uses a three-phase treatment system consisting of physical sizing, chemical leaching with
acids and reagents, and liquids processing. They extract metals put of the aqueous waste '
stream into usable concentrations that are sent to industrial processing facilities. The
wastewater is neutralized and discharged into the sewer. Solid waste residue is then
returned to the soil. In general, approximately 50 percent of the wastes treated are
treated off site and 50 percent are treated on site. The interviewee believed that the
percentage of wastes accepted at the facility that is part of a treatment train begun at the
generator fs facility is low. The interviewee estimated that the facility could provide
70,000 tons annually of off site capacity and 70,000 tons annually of on site capacity for
typical metal wastes. The only problematic waste stream is TC metal, wastes that are also
low-level radioactive wastes. The facility does not currently treat these wastes. However,
Mr. DeSipio indicated that the facility is planning to treat .them in the future. The plant
would need 4 weeks to be retrofitted to accept low-level radioactive/TC metal wastes.
The de-watering systems for the soils that pass through would.need to be expanded to
handle incresed quantities. The facility can accept almost no additional Phase IV Wastes.
They expect all individual standards to be met. ^
In a follow-up call, Mr. Valiga said that the facility would have no difficulties
meeting the hypothetical UTS levels. He noted in particular that antimony, beryllium,
nickel, thallium, vanadium, 'and zinc would create no treatment difficulties because they
are easily soluble.
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Mr. Rod Bartchy
Vice President of Public Affairs
EnviroSafe
Phone: 1-800-523-0781, ext. 5470
Fax:215-956-5438
Interview conducted by: Gail Shaw
Date of interview: September 25,1996
Date of follow-up interview: January 13,1997
Mr. Bartchy commented that their facility in Ohio treats 1,000 tons/day of
primarily hazardous waste, depending on the level of business. 20,000 tons/year of
capacity is available for Phase IV wastes. The facility hi Idaho has the design capacity to
treat up to 110,000 tons/year of primarily hazardous waste. The facility usually treats less
than 50,000 tons/year in terms of actual receipts. 40,000 tons/year of capacity is available
for Phase IV wastes. He noted that 100 percent of treatment capacity is commercial.
They do, treat Phase IV TC metal wastes; 100 percent of Phase IV wastes are treated on
site at the facility, and a minority of wastes may be part of a treatment train. Most of
these Phase IV wastes meet the UTS at the present time, and would not be a problem in
the future. There would be no problems treating to individual standards or treating a
mixed constituent waste stream. However, the facility can not treat organic UHCs. No
modifications will need made to the treatment process except perhaps minor additive
changes. Mr. Bartchy estimated the facilities could currently accept another 150,000 -
200^000 tons of additional Phase IV wastes. The facility can provide. supporting data if.
requested. . .
. ' i
In a follow-up call, Mr. Bartchy said that the facility would have no difficulties
meeting the hypothetical UTS levels. ,
Mr. Warren Norris .
Sales Manager
GNI (Disposal Systems) , . .
Location: Deer Park, TX
Phone:713-930-0350
Fax:713-930-2511 ''
. Interview conducted by: Gillian Foster , ' " . '
Date of interview: August 21,1996
Date of follow-up interview: Left messages January 2 and January 8,1997
Mr. Morris responded that their facility treats mineral processing wastes and
wastes that fail the TC metals only. The facility does not'conduct off site treatment, only
on site at the facility. None of, the wastes are pretreated before reaching the site. The
facility accepts liquid wastes that undergo oil removal (reclaimed for. heat value), /
dewatering, and filtration. The liquid phase is deep well injected. The facility holds a
-------
no-migration petition variance. The solid phase is stabilized "on site or shipped off site
for incineration. The facility manages 333,000 wet tons of liquid wastes before treatment
per year. The facility has a capacity of 1,159,000 tons per year. The facility also
manages 2,400 tons of solids per year. All volumes are approximate. None of the waste
streams will cause the facility to make modifications in their treatment process.
Approximately 50-75 percent of TC metal waste streams have constituent concentrations
above TC or UTS levels. Mr. Norris expects that all TC and UTS standards will be able
to be met for the TC metal waste streams. He noted that cadmium stabilization is
difficult, although hot impossible. Selenium does not stabilize well, and arsenic is very
soluble and leaches readily. The facility handles arsenic by mixing the waste with
aqueous wastes or water and then deep wells the arsenic containing liquid phase.
Mr. Terry Farrell
Heritage Environmental Services '
Location: Indianapolis, IN * '
Phone:317-486-2726 ,
Fax: 317-249-2046
Interview conducted by: Gillian Foster
Date of interview: August 20,1996 .
Date of follow-up interview: Left message January 8
Mr. Farrell responded that their facility does not treat a significant volume of de-
Devilled wastes, if at all, and they do not accept TC organic waste streams.
Approximately 60 percent of the wastes they stabilize are generated by their on site
treatment facility. This facility treats plating wastes, acids, and caustic liquid wastes
through metals precipitation and treatment. The treated wastewater is then filtered in a
filter press that generates a liquid, which is discharged to a sewer, and a filter cake, which
is stabilized and disposed in a landfill. About 40 percent of their waste stream is filter
cake that arrives from off site for stabilization and disposal. In order to meet the UTS
for underlying organics, the facility has two options: 1) pre-screen waste materials against
organics and refuse those waste streams; 2) undergo a "significant facility expansion" by
adding a treatment process to the treatment train that will address organics (e.g., . .
chemical oxidation, or thermal treatment). The second option could take two years for
the permit modification approval process, engineering, and construction. The tune
period would depend upon the type of permit modification that is required (e.g.,Class I,
II, or III). Almost 100 percent of the TC metal waste streams have constituent
concentrations above TC or UTS levels that would require additional or modified
treatment. Metals with organic UHCs are problematic at this facility. Their process is
geared towards handling characteristic metals only. At the least, additional analytical
expense would incur. Mr. Farrell believes that Phase IV would force waste streams to
incineration because many waste metal waste streams would need to be incinerated for
the organic UHCs. In a mixed constituent waste stream, nickel is the hardest constituent
to stabilize. Lead, chromium, and cadmium follow nickel in stabilization difficulty.
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Cyanides present in the filter cake received from off site could require 'oxidation or
chlorinating to meet the UTS. .
Ms. Kim Knotts
Environmental Coordinator '
LWDInc.
Location: Calvert City, KY
Phone:502-395-8313
Fax:502-395-8153
Interview conducted by: Gail Shaw
, Date of interview: September 17,1996 . .
Date of follow-up interview: January 2,1997
Ms. Knotts responded that in 1995, their facility treated 35,320 tons of hazardous
waste through incineration. Another 10 percent was non-hazardous. Additionally, 3,642
tons of hazardous waste and non-hazardous waste was treated through chemical
stabilization (35 percent being non-hazardous). She noted that 99 percent of the
treatment capacity is commercial. The facility does treat Phase IV waste; 100 percent
can.be treated to UTS at the present time and the same is expected in the future. The.,
facility expects no problems treating to individual standards. There will be also be no
problem treating organic UHCs; the facility will vary their stabilization process, using
different chemicals to drive off the organics. Treatment problems may occur with mixed
metals. No modifications will need to be made to the treatment process, except minor
changes in stabilization processes for mixed metals. A few weeks will be necessary for
these minor modifications. '
In a follow-up call, Ms. Knotts noted that the facility has not tried to meet levels
as restrictive as the hypothetical UTS levels.
Mr. Mark Rein
Assistant VP of Environmental Affairs
PDC
Location: Peoria, IL
Phone: 309-688-0760
Fax:309-688-6801
Interview conducted by: Gail Shaw
Date of interview: September 17,1996
Date of follow-up interview: January 2,1997
Mr. Rein responded that the facility receives only hazardous waste for treatment.
-------
Phase IV wastes (30-40 percent of the waste, stream) are treated; 100 percent of wastes
received on site are treated. Approximately 30-40 percent of the waste stream is part of
a treatment train. He noted that 90 percent of Phase IV wastes can be treated to UTS
at the present time and the same is expected in the future. No problems are expected in
treating to individual standards or a mixed constituent
problem with organic .UHCs. Their facility does not have the capability to treat UHCs.
They are treated off site at another facility prior to behg received at this facility. No
modifications will be made to the treatment process. liefer to the comments on the
August 1995 proposed rule submitted to. EPA for supporting data.
Rein
, In meeting the hypothetical UTS levels, Mr.
would have no difficulties except with lead (D008). Fo
recipes would need to be modified, requiring. approximately
Mr. Richard Grondin
Technical Manager ,
Rollins Environmental Services . .
Location: Deer Trail, CO
Phone: 970-386-2293
Fax:970-386-2262
Interview conducted by : Gillian Foster
Date of interview: August 21,1996
Date of follow-up interview: January 10,1997
Mr. Grondin responded that 1 percent of their facilities'total waste stream is de-
Beviiled wastes. Approximately 50 percent of .the total
only wastes. The, facility does not conduct off site treatrient, only on site at the facility.
Twenty percent of its solid waste stream is comprised c f incinerator residuals received
from off site. Rollins provides stabilization, chemical p recipitation, chemical reduction,
;chemical oxidation, and on site disposal in a Subtitle C
receives approximately 100,000 tons to 125,000 tons pei
waste stream. There will be a
commented that the facility
r this constituent, the treatment
one month. .
waste stream is TC for metals
landfill. The facility presently
year, of waste that can be treated
to UTS. -The total capacity at the facility is approximately 200,000 tons per year.
Approximately 99 percent of the waste stream is solid waste and only 1 percent is liquid
waste. Treating selenium (Lj 10) through stabilization to UTS is impossible at this
facility. They generally exclude waste streams with high concentrations of
seleniumcurrently five to ten tons per year. D010 wastes, comprise less than 1 percent
of the total wasteareated at the facility. The UTS leve
to several factors: 1) selenium is an emphoteric metal;
both low and high pHs; 2) selenium cannot be reduced
optimum pH for selenium stabilization is between 6 and 7. However, at pH 6-7, all other
TC metals will readily leach from the matrix at levels ax>ve the TCLP and UTS
standards. As a result, many selenium bearing wastes i.re sent to Canada for disposal.
Mr. Grondin believed that .the Phase IV LDRs would result in more D010 waste shipped
for selenium is unachievable due
t is teachable in many matrices at
or oxidized efficiently; 3) the
-------
to Canada for disposal. In treating chromium (D007), the, facility will have to increase
the amount of reagent used, thus increasing the cost. D007 wastes comprise 10 percent
of the total waste stream. Generally though, no extensive modifications to the treatment
processes will be necessary. Except for selenium, there should be no problem treating all
other TC metal wastes and de-Bevilled wastes to UTS.
In meeting the hypothetical UTS levels, Mr. Grondin commented that the facility
would have no difficulties except with selenium (D010), which could not be treated. For
this constituent, he noted that a UTS level of 5.7 would be achievable,
In addition to phone conversations, a, site visit to Deer Trailwas conducted by Mr,
Howard Finkel, Project Manager at ICF Incorporated, on August 20,1996.
-------
ICF
Appendix C-2
CONSULTING GROUP
ICF Incorporated
9300 Lee Highway
Fairfax. VA 22031-1207
703/934-3000 Fax 703/934-97-10
MEMORANDUM
To: Bill Kline and C. Pan Lee, EPA
From: Raghu Raghavan and Jim Laurenson
Subject: Status Report on the Available Capacity Assessment for TC Metal and Mineral
Processing Wastes.
This memorandum addresses available capacities
recovery for meeting the Phase IV TC metal and, mineral
are currently conducting the following activities:
We are combining and substantially updatir g the discussion of available
commercial treatment capacity given in the
analyses supporting the proposed LDR rule
June 14,1996
fir
metal waste stabilization and metal
processing waste LDR standards. We
background document for the capacity
We have conducted a preliminary review o
for 1993 to identify commercial facilities providing
metal recovery capacities.
We have compiled .BRS information on the
utilized capacity for various treatment system
recovery at these facilities.
We have compared the BRS information
performed for the Third Third LDR rule (
with
We are in the crocess. of contacting compai
commercial facilities to improve our data
capacity for the wastes affected by the proposed
The remainder of this memo presents our preliminary results of the BRS data review and our
activities concerning the contacting of facilities.
A facility required to submit the BRS must complete a separate and independent Form PS
for each on-site hazardous waste treatment, disposal, or recycling process system that was existing
and operational, for which there were plans to build and start operations, or that was in the
closure process. The information given in Form PS includes estimates of the maximum
, operational and actually used capacities for each system type available on site. After t
preliminary review and comparison of data given in the Form PS in 1991 and 1993 BRS, we
the biennial reporting system (BRS)
metal waste stabilization and
maximum operational capacity and
providing stabilization or metal
the results of the capacity analysts
990).
aid
lies who are operating selected
understanding of the .available
rule.
-------
decided to focus on the RCRA capacity related information and other data given in Form PS in
1993 BRS for the following metal recovery and stabilization systems: .
* Metal Recovery Systems
. . ' MO 11 High temperature metals recovery ;
M012 Retorting
M013 Secondary Smelting
MO 14 Other metals recovery (e.g., ion exchange, reverse osmosis, acid leaching,
etc.)
MO 19. Metals recovery - type unknown .
Stabilization .
Mill Stabilization/Chemical fixation using cementitious .and/or pozzolanic
materials .
Ml 12 Other stabilization
Ml 19 Stabilization - type unknown
By using the information given in Form PS to define the commercial capacity availability of each
system, we were able to list separately the facilities having commercially available and non-
commercial capacities for metal recovery and stabilization. The following lists are attached with
this memo as an illustration of'the preliminary results of maximum and utilized RCRA 'capacities
that we obtained from use of Form PS in the 1993 BRS:
* Commercial stabilization systems and capacities;
Non-commercial stabilization systems arid capacities;
Commercial metal recovery systems and capacities; and
Non-commercial metal recovery systems and capacities.
the attached preliminary tables have been analyzed further by comparing their contents with
information on the utilization of capacity given in other forms - Forms WR and GM in the
1993 BRS. As mentioned before, the BRS information was compared with the results of the
capacity analysis performed for the Third Third LDR rule.
t .
Based on the analysis of 1993 BRS completed to-date, it seems that there are nearly 30
operational facilities providing commercial stabilization capacity. The utilized capacity for
stabilization appears to be approximately 750,000 tons per year. The maximum operational
capacity at these commercial facilities has yet to be confirmed. (For example, the attached table
on commercial stabilization indicates that several facilities reported maximum capacities that far
exceeded utilized capacities. These data must be confirmed through personal contacts of the
facilities or by using other reliable sources of information.) However, it seems that the available
stabilization capacity would be more than the previous estimate of i million tons per year. The
1993 BRS information also showed that additional stabilization capacity is utilized and available at
nearly 60 non-commercial facilities. As for metal recovery, nearly 60 commercial facilities have
reported the utilization of approximately 600,000 tons of capacity in 1993. Additional capacity for
metal recovery is also being provided at nearly 120 non-commercial facilities. The maximum
operational capacity at commercial metal recovery facilities must also be confirmed. (As with
stabilization capacity, the attached table on commercial metal recovery shows large differences
between maximum and utilized capacities.) \
-------
At present, we are trying to improve the data obtained
operational and utilized capacities for commercial stabilization
however, to improve upon the quality of these numbers thrc ugh
contacts of selected facilities. It is also necessary to obtain-at
addressing the logistics and applicability of existing technologies
identified mineral processing wastes and other TC metal.wastes
We have selected the following six companies to discuss the available capacity for metal
waste stabilization: ''-,'
^ 1. Laidlaw Environmental Services,Inc.
.2. Rollins Environmental. Services
3. Chemical Waste Management
4. . Peoria Disposal Company
5. Gibson Environmental .
* .6. Republic Environmental Systems, Inc.
The first three companies operate commercial hazardous waste
commented on the proposed Phase IV LDR rule. Most of
Commercial Treatment/Recovery Data Set (May 1990) and
capacity on site. The last three companies listed above were
capacities for metal waste stabilization. All of these
available capacity on stabilization for some of the hazardous
We have selected the following six companies to discjuss the available capacity for metal
recovery: -
1. INMETCO, Inc.
2. Quemetco, Inc"
3. Revere Smelting and Refining Corp.
4. s Recontek Inc.
5. ETICAM Process
6. Encycle Texas Inc. . '.
INMETCO provided'comments, on the proposed Phase IV LDR rule. The next two companies
showed'high utilization of secondary smelting capacity at their facilities. The last three companies
were selected due to the need for confirming that they are a:tive in processing a wide range of
metal-bearing hazardous wastes, as reported in the capacity ; nalysis background document
supporting the proposed rule. We are expecting to resolve some of the major discrepancies
between maximum and utilized capacities shown in the attached table on commercial metal
recovery systems (e.g.,Phibro-Tech, Inc.) without contacting the facilities.
from BRS oh maximum
and metal recovery. It -is necessary,
a limited number, of phone"
least some qualitative. information
to meet the UTS for newly
landfills in different states and
hese landfills were reported in EPA's
n the 1993 BRS to have stabilization /
also reported in BRS to have large
compan es may be interested in providing
waste affected .by Phase IV LDRsl
We are asking one or more of the following question;
already provided or expected) after contacting the right person
What is the maximum capacity for stabilizatio i
each of the facilities operated by the compan}?
(depending on the information
in each of these companies:
and/or metal recovery installed at
' How was this capacity measured?
-------
When was the facility originally buik? What kind of technology confirmation was
required before designing, building, or starting operations at the facility?
What is the current utilization of capacity at each facility? What percentage of
' ' capacity is utilized for commercial purposes? Are there any limitations in the use
of commercial capacity? What is the non-commercial capacity used for?
What are .the types of capacities available? For example, is stabilization '
technology based oh physical encapsulation or chemical fixation? As another *
. example, what are the metals recovered from the wastes? Are there any technical
limitations in the use of technology(ies) used at the facility?.
What types of industries/wastes are being provided with commercially available
treatment, capacity? Newly-identified, mineral processing wastes?'Other TC metals
required to meet UTS?
Will the company be interested in building and/or operating on-site metal waste
stabilization or metal recovery facilities for selected new customers? Has the
company considered or provided similar services in the past? What are the
logistics and economic considerations in developing this additional capacity?
, . ' , V
' I *
In addition to contacting these, companies, we are in the process of contacting a few selected
trade associations to confirm our new findings on the availability of commercial stabilization or .
metal recovery capacity, and the feasibility of building new waste treatment capacities on.site. We
also plan to discuss these topics with some'technical specialists in metal waste stabilization or
metal recovery. For example, we plan to contact one of the authors of the, attached paper on
chemical fixation, Gregory Indelicato, to discuss the applicability of new techniques in chemical
fixation for hazardous waste treatment. . ,
Please call Raghu Raghavan at 703-934-3417 or Jim Laurenson at 703-934-3648 if you
have any questions on this memorandum.
-------
Commercial Stabilization Systems
(Basls:1993BRS-Forin PS)
Facility Facility Nam*
COD991 300484 HIGHWAY 36 LAND DEVELOPMENT CORP
CA0980883177 GIBSON ENVIRONMENTAL
I LD 00080581 2 PEORIA DISPOSAL CO INC
PAD085690592 REPUBLIC ENVIRONMENTAL SYSTEMS, INC.
UTD991301748 USPCI- GRASSY MOUNTAIN FACILITY
AL0000622464 CHEMICAL WASTE MANAGEMENT
MID000724831 ENVQTECH MANAGEMENT SERVICES, INC
IND093219012 HERITAGE ENVIRONMENTAL SERVICES, INC
MID074259565 DYNECOL INCORPORATED
PAD059087072 MILL SERVICE INC - BULGER
GAD096629282 CWM RESOURCE MANAGEMENT INC
PAD00483514S MILL SERVICE INC YUKON
KYD985073196 LWD SANITARY LANDFILL, INC.
NYD049836679 CWM CHEMICAL SERVICES, INC.
OKD065438376 U.S. POLL CONTROL, INC.-LONE MOUNTAIN
OHD045243706 ENVIROSAFE SERVICES OF OHIO INC
OHD980568992 ENVIRITE CORPORATION
MID096963194 CHEM-MET SERVICES INCORPORATED
ILD01 0284248 CIO RECYCLING & DISPOSAL FAC
1000731 14654 ENVIROSAFE SERVICES OF IDAHO, INC
IND07891 1 1 46 CHEMICAL WASTE MANAGEMENT OF INDIANA INC
PAD0101S4045 ENVIRITE CORPORATION
CTD072138969 ENVIRONMENTAL WASTE RESOURCES INC
OHD083377010 ENVIRONMENTAL ENTERPRISES INC
OHD000816629 SPRING GROVE RESOURCE RECOVERY INC
IND984874230 ROANOKE WASTEWATER TREATMENT PLANT
CTD089631 956 EAST COAST ENVIRONMENTAL SERVICES
NVT330010000 US ECOLOGY INC . !
OKD000402396 PERMA-FIX TREATMENT SERV., INC.
OKD082708371 HUGO RAILCAR
GAT000001971 GEORGIA DEPARTMENT OF TRANSPORTATION
OKD007224702 BARTLETT-COLLJNS GLASS CO.
CATC 800 101 01 APPROPRIATE TECHNOLOGIES 11, INC.
CAT080033681 CHEM-TECH SYSTEMS, INC. .
ILD000608471 CLEAN HARBORS OF CHICAGO INC
LAD000777201 CHEMICAL WASTE MANAGEMENT
NED981 1171 53 HOUSTON J-M CORPORATION
OKD096648837 MORRIS SUCKER ROD
CAD021 774559 AMERICAN BRASS * IRON FOUNDRY
TOTAL QUANTITY FOR COMMERCIAL FACILITIES
'-..'. '. ' ' -
^ .**... .t ' i . '
System 1 Maximum RCRA LHHI».^ n«« . \
\ Code
^Mlll
"TSiT
^Mii
Mil
Mil
M11
;MHI
M111
M112
^Mlll
M112
M111
1M111
Mill
M111
'Mill
M112
Mill
M111
Mill
Mill
M112
Mill
M111
Mill
M111
Mill
M111
Mill .
M111
Mill
M111
Mill
M111
Mill
Mill
Mill
Mill
M111
Capacity
40.000.000
1.752.000
1.187.840
547.500
468.000
428,442
Capacity
17,233
47,231
41,557
8,862
14.8SO
57.370
385.804 I 1<19 119
350.000
224.648
175.000
132.919
130.088
120.000
106.392
95,200
80.000
75.000
29.800
27.243
.
423
9,558
656
60,822
93,568
56,500
41,056
73.502 i 19.965
67.200
52.000
50.700
50,000
40.000
25,200
15,230
14,900
5,000
670
107
55
8
' 4
.
*
. *
46,633,208
2.843
10,920
34.197
32,267
1,323
16,200
2.116
7,450
22
40,810
21
32
8
4
4
.
'
50,973
«
1
273
868,312
-
and Capacities
1 Data in this memorandum has not undergone extensive review by the Agency,
-------
Non Commercial Stabilization Systems and Capacities
(Basis: 1993 BRS-Form PS)
t
Facility . Facility Name
System
Code
ID4890008952 USDOE IDAHO NATL ENGINEERING LABORATORY M1 1 1
MID005356860 CMC, INLAND FISHER GUIDE M111
LA D01 0395 127 ROLLINS ENVIRONMENTAL SERVICES M111
ALD003397569 ACIPCO (AMERICAN CAST IRON PIPE COMPANY) M111
CAD009151671 E I DUPONT DENEMOURS & CO M111
A LD 04648 1032 SANDERS LEAD COMPANY, INC. M111
ILD006271696 OLIN CORP M112
ILDOOS2631S7 NORTHWESTERN STEEL & WIRE #2 M111
CAD009114919 CHEVRON USA PRODUCTS CO, RICHMOND REFIN M111
AZ4570024055 DAVIS MONTHAN AFB JM111
LAD008184137 SCHUYLKILL METALS CORP M111
IND005146683 THE FORD METER BOX CO., INC. M112
NCD986181451 MANNINGTON CERAMIC TILE M111
OH D032271 975 MARION STEEL COMPANY M112
NYD980779S40 WEST VALLEY DEMONSTRATION PROJECT I M1 1 1
ALD983191966 VIRGINIA CAROLINA CHEMICAL SO M111
VAD065417008 GRIFFIN PIPE PRODUCTS CO . ;M111
IND06470884S KUNKLE FOUNDRY CO..INC.
GAD033842543 TRI-ST ATE STEEL DRUM INC
C 07890010526 U.S. DEPARTMENT OF ENERGY - ROCKY FLATS
ALD095688875 ZENECA INC-COLD CREEK
FLD984243097 BIO MEDICAL SERVICE CORP
NM089001 051 5 U.S. DOE LOS ALAMOS NATIONAL LABORATORY
MOD006308407 A.B. CHANCE COMPANY ALLEN STREET COMPLEX
IND121581698 WABASH NATIONAL CORPORATION
PAD004329835 PENNZOIL PRODUCTS CO ROUSEV1LLE REFINERY
CAD982412165 TOPPAN WEST, INC
PAD041731670 CERDEC CORP - DRAKENFELD PRODUCTS
MOT30001 0022 A C F IND SHIPPERS CAR LINE DIVISION
MSD033353129 THE CLARION LEDGER
MSD097909485 RELIABLE ELECTRIC UTILITY PROD
FLD9821 20024 BOSTON WHALER INC
IN DO 56041 21 3 LEER MIDWEST . . .
OKD000758557 CHROM ALLOY DIVISION-OK
GAD098S83909 HERCULES INC OXFORD PLANT
MOD981709272 IT ANALYTICAL SERVICES ST. LOUIS
CTD981 063431 PFALTZ & BAUER INC
DC8170024311 NAVAL RESEARCH LABORATORY
KSD0071 50477 GNB INCORPORATED
OKD001 824564 AMERICAN AIRLINES, M & E CENTER
OKD007220148 AMERICAN AIRLINES, COMPOSITE CENTER
OKD081398612 UNIT PARTS COMPANY
OKT41 0010797 GEA RAINEY PLANT *fl
CAD001216548 JOSLYN JENNINGS CORP
CAD056160336 LITTON IND ELECTRON TUBE DIV.
CAD982324154 COMPOSITE STRUCTURES
C07890010526 U.S. DEPARTMENT OF ENERGY - ROCKY FLATS
MED001 097237 SNS PLASTICS CO INC
OKD000829440 ZINC CORPORATION OF AMERICA
VAD003444379 VIRGINIA METALCR AFTERS INC
M111
M111
M111
M112
M112
M111
M111
M112
M111
M111
M111
M111
M111
M111
M112
M111
M111
M112
M111
M111
M112
M111
M111
M111
M111
M111
M112
M112
M112
Ml 12
M112
M112
M112
Maximum RCRA Utilized RCRA I
Capacity
., 360,000
190,360
130,000
60,034
50,000
44,777
40,320
35,092
31,590
25,000
25,000
15,000
12,000
4,500
2,865
2,500
2,300
1,125
1,040
831
500
459
173
150
117
100
75
75
40
34
25
24
4
3
0
0
0
0
..
'
.
-
.
'
- .
'-.
.
.Capacity
. 'I
107.871
65
2,000
18,080
26,019
1,309
27,192
.
24,167
10,499
1,721
7,935
3,277
906
2,500
1,236
244
, 175
,
244
137
60
521
11T
65
5
23
: 10
34
12
24
4
24
0
0
0
'
170
187
38
212
7
-
-
- ,
_
il
1
- 1
Pagel
-------
Non Commercial Stabilization Systems and Capacities
(Basis: 1993 BRS-Form
MOD985821719 MIDAMERICAN TRUCK MAINTENANCE
OKD000829440 ZINC CORPORATION OF AMERICA '
MD61 50004095 NATIONAL INSTITUTES OF HEALTH
MD61 50004095 NATIONAL INSTITUTES OF HEALTH
TOTAL FOR NON-COMMERCIAL FACILITIES
M119
M119
M111
IM112
-
- '
'
. 1,036,112
- .
3
0
0
236,526
Page 2
-------
f
Commercial Metal Recovery Systems and Capacities
(Basi: 1993 BBS-Form PS)
. . . : System
Facility Facility Name . Code
NYD981 182769 KBF POLLUTION MANAGEMENT INC M019
CAD00848802S PHIBRO-TECH, INC. , M014
PAD002395887 HORSEHEAD RESOURCE DEVELOPMENT CO INC M011
PAD990753089 GENERAL BATTERY CORP - READING COMPLEX M013
MND006148092 GOPHER SMELTING & REFINING COMPANY M013
ILD984766279 RECONTEK INC M014
CAD069124717 MICRO METALLICS CORPORATION M011
ALD046481032 SANDERS LEAD COMPANY, INC. M013
P A D9 8 1038227 WORLD RESOURCES COMPANY M014
MOD059200089 DOE RUN CO BUICK SMELTER M0 13
P A D9 81 11 0570 HORSEHEAD RESOURCE DEVELOPEMENT CO INCM011
CAD088504881 KINSBURSKY BROTHERS INC. M014
MND981 098478 U.S. FILTER RECOVERY SERVICES, INC. M014
C A D070 148432 DREW RESOURCE CORPORATION M0 14
CAD069124717 MICRO METALLICS CORPORATION M0 14
MND985746569 RECYCLIGHTS, INC. M014
LA D0571 09449 UOP - SHREVEPORT PLANT M0 14
ILD005087630 UNITED REFINING & SMELTING CO JM011
IND093219012 HERITAGE ENVIRONMENTAL SERVICES, INC M014
C AD001 968361 LEARONAL INC M014
NYD001 325661 LEARONAL, INC. M014
LA D981 152903 NEW ORLEANS SILVERSMITHS \ M014
FLD984217877 CHEMICAL POLLUTION CONTROL INC M019
MID9855671 14 CYANO CORPORATION OF MICHIGAN INC. M014
NYD0481481 75 MERCURY REFINING COMPANY INC . M012
PAD002390961 BETHLEHEM APPARATUS CO INC M012
PAD987367216 ADVANCED ENVIRONMENTAL RECYCLING CORP M012
OHD061614673 DAYTON WATER SYSTEMS M014
CAD9816899S3 LESHER COMMUNICATIONS INC. M014
ILD005087630 UNITED REFINING & SMELTING CO M0 14
CAD982440273 BAY PHOTO LAB INC. M014
CAD069138899 J&B ENTERPRISES ' M014
NYD001 325661 LEARONAL, INC. ' ' M011
ILD000675249 AMERICAN CHEMICAL & REFINING . M014
KS 1571 9241 40 MCCONNELL AIR FORCE BASE M014
LAD087029872 ALFRED'S PROCESSOR SALES/SERVICE M014
PAD089352983 FEDERATED-FRY METALS M013
MND981 002470 ELECTROCHEMICALS, INC M014
MAD0006S0051 WINDF1ELD ALLOY INC. . M0 14
NYD086225596 AT&T NASSAU PLACE M0 14
CAD981424732 QUICKSILVER RECYCLING INC M019
IND005226949 REMOTE CONTROLS INC. M014
NYD086225596 AT&T NASSAU PLACE , M011
RID001200609 PEASE & CJRREN INC M0 19
AZT050010685 ALLIED PRECIOUS METALS RECYCLING CO. M013
CAD981424732 QUICKSILVER RECYCLING INC M0 14
RID001200252 TECHNIC INC . M011
MAD000650051 WINDFIELD ALLOY INC. M013
Maximum RCRA
Capacity
4,035,363
2,322,554
300,000
83,600
48,000
48,000
28,050
25,000
24,250
21,175
20,000
15,980
8,655
8,501
5,976
5,622
2,600
2,500
2,105
1,142
1,004
890
842
788
510
375
345
259
209
209
186
133
125
104
104
100
83
78
38
38
.36
27
25
22
20
5
5
3
Utilized RCRAJ
Capacity fl
i ^
1.757
608,199
270,000
3,894
- 60,251
357
39
5,200
. 20,446
1,339
1,216
10,500
418
3,346
31
610
726
126
6
100
46
157
6831
190|
311
350
172
197
23
5
80
53
6
,52
-
39
83
64
1
29
32
27
12
7
60
- j
1
OJ
Pagel
-------
Commercial Metal Recovery Systems
(Basi: 1993 BBS - Form
and Capacities
PS)
R I DO0 1200252 TECHNIC INC
NYD071600100 STATE UNIVERSITY OF NY AT BINGHAMTON
CAD0691 38899 J&B ENTERPRISES
NYD03048S288 REVERE SMELTING & REFINING CORPORATION
CAD9811 60948 PHIBRO-TECH, INC. AKA ENTECH RECOVERY, I
PAD087561015 INMETCO INC . .
CAD982411993 MERCURY TECHNOLOGIES INTERNATIONAL
IND000199653 QUEMETCO, INC.
R I D9 8 1886 104 GANNON & SCOTT INC
COD983788688 ENVIROSERVE INC.
IND984891994 BOLIDEN METECH, INC
MID985619824 NORTRU INCORPORATED
RID063890214 BOLIDEN METECH INC
RID981886104 GANNON & SCOTT INC
IND000718130 REFINED METALS CORPORATION
MOD030712822 SCHUYLKILL METALS CORPORATION
CAD9B1 978752 PASADENA CITY COLLEGE
CAD982523102 PHOTOTEK
TXD084281575 TEXAS INSTRUMENTS, INC.
TXD981514383 ALPHA OMEGA RECYCLING, INC.
TXD988079307 FUJI TRUCOLOR
TX6213820529 LONGHORN ARMY AMMUNITION PLANT
TOTAL QUANTITY FOR COMMERCIAL FACILITIES
M019
M014
M011
M013
M0 14
M011
M0 12
JM013
M013
M014
M014
M014
M014
M0 14
M013
M013
M014
M014
M014
M014
M014
M014
2
1
0
-
.
'
,
' -
/
. -"
-
' -
;
;- '
i
.
'
'
. -
-
7,015,635
84
: 0
0
114,362
560
40,168
.
148,548
6
64
153
32
«
- ,
-
-
-
'
1,295,222
Page 2
-------
Non Commercial Metal Recovery Systems and Capacities
(Basis: 1993 BPS- Form PS)
Facility Facility Name
System
Code
LAD008184137 SCHUYLKILL METALS CORP M0 13
IND000717959 GENERAL BATTTERY/EXIDE CORPORATION M013
CAD008344285 DICEON ELECTRONICS INC M014
MAD990886301 ALTRON INCORPORATED M0 14
CAD980816763 VELfE CIRCUITS INC. M014
MND0507301 75 HARD CHROME INC M014
CAD983601360 SOUTH BAY CIRCUITS INC M014
PA0990753089 GENERAL BATTERY CORP - READING COMPLEX M013
IAD984568204 UNIVERSAL CIRCUITS INCORPORATED M014
MID006409387 PLASTIC PLATE 1 M014
MNT280010257 NICO PRODUCTS INC M014
MND980700900 BUREAU OF ENGRAVING, INC INDUSTRIAL DV M014
CAD008492951 HUGHES MISSILE SYSTEMS CO M014
MN0045976107 PRO-TECH INC M014
MND11 6224288 PROFESSIONAL PLATING INC M014
PAD005031448 ERIE PLATING COMPANY
NJD011417516 PLASTI CLAD METAL PRODUCTS INC
MND981 089832 UNIVERSAL CIRCUITS, INC.
MID981 090509 LACKS, AIRLANE
FLD004092839 GULF COAST RECYCLING INC
CAD983654633 TRUST PRINTED CIRCUITS
MND9806815B9 AVTEC FINISHING SYSTEMS INC
MND006481287 JOYNER'S SILVER AND ELECTROPLATING
IND980898522 CUSTOM CIRCUITCRAFT, INC.
CT4170022020 US NAVAL SUBMARINE BASE
GAD070330576 GNB BATTERY TECHNOLOGIES
RID059735761 ADVANCED CHEMICAL COMPANY
ARD981 908890 NUCOR YAMATO STEEL
CAD009680232 GRAPHIC RESEARCH INC
MND006219232 MICOM CORP
NYD001273242 QUEENS PLATING COMPANY INC
NHD982202673 ABC FABRICATORS INC '
PAD0021 16994 TORPEDO WIRE 4 STRIP INC.
MND053422762 UNIVERSAL CIRCUITS INC
NYD041293127 R D SPECIALTIES INC
AZD980896310 CONTINENTAL CIRCUITS
MND0851 14890 TELEX COMMUNICATION INC
AZD980816276 TALLEY DEFENSE SYS
IND075954222 DIVERSFIELD SYSTEM INC.
MAD001411081 RAYTHEON COMPANY
MND006253801 SUPERIOR PLATING INC
NYD052782497 NEWSDAY, INC.
MND079731519 UNISYS CORPORATION
CAD982519423 SAN JOSE MERCURY NEWS
MND98061 5496 ROSEMOUNT AEROSPACE INC.
AZD063274609 CONTINENTAL CIRCUITS CORP
KYD985083625 , APPALACHIAN REGIONAL MEDICAL CENTER
CAD982436172 MULTILAYER TECHNOLOGY, INC.
M014
M014
M014
M014
M013
M014
M014
M014
M014
M014
M013
M014
M011
M014
M014
M014
M014
M014
M014
M014
M014
MOU
M014
MOU
MOU
M014
MOU
MOU
M014
MOU
M014
MOU
MOU
Maximum RCRA
Capacity
350,000
240,000
127,284
123,853
114,679
112,594
107,381
106,400
Utilized RCRA J
Capacity 1
6,417]
132,923
58,687
82,877
110,509
170,898
76,755
4,956
106,255 38,729
92,160 ; 43,536
85,488 . 54,712
84,762
, 72,448
72,195
-.-. 45,872
45,746
43,853
43,716
42,952
41,000
33,361
30,901
29,633
26,022
25,500
25,200
18,657
17,000
16,971
.13,136
7,500
6,844
4,918
4,170
3,753
3,700
3,508
3,123
2,752
2,717
2,365
2,180
, 1,719
1,344
1,043
1,000
957
911
.42,400
130
28,731
19,187
45,746
6,649
25,761
42,952
27,513
17,608
10,587
15,6381
15,613 I
23
24,010
827
12,427
2,286
11,259
1,088
3,332
624
3,963
4
751
718
'0
440
1,368
647
3
3
.
518
216]
11
193 |
ft
ft
Pagel
-------
Non Commercial Metal Recovery Systehis and Capacities
(Basis: 1993 8RS- Form PS)
KYD074047556 GE AIRCRAFT ENGINES
CAD983600339 KAISER FOUNDATION HOSPITALS
DED003913266 OCCIDENTAL CHEMICAL CORPORATION
GAD980847479 HITACHI CHEMICAL ELECTRO-PRODUCTS INC
K YD 13039 9363 HUMANA HOSPITAL-UNIVERSITY OF LOUISVILL
MOD985801380 MONSANTOA COMPANY
KYD074051202 LEXINGTON CLINIC
CAD063110605 CHEVRON PETROLEUM TECH. CO.
CAD071 557029 THE GRASS VALLEY GROUP, INC.
ALD008163388 OCCIDENTAL CHEMICAL CORPORATION ,
MAD981 063001 CPC INCORPORATED
MND981089790 WEST PUBLISHING COMPANY
MND985668227 PRECISION DIVERSIFIED IND., INC.
CA21 700231 52 USNAVY CHINA LAKE NAVAL AIR WPNS STN
MND083467688 MAYO FOUNDATION
OKD055943286 GRAPHIC ELECTRONICS
PAD134752583 BURNDY CORP
PAD980554570 OSRAM SYLVANIA INC - WARREN
NHD986466688 CIRCUIT CONNECT INC
FL280001 6121 USAF CAPE CANAVERAL STATION
NYD045201688 AMERICAN BOARD CO
MAD001 01 41 74 AGFA DIVISION, MILES INC,
ALD004019642 OCCIDENTAL ELECTROCHEMICALS CORP.
MDD1 21 338297 CARROLL COUNTY ITEMS
NYD082788126 GEOMETRIC CIRCUITS, INC.
PAD003004587 ATOTECH USA INC - STATE COLLEGE
CAD1 081 48958 SAINT JOSEPH MEDICAL CENTER
Nvnndf\ftnRdfin IM PRINTING & PHRI iQMiMf*
CAD047784574 KETEMAA&E
LAD062666540 PIONEER CHLOR ALKALI COMPANY
CAD008314908 SOLAR TURBINES INC-HARBOR DRIVE FACILIT
CTD983876814 COMPONENT TECHNOLOGIES, INC.
CAD047297593 NATIONAL SMELTING & REFINING
N YD002241 982 HADCO CORPORATION "
OHD004174827 R.R. DONNELLEY & SONS COMPANY
MND058330473 ADVANCED FLEX, INC. - PLANT 1
MAD086538394 RAYTHEON COMPANY
MNT28001 0414 UNIVERSITY OF MINN MPLS CAMPUS
KYD981 854987 ST. JOSEPH HOSPITAL
KYD045739471 AMERICAN GREETINGS CORPORATION
MND000819268 ALLJANT TECHSYSTEMS, INC T.C. AMMUN.
NYD049838568 EXCEL PRECISION, INC.
AKD000643239 BP EXPLORATIOIN ALASKA INC PRUDHOE BAY
CTD001 183763 CIRCUIT WISE INC
KYD068324037 LEXINGTON HERALD LEADER COMPANY
NYD987000759 COLOR DATA EAST
MND982425589 STAR TRIBUNE NEWSPAPER
CAD076243815 TELEDYNE AIRCRAFT PRODS-CAST PRODS OP!
NHD081255788 ADVANCED CIRCUIT TECHNOLOGY
KYD985085166 OUR LADY BELLEFONTE HOSPITAL
i
5
M014
M0 14
M012
M014
M014
M014
M014
M014
M014
M012
M0 14
M014
JM014
M014
M019 ,
M014
M0 14
M014
M014
M014
M014
M014
M012
M014
M014
M014
M014
MM A
M014
M014
M019
M019
M014
M014
M014
M014
M014
M014
MQ14
M014
M0 14
M014
M014
M0 14
M014
M014
M014
M014
M014
M014
822
651
600
506
450
436
420
415
410
400
375
365
311
288
280
271
258
252
250
218
209
204
200
163
150
133
1 s- 125
IOC
119
115
110
92
91
87
87
87
78
66
65
62
60
59
58
54
50
50
48
44
42
40
21
580
153
, 404
24
108
,24
9
98
120
129
123
217
288
240
-
. - 67
39
188
37
197
33
88
16
83
21
63
- ... . 11
3
33
22
64
: '
15
. 46
13
9
59
32
3
20
14
55
2
17
9
5
37
31
34
Page 2
-------
Non Commercial Metal Recovery Systems and Capacities
(Basis: 1993 BPS-Form PS)
KY621 0020479 USAARMC AND FORT KNOX M0 14
KYD144303864 HARDIN MEMORIAL HOSPITAL
MND982639775 T.R.C. CIRCUITS INC,
JM014
,M014
COD98 15494 13 SAS CIRCUITS INC !M014
CTD001 159557 COMBUSTION ENGINEERING, INC. M014
KYD006383665 GATEWAY PRESS INC. M014
PA0890090004 US DOE - BETTIS ATOMIC POWER LAB M014
MND0061471 02 QUEBECOR PRINTING INC. M014
MAD991289505 CHILDREN'S HOSPITAL CORP. M014
CAT080031461 CSUF , M0 14
CAD983576760 PROGRESSIVE CIRCUIT PROD M0 14
GA7360015450 VA MEDICAL CENTER M014
KYD068135516 HIGHLANDS REGIONAL MEDICAL CENTER IM014
MD3750832062 FREDERICK CANCER RESEARCH AND DEVELOP* M01 4
MND048166672 INSTANT WEB, INC 'M014
CAD0801 29000 GENENTECH INC M0 14
FL6800014585 USNASA KENNEDY SPACE CENTER M014
NYD033490640 ANDIN INTERNATIONAL M0 14
FLD060240207 MARTIN MARIETTA MISSILE SYSTEMS M014
CAT000618603 CHEVRON RESEARCH & TECHNOLOGY I M014
CA2890012584 LAWRENCE LIVERMORE NATIONAL LABORATOR
CAD009220898 TELEDYNE RYAN AERONAUTICAL
COD085270270 BALL AEROSPACE & COMMUNICATIONS GROUP
FLD004100152 E-SYSTEMS ECI DIV
UTD980959191 HERCULES AEROSPACE
MND081138604 ALLIANT TECHSYSTEMS PROVING GROUND
MND981 536006 L1THO SPECIALTIES, INC.
MED037719846 US DEPRTMENT OF VETERAN AFFAIRS
CA7170024528 USNAVY NAVAL WEAPONS STN CONCORD
MND980826457 MCF-STILLWATER
CT00011 83763 CIRCUIT WISE INC
FLD980841746 MARTIN MARIETTA ELECTRONIC SYSTEMS
MS621 0809871 WATERWAYS EXPERIMENT STATION
KYD980844757 RIVERPORT IMAGING
KY5170024173 NAVAL ORDNANCE STATION
MND985703024 SOURCE, INCORPORATED
CAT000617597 USC HEALTH SCIENCES CAMPUS
NYD043835081 AIR TECHNIQUES INC
FL2570024404 USAF PATRICK
MDD050793926 TOWSON STATE UNIVERSITY
VAD000820712 UNIVERSTTY OF VIRGINIA
ME8170022018 US NAVAL AIR STATION
MND985684620 IMPRESSIONS INC.
CAD075301390 TELEDYNE AIRCRAFT PRODUCTS
FLD984225821 HEALTHSOUTH DOCTORS'HOSPITAL
MND041786930 ADVANCED FLEX, INC. - PLANT 2
MND985667047 QUEBECOR PRINTING ST. CLOUD, INC.
FLD00410410S HONEYWELL INC
KYD985095140 GOOD SAMARITAN HOSPITAL
MOD071999783 UMSL DANGEROUS CHEMICALS STORAGE BLDG
M014
M014
M014
M014
M014
M019
M014
M014
M014
M014
M019
M014
M014
M014
M014
M019
M014
M014
M014
M014
M014
M014
M014
M014
M019
M014
M014
M014
M014
M014
38
35
34
33
32
30
30
30
28
25
25
23
23
22
22
21
21
20
18
18
18
18
16
16
15
15
14
13
13
12
12
12
11
10
10
10
10
. 10
10
9
9
9
8
8
8
8
7
7
6
6
- , 28
251
^
18 I
1.
12
0
15
17
1
1
8
23
1
12
2
15
. 7
5
1
1
0
2
. 0
6, 1
of
12
1
1
0
1
1
1
3
2
7
8
3
7
1
5
1
5
7
6
6
6
'1
^
iT
Page 3
-------
Non Commercial Metal Recovery Systems and Capacities
(Basis: 1993 8RS-Form PS)
1
>~
ME9570024522 US AIR FORCE BASE - LORING
NYD002235182 MARTIN MARIETTA CORP AIR FORCE PLNT#59
NYD981 875461 PEPSI-COLA COMPANY
MND985677210 CONTAINER GRAPHICS CORP
MAD041710609 TECH-ETCH, INC.
NMD04 1358904 NEW MEXICO INST. OF MINING & TECHNOLOGY
CAT000613372 KCA ELECTRONICS INC.
KSD980852669 UNIVERSITY OF KANSAS
CAD099457061 MAGNAVOX ELECTRONIC SYSTEMS CO
CA1 800005034 USNASA AMES RESEARCH CENTER
CAT000617589 USC UNIV PARK CAMPUS
MN0000819292 ADVANCED FLEX, INC. -PLANT 3
FL8170023792 USN COASTAL SYSTEMS CENTER
CAT080033392 CALIFORNIA STATE UNIVERSITY NORTHRIDGE
MND980792642 MANKATO STATE UNIV
CAD072518517 BECKMAN INSTRUMENTS INC
VAD046960449 BABCOCK & WILCOX CO N N F D
ME71 7002201 9 PORTSMOUTH NAVAL SHIPYARD
CAD079622569 AEROJET ELECTRONIC SYSTEMS PLANT
MAD001027325 GARE INCORPORATED
FLD064824030 MCDONNELL DOUGLAS MISSILE PRODUCTION
MAD001423631 NORTHEASTERN UNIVERSITY
NYD000810986 CORNELL UNIVERSITY LIFE SAFETY
CAD009587700 TELEDYNE ELECTRONIC TECHNOLOGIES
CAD047791421 CARPENTER TECH. CORP. -SPECIAL PROD. DIV
MO421 3820489 LAKE CITY ARMY AMMUNITION PLANT
MID041793589 PARLIN INDUSTRIES INCORPORATED
CTD010174613 KLOCK CO DIV OF WICKES CO INC
CA1 170090020 USNAVY PT LOMA NAVAL COMPLEX
NYD000799239 SYRACUSE UNIVERSITY (QUAD)
KSD007233323 KANSAS PLATING INC
NY6360010312 VAMC - NORTHPORT
MAD071723563 NEW ENGLAND DEACONESS HOSPITAL
NHD073976904 GENCORP POLYMER PRODUCTS
CAD066233966 QUEMETCO, INC. ,
PAD002330165 EAST PENN MFG CO
CAD000628032 AIRCRAFT X-RAY LABORATORIES, INC
CAD001425206 RAYTHEON COMPANY ESD
CAD008319089 CHROMALLOY ADV TURBINOLOGY
CAD020530846 GDE SYSTEMS INC '
CAD02887801 5 STANFORD UNIVERSITY HOSPITAL
CAD069130995 HEWLETT-PACKARD COMPANY
CAD980673347 U.S. CIRCUIT, INC. :
CAD980737837 SACRAMENTO BEE
CAD980885941 ALLERGAN MEDICAL OPTICS
CAD981385958 AMBITECH, INC
CAD982417172 NAPA PIPE CORP
CAD982484826 UNIVERSAL CIRCUITS
CAD990843716 ILC TECHNOLOGY
CAT000646257 FLIGHT ACCESSORY SERVICE DIV. OF HAWKER
Page 4
* V ,
M0 14
M014
M014
^M014
! M0 14
M014
M014
M0 14
M014
M014
M014
M014
JM014
M014
M014
M014
M014
M019
M014
M014
M014
M014
M014
M0 14
M014
M014
M014
M014
M014
M014
M014
M014
M014
M014
M013
M013
M014
M014
M014
M014
M014
M014
M014
M014
M014
M014
M014
M014
M014
M014
5.
5
..- ' S
4
4
4
3
3
3
3.
, 3
2
2
2
2
' 2
1
1
,1
1
1
, 1
1
0
0
0
0
0
0
0
o
0
0
, 0
- '
.
'
-
'. - , - .
, *
1
.
. -
- -
.
. .
2
1
8
' " 2
1
2
1
1
0
177
2
1
0
. .
1
2
1
1
.'
0
0
0
0
0
0
0
0
0
0
2
0
0
0
0
1,609
146
3
- -
-
-
-'
'
4»
-- '
,.
.-
-
* .
/
-------
Non Commercial Metal Recovery Systems and Capacities
(Basis: 1993 BRS-Form PS)
COD082657420 SCHLAGE LOCK COMPANY :M014
CTD018695999 AEROSPACE METALS M0 14
DED002337806 NVF COMPANY ,M014
KSD1 16030909 COLT TECHNOLOGY CORPORATION M0 14
MAD001032358 GLOBE NEWSPAPER CO. M0 14
MID0471 53077 PRODUCTION PLATED PLASTICS INCORPORATEIJM014
MND006159149 THE JOHN ROBERTS COMPANY ;M014
MND006258115 JAPS-OLSON CO. JM014
MND985667807 ADVANCED FLEX, INC. - PLANT 2
NED007281728 LINCOLN PLATING COMPANY
M014
M014
NED986387041 SUPRA COLOR LABS INCORPORATED M014
NYD986875326 HERAEUS PMR M014
PAD005031497 AMERICAN TINNING & GALVANIZING CO M014
PAD014299523 WEINSTOCK CONESTOGA INC ,M014
PAD987377504 INTERNATIONAL ENVELOPE CO JM014
VTDO0 1075 886 MERIDEN STINEHOUR PRESS iMOU
ALD000826958 AUBURN UNIVERSITY . M019
CAD009584210 CALIF INSTITUTE OF TECHNOLOGY
CAD9823241S4 COMPOSITE STRUCTURES
M019
M019
CTD002S92020 BEAVER BROOK CIRCUITS INC. M0 19
CTD023869423 COMPONENTS TECHNOLOGIES, INC
CTD099762015 INTER MAGNETICS GENERAL CORP
CT0572826873 CT ARMY NATIONAL GUARD BRADLEY BASE
DED003930799 E.I. DUPONT CHESTNUT RUN
MIT270012198 GRAND HAVEN BRASS FOUNDRY
MND985668227 PRECISION DIVERSIFIED IND. INC.
GU91 70090022 USNAVY NAVAL HOSPITAL COMPLEX
KSD007237241 BOEING COMPANY, THE
M019
M019
M019
M019
M019
M019
M014
M0 14
TOTAL QUANTITY FOR NON-COMMERCIAL FACILITIES
«
.
n
: ^
~ af
!
14
.
6
- 5
- !
.
-
- 39
t ' . -
\.
-
,
-
.
-
-
-
-
m
m
m
2,361,290
1
.
.
0
,
' -
., »
*
'1
1
- T
*
1,150,491
Pages
-------
HAZMAT
Chemical fixatio
options for haza
waste treatment
i increases
dous
HE HAZARDOUS AND SOLID WASTE AMENDMENTS (HS\
to the Resource Conservation and Recovery Act (RGRA) gov-
ern the manner in which hazardous materials are managed.
Disposing RCRA hazardous wastes on or in the land is 10
longer an accepted remedial option. This land disposal resti ic-
tion requires diat all listed and characteristic hazardous wastes (as defir ed
by RCRA) must be treated according to specified standards before tt ey
are disposed [40 CFR 268.40]. These treatment standards define tec h-
nologies and concentration limits. Hazardous wastes that do not meet t he
standards are prohibited from being disposed on land, such as in landfi Is.
surface impoundments, land treatment units, injection wells; and mil es
The Environmental Protection Agei cy
(EPA) permits land disposal of some hazardous
waste streams provided die toxicity or mobil in-
of die specific hazardous constituents has bx en
reduced to required treatment standard c< n-
centrations. Such is the case with hazard< us
wastes exhibiting toxicity characteristics (T< Is)
as identified in 40 CFR 261.24. Specifically,
wastes contaminated with arsenic barium, c id-
tnhim, chromium, lead, mercury, selenium and
silver known as the RCRA metals fall
under the standard.
Given these TC concentration limits, E 'A
gives generators the ability to choose from & v-
' eral treatment technologies. The standard to
, which the effectiveness of other treatment tet h-
nologies for a specific waste is composed is caled
the best demonstrated available technology.
or caves.
Bv GREGORY J.
INDELICATO
AND GARY A,
TIPTOX
20
May 1996
Remedial options. Treatment generally is
the only option for metal-containing listed wastes
and wastes that include any RCRA metals in con-
centrations exceeding the TC treatment stan-
dard. There are several non-treatment methods;
however, their applicability is limited. These
include:
RecLissifatimcf the material, filltm-fd by dis-.
posaL This involves obtaining a variance to clas-
sify the waste as hazardous and dispose it as
non-hazardous. Although ^classification is an
' inexpensive alternative, it is being phased out as
variances expire and are not renewed.
Disposal in a permitted hazardous Tcaxe facil-
ity. The waste is transported as hazardous waste
to a hazardous-waste disposal facility, where it
is treated and disposed. The advantage of mis
method is that the waste can be removed from*
the site quickly. However, the waste soil must.
be treated to meet pre-disposal treatment stan-
dards; in addition,' transportation, and offsite
treatment and disposal of hazardous waste can
be costly and increase the generator's risk of
exposure to liability.
Reclamation and recycling. As long as the
waste contains specific metals in concentrations
high enough for recovery, recycling is an attrac-
tive option, eliminating long-term liability and .
reducing die volume of waste generated. How-
ever, this method may not be viable if concen-
trations are not at rfireshold levels.
Thus, generators usually are forced to treat
metal-cohtaminated'waste using an accepted
treatment technology, such as solidification and
stabilization processes, thermal decomposition,
sorbents, osmotic and ion-exchange methods,
and flocculation and precipitation:
-------
Solidification/stabilization. This com-
mon process treats waste by physically or chenv-
ically immobilizing the constituents, diminishing
medr effective mobility and toxidty. Many solid-
ification and stabilizadon processes use cement-
ing or encapsulation to immobilize
contaminants. A variety of materialssuch as
Portland cement and other calcium-based
cements, silicates and other siliceous materials,
and even asphalrics and waxess are used as
binders to stabilize die metals, or surround or .
incorporate die metals in a matrix
In cement-based approaches, wastes are
mixed directly with cement or similar setting
materials; die metals then are incorporated and
bound in me cement The pH increases as die
cement cures, and most multivalent cations are
converted into insoluble hydroxides or carbon-.
ates. However, metal hydroxides and carbon-
ates are insoluble only over a narrow pH range;
as die curing process continues and pH increases,
die solubility of these metal compounds will
increase as well
Anodier approach is to add a siliceous mate-
rial with lime, cement, gypsum and other suit-
able setting agents. Siliceous material includes
fly ash, blast furnace slag, and calcium, sodium
or potassium silicates- Pordand cement and lime
are the most commonly used setting agents.
Under proper conditions, a reaction will take
place between die silica-rich material and die
polyvalent metal ions, yielding a wealdy bonded
metal-silica material.
Various materials generally present in typi-
cal waste streams can inhibit die effectiveness of
solidification/stabilization; these materials include
sulfates, organics (oil and solvents, for example)
and many of the metals being treated. The mate-
rials prevent or retard die curing process, reduc-
ing die strength and durability of die treated
waste and increasing die susceptibility for leach-
. ing of die contaminants.
Treated wastes also are highly susceptible to
changing chemical conditions, such as lower pH.
Simple cemented wastes are subject to leaching
'in die presence of even mildly acidic solutions -
such as rainwater, thereby rendering the process
ineffective for immobilizing die metals. As die
matrix breaks down, die encapsulated material
will begin to leach. Similarly, die matrix, if not
Copper
Uad
HfEfeM
.Sdiilam
KflteiVohinw.liicreasB ms less
processed properly, can retain a large amount of.
water that is not chemically bound. This can
structurally weaken the final product, making it
susceptible to leaching. Over time, the water will
migrate out of die treated waste material and. in
the process, leach but die metals.
Orner solidification processes vary in applic-
ability and effectiveness. Many of die diermo-
plastic processes such as asphaltic, bitumen
and paraffin-based methods are cosdy and
have limited compatibility with many waste
streams.
These methodologies are enhanced if die
contaminants can be chemically stabilized or
"fixed" in die'molecular structure of die solidi-
fied product. The applicability and enectiveness
of die various chemical fixation protocols avail-
able depend on die nature of die contaminants,
dieir concentrations, the matrix, other metal
interactions and interferences, and physical and
chemical parameters. These factors must be
understood fully to maximize treatment effec-
tiveness.
Chemical fixation. Chemical fixation is a
treatment process that employs reagents
CONTINUED
-------
Fixation
designed for die specific contaminant or
, contaminants in the waste stream. Using
the pozzolanic material as a silica source.
the metal-affected waste is remineraEzed as
non-leachable metal silicates. The physic-
ochemical reaction process, which involves
hydration, sorption, molecular cross-Jink-
ing and other reactions, ultimately produces
, a monolimic, calcium-metal silicate mate-
rial wim potentially hi^i structural'strengrfi.
Chemical fixation uses predetermined
to
itarninants'
ical activity of such specific metals as cad-
mium, mercury arid arsenic may ne« d to be
stabilized or modified: mis is especc lly true
for metals that complex with organ ics.
Reacdon kinetics must be optirr ized
ensure effective fixation of the contai
in the waste stream. Several n pes of
reagents can be added to induce an d facil
itate the chemical fixation process. These
include:
Mixing agents, w-hich facilitate me dis-
persion of organics and help incoi porate
the metal(s) into the mixture;
Inhibitors, which are used
hydration reactions so the slower
complexing reactions can occur;'
to slow'
silicate
Chemical fixation of municipal incinerator ash
ASb ID8an* TfBfltDKOt
ton)
(TCtftng/Q
Field trial insults.
24-hour ean(iiig/l)
SW-A1 SW-A2
28^)ay cure (tag/I)
SW-1
ND anon-detectable
The mean was calculated (ram samples taken on six different days.
SW-A1 and SW-1: mixture of 10% fly ash, 90% bottom ash, pozzolans, reagents
SW-A2 and SW-fc mbrture of fly ash. pozzolans, reagents
treatment protocols based on the contam-
inants in .die waste stream. The protocols
specify the volumes, concentrations and
proper sequencing of proprietary reagents,
and emphasize appropriate mixing and reac-
tion times for each step. Special attention
is given to matrix interferences and inter-
actions involving metal solubility, such as
ionic strength, valence state, redox poten-
tial, pH and compering ions. It may be nec-
essary to reduce the toxicity of specific
contaminants (for example, hexavalent
chromium or cyanide) before chemical fix-
ation takes place. In other cases, .the chem-
Complexing agents, which ft cilitate
reactions between amorphous silica and the
metal contaminants; and
Accelerators, which increase the rate
of the silicate reactions as the inhibitors are
consumed*
' Series of reactions. .When properly
combined, the metals-affected wast u fixing
agents and proprietary chemicals (a; deter-
mined by the appropriate proton >1) pro-
duce a series of reactions. First, c alcium
silicates from the pozzolanic materi J begin
to decompose, releasing calcium ox ide and
silica. Then, the calcium hydroxid< is pre-
cipitated with the hydrated calciui n silica
gel'under conditions mat allow silk a com-
plexes to form.
Next, proprietary chemicals (selected
based on die contaminants prese nO are
22
Environmental Solution* May 1996
added to the waste stream, increasing the
viscosity of the mixture. This acts as an
.effective interparticule lubricant, which
accelerates the homogenization of die mix-
ture and simultaneously decelerates the dif-
fusivity of other components in the
cementation reaction.
At mis point, die calcium oxide and cal-
cium silicates hydrate while odier chemi-
cals dehydrate, generating cross-linkage
among parades and dehydrated molecules.
This helps prevent volume expansion in me
solidified mixture. In this stage, the cemen-
tation reaction begins to accelerate.
Next, the hydrated calcium silica gel and
crystals physically and chemically entrap
the contaminants within the solidified
matrix. Many of die metal components are
incorporated into die crystalline structure
through ion exchange, substitution, solid
solution and complexing processes. Some
fine inorganic particles are encapsulated
physically within the macropores and
micropores of the silicate matrix, while
some metals are absorbed on the surface of
the crystals and the particles of the fixing
agent. Contaminant entrapment and encap-
salatbn are enhanced naturally by me cage-
like structure associated with die previously
formed cross-linked molecules.
Finally, the dissolved or dispersed
organic components are physically trapped '
and encapsulated in the macropores and.
micropores of the solidified mixture matrix,
or are absorbed or chemisorbed on me sur-
faces of these pores through dipole-dipole
interaction, London-force attraction or
hydrogen bonding. Remaining components
are incorporated chemically into die matrix
duough a variety of processes, which can
include complex formation, chemical (cova-.
lent) bonding and cross-linkage formation.
The process overcomes die tendency of
organic waste components to inhibit the
cementation reaction.
The solidified mixture produced by this
process has much-greater density and
mechanical strengdi, which results in sub-
stantially lower leaching rates of the final
waste product; 28-day, unconfined com-
pressive strengths of more than 4,000
pounds per square inch (psi) have been
achieved in some treated organic sludges,
wim as much as 12,000 psi in non-organic
' CONTINUED
-------
Fixation
materials. Characteristically, an increase in
the density of a solid indicates diminished
permeability, eliminating any substantial
mobility of hazardous components within
the solidified waste. The increased mechan-
ical strength also minimizes the generation
of additional surfaces from micro- and
macro-fissures resulting from structural 63-
ure. Water penetration and the subsequent
transport of soluble metals constituents are,
therefore, minimized.
Chemical fixation advantages.
There are distinct advantages in using this
proprietary chemical fixation process:
It can be used to treat a wide range of
waste streams; .
There is minimal increase in the vol-
ume of the treated waste; and
, The process is relatively inexpensive.
Unlike many conventional solidification
processes, chemical fixation can treat a wide
range of waste streams, including complex,
multicontaminant inorganic wastes and the
typically hard-to-treat, organically contam-
inated wastes. Waste streams treated suc-
cessfully by this process include soils
contaminated by heavy metals, organically
contaminated soils, electroplating sludges,
paint-sludge wastes, sandblasting grit cont-
aminated by heavy metals, API separator oik
and sludges, petroleum tank bottoms, wastes
containing polychtorinaiEd biphenyis (POSs),'
asbestos wastes, and incineration ash.
Con.fi.denceV/ a: faith or belief that
one win act in a right, proper, or
effective way...
AVHw/«\s \inih .Vtvr Collegiate l)i>
Wouldn't you like to have
confidence in your hazardous
waste management company?
LWD customers can sleep well at night,'with
confidence in our:
MGXII
RCRA Incineration
FieldServices -
LWD INC
Trucking
Landfill'
That's Confidence.
That's LW.
P.O.Eox527
Calvenaty,Sf4m
50289*813
24
VISIT BOOTH #355 AT HAZMATINPL
CMS No. 325 en Reader Service Cart
Environmental Salutlonc . May 1996
CMe No. 329 on Reader Service Card
-------
\
{
Mix formulations can be modified to
oommodate specific waste streams so that
the waste takes an active role in the cemen-
tation phase of stabilization. Some wastes"
even function as chemical reagents, assist-
ing in their own stabilization by contribut-
ing to physical hardening, (hereby reducing
or eliminating permeation and leaching
Chemical fixation can treat a wide range of waste
streams, including nndtteODtaninant inorpdc
and ftanl-to-Jreal organic wastes, at relatively
I volume increase. .
concerns. Also, by altering me design of me
mix, processed waste can be poured as a
plastic solid similar to concrete and cast into
blocks, super sacks, rolloff boxes and other
forms suitable for disposal. The processed
waste also can be stabilized into a final state
with a soil-type texture. In either forr i, low
solubility reduces the potential for lea dung,
to a negligible degree. The resulting o eated
waste yields analytical results below ] LPA's
TC leaching procedures.
Typical solidification/stabiliz mon
processes add cement to the micture,
increasing the volume of die waste. C hem-
ical fixation limits vc lume
expansion of the resultant
waste material. Becaiu e dis-
posal charges at most land-
fills are based on volinr e, this
translates into significai it sav-
ings. In one test, a 65 -per-
cent organic oily waste
sludge that was solidified
showed an increase i: i vol-
,ume of less than 50 percent In anodu r test,
soil containing PCBs at 30 pans pe mil-
lion was treated with chemical fixarior, with
a resulting 15-percent volume redi ction
and a 28-day compressive strength of 3,250
psi. When compared to die costs for treat-
ment and disposal of hazardous waste, treat-
ment processes and subsequent disposal of
non-hazardous waste is significantly less
expensive.
Chemical fixation can be customized for
a facility's specific hazardous waste treat-
ment and disposal program. Years of devel-
opment and application has resulted in an
extensive data base of treatment reactions
for metal-contaminated wastes. More than
700 waste streams have been evaluated and
successfully treated. More than 400 waste
streams have been treated successfully in
bench-scale testing, and more than 100
waste streams have been treated in field
applications. ' D
i- '' * - '
GngayJ. Indelicate is jnanagcr of emer-
gency and remediation services far CURA Inc.
(Dallas), Gary A. Upton isan environmental
further information on the chemical fixation
process can contact biddxan at 800/486-7117,
ext.220.
Instant
Holding
Tanks
spflldeaiHip
' 100 lo 100,000 gallon copadties
'Folly collapsible & portable.
> Used by (I.S. Army, Navy, Marines etc.
JWfBSEWTMt HAZMATTDOl
IN STOCK FOR FAST EM£MEHCr SMCE
Also TK Utounun, Int.
Spc&f Ron Ifldmbiol Pone
Ramsey, HJ07W-1251 USA
ftonc 201-125-1400
CUde No. 30S on Reader Senioa Cart}
Dewatering
Reaction
OS
<5% to >95%
Patented
Technology
Oil Spill
Clean-up
SEE US At HAZMATINTL BOOTH #351
CMBNaaOBonReacterSeniaeCaiti .
Envtrancmntal Solution* May 1996 25
-------
-------
Appendix C-3
FROM: Stephen Schwartz
SUBJECT:
Wade
to
Hazardous Was
\ Stabilize 0008 and Other
commercial
13 May 96
all Underlying Hazardous t**~+i+«-Z*.r^3L
Regions
tal
to
to
wastes to
2SW«W°f? ^c^icany, i
*t£bilization technoi««i *i
including
detail, .or their
vaa«u, or
they didn't
producing
qu««tion to ail
.
b*li«v«d
**»
the
, but
teeataent. Storage,
5 and s
(UHCS)
could
ine contacts, including the
country
which actually performed
or *^ to one
on
stabilize wastes, one is
_' received such waste they
- 1°";! of tha ^^ <5i«i not
" buuc solids, but mostly
0008
to **«»>iliz« the vast.
. incl°din9 «» lead
-------
OF
CONTACT
/0/riAy
1 -
Do you receive nen-vastewat«r vastas froa brms«/brenzo
foundries? Do you ree«iv« siailsr wastes? If similar, vhy
ar« they slaila*? ^ . _. _ _^f ,
Typical foundry vaata contact fine sand particles
eoxitaminated vitti a few percent load, zinc, copper.
2 -
If so, do you stabilize those wastes witH pozzolonic-tyge
stabilizing agents? -
- if so, what tjpical mix of water/stabilizer/waste do you use?
5- would you forsee problems in treating these
.levels? '
to
-------
COH1ACT PERSON:
l - ,Do you receive sea-vastevater
foundries? Do yea receive
are they similar?
Typical foundry waste
contaminated vith a fev pea
siaUar wastes?
^.THScYi
2 -
If so, do you stabilize those
stabilizing agents?
fi
3 -
so, what typical nix ,of water/stabilizer/waste do you use?
4-
int lead, zinc, capp«r
wastes with pozzolonic-type
To what: TCLP levels are you able to stabilize the BDAT/TC
metals? CAN WE ffiVTS D&X& I*OR USTSE&IED/T5E%X£D HZTMt
COKSTITOSITS?
Would you forsae problems in trmatiiKj th«se wastes to TC/UT3
lavals? -
-------
~MAlffi/ADDSESS/PHOSB OP
CONTACT PERSON:
(W
1 - DOX
w
raeaiva
.
Typical £oo&d£7 vasts con*'*'*^ fln«
contaminated witH a f«r parent i*a«,
2 -
3 - If so, vhat typical mix of vatar/stabilixer/vasta
do yea
4-
££^£%££J^ « W«BV«W »£
S" Iwiis?* *°"** S*0^1*" ta tr«»tlB» tlum taotM to ic/OTS
-------
op FISH:
1 -
siiiilar
Do you receive
foundries? Do you
are they similar?
Typical foundry waste .._ r
contaminated with a few percent lead, zinc, copper
2 -
If. so, do you stabilize those'wastes with pozzolonic-type
stabilizing
fc »
vastos fran bxmss/broaz*
If siailar, why
contains fiat sand particles
3 - If so, what tjpieal mix of water/stabilizer/waste do you
4- TO vhat TOP levels are you
metals? OUT WE H&7E
CONSTITUENTS?
able to stabilize the BOAT/TC
FOA DNTBS&TED/TS2MSJ
5- Would you foxsee probl
lavals? '
in treating these wastes to TC/X2TS
^torstQ T W
-------
../AMMCIUS/PHONE OF F33ZM;
/ t'
CONTACT PERSOH:
1 -
Do you receive aoa-vastewater wastes from brass/bronze
foundries? Do you receive siailar wastes? If siailar, why
are they siailar?
Typical foundry waste contains fine sand particles
, contaminated with a fev percent lead, zinc, copper.
2 - If so, do you stabilize those wastes with pozzolonic-typi
stabilizing agents?
3 - If so, what typical mix of water/stabilizer/waste do you us«?
4-
to what TCLP levels are you able to stabilize the BDAT/TC
netals? C3VH RE BX7E D&Uk FOR DNTHZAUO/TREaTED METAL
s-
Would you forsee probleas ia treating these wastes to TC/urs
levels? -.*',''' . " '
-------
COHTACT
1 -
Do you receive &oa-vastewater waste*
foundries? ap y<« rtctive siallai
they similar?
T^P^l fooidry waste eoBtiias
contanlaatad with a f«v perceit
2 -
I* so, do you stabilize those
stabilizing agents? y *
vastes with pozzolonic-type
3 - If so, what typical aix of vater/stabilizer/waste do
4-
To what - TOP levels are you able
.aetals? C3kH WE EK7S, CM3L FOR
S-
f ors**
you tisa?
to stabilize, the 8DAT/TC
METAI.
treating these wastes to TC/TJTS
-------
OF FXRHS
CQSTACT PHJSOH: A /
- Do you »
OWE: i. _.- 1
10 <*Aw^
2
3 - If so, what typical mix of vator/stabilizmr/vasta do yoa us«?
4- To rtiat TCI» l«v«l» ax« you able to stabilize th*
HEttL
fors*« problam* in treating thaa« vastas to
-------
1 -
2 -
4 .-
S -
7 -.
8 -
FACZCXXXZ9
ASP DISPOSAL
<3NX Group (Disposal sy*t
P.O. Box 1914
Deer Par*, T3C 77536
s
Mr. Farran Horris - 713/930-25
clean Barbers of Chicago
11800 Stonay island Avenue
Chicago, IL 60617
Mr. tin Getzloff - 312/646-6202
AETS/Chamical Waste Management
W124 H9451 Boundary Read
Menomonee Falls, Wl 53051
"
Mr. Alan Xoumtz -,414/255-6655
Heritage Environmental Services
7901 W. Morris Street
Indianapolis, IN 46231
MS. Darey Ray - 317/243^8811 e^ct. 1483
Envirite Corp. '
16435 S. Canter Avenue
Harvey, IL 60426 .
Mr. David Reyes -. 708/596-7040
6 - Rollins Environaantal s«rvices
P.p. Box 73877
Baton Reugar LA 74137
Pred Gurdass - 302/426*3168 6
Richard Crondan - 970/386-2293
Chemical Waste Management
7170 John Brannon Road
caxlyss, LA 70663
»-
Ms. Ranea Dillion* - 318/583-21<>9
(LA), Inc.
(Colorado facility)
Traataaht Ona
5743 Chesvood
Houston, TZ 77087
2169
Ms. Shiela Arastrong - 502/327-
THEZ DO HOT HANDLE BULK SOLIDS,
WASTES. -
8860 (Louisville, KY facility)
ISCL. FOtlHDR? SATO
-------
P.O., BOX 709
Texas city, a 77532
Ms. Tracy Holistar - 409/943-3301
NONWASTEHAXERS.
WOUXO SU8COOTP*
-------
, , . APPENDIX D
DATA ON AVAILABLE VITRIFICAtlON CAPACITY
This appendix has two sections:
D-l: Provides a phone log of vitrification facilities and vendors
D-2:. Describes the vitrification technology, its applicability, limitations/constraints, and
availability/costs. . ' '
the Agency contacted.
-------
-------
PHONE LOGS OF VITRIFICATION FACILITIES
Mr. Matt Haas
Geosafe Corporation
Location: Richland, WA
Phone:509-375-0710
Interview conducted by: Gail Shaw
Date of interview: March 7,1997
Date of follow-up interview: April 11,1997
Mr. Haas believes that their facility may be the only
currently have one system operating which has an available
facility can readily expand its operations to three systems i
current maximum capacity would be 45,000 tons/year.
supplier of in-situ vitrification. They
capacity of 15,000 tons/year. The
demand arises. Therefore, their
if the
i Mr. Doug Rosholt
MSE Technology Applications
Location: Butte, MT '
Phone:406-494-7100 ^
Interview conducted by: Gail Shaw
Date of interview: March 7,1997
Date of follow-up interview: April 11,1997
V . '
Mr. Rosholt responded that their commercial facility supplies plasma vitrification. The
Unit's available capacity is 2,000 tons/year; that is also theii maximum capacity.
Ms. Yvonne Eglanton
Vortech Corporation,
Location: Collegeville, PA ,
Phone:610-489-2255
Interview conducted by: Gail Shaw
Date of interview: March 7,1997
/
* '*
Ms. Eglanton responded that their corporation is a'vendor of vitrification technology
. equipment.
-------
Mn Matt Mede
Retech
Location: Ukiah, CA
Phone:707-462-6522
Interview conducted by: Gail Shaw
Date of interview: March 7,1997 .
Mr, Mede responded that their corporation is a vendor of vitrification technology
equipment. .
-------
Appendix D-2
ATTACHMENT TO MEMORANDUM FRdM
TO ICF INCORPORATED,- MARCH
Vitrification
l'. Process Description
BILL KLINE (U.S. EPA)
17,1994
Vitrification is the process by whilch contaminated soils a*»
converted into chemically inert and stable glass and crystalline
materials by a thermal treatment process operating at a
temperature of 2000 degrees F to 2800 degrees F. This technology
is primarily intended for the treatment of heavy metals; however,
an organics content of up to 20% can be handled. A high current
of electricity is passed through electrcdes inserted into the
contaminated soil. The heat causes a melt that gradually works
downward through the soil, organic constituents are destroyed
while the inorganic contaminants are immobilized in the high
compressive strength glass-like or ceramic end product. A volume
reduction of 20% to 45% is achieved. 'Types of vitrification
processes include glass-melting furnace!r, h±trti-trempe"raTnre fluirfr-
wall reactors. .
s ' , \
, "* " N x
2 * W3tS wQ
Vitrification was originally tested as a means of
immobilizing low level radioactive metals. However, it can be
applied to a wide range of contaminantsL The process destroys
nitrates and partially 'decomposes sulfate compounds. Fluoride
and chlorine compounds are dissolved into the glass materials up
to their .limits of solubility. .Wastes containing heavy metals,
PCBs, for example, will either fuse or
3 . Lint it at ions/Constraint s
vaporize.
Vitrification processes are very energy intensive (800-1000
kw/ton), requiring temperatures up to 2500 degrees F for'fusion
and melting of the waste-silicate matrix. Commercial waste
management companies may not have built vitrification processes
because: vitrification is only specified as BOAT for a few
relatively small-volume hazardous wastes, there is little,if any
operating experience with the process, and RCRA permitting
officials have essentially no experience with this process.
Total organic concentrations are limited to 20% by weight. Also,
inorganic, debris is limited to a maximum of 20% by volume.
4. Availabilitv/Capacitv/Costa
" At this time, vitrification processes have riot been widely
accepted. As mentioned above, this may be due to the high
operation costs, technical complexity af the process, and
difficulty in obtaining permits. The cost of this process can go
up to $1000 per ton, with an average cost in the range of $400-
$600 per ton of soil. The following companies* are believed to
provide vitrification processes: .
1. B&w Nuclear Environmental Services, Inc.; pilot-scale
-------
unit: 200 Ib/hour
2. DOE/Battelle Memorial Institute's Pacific Northwest
Laboratory; pilot scale; 3 units constructed, 6 other
units planned: 10-25 tons/day
3. Electro-Pyrolysis, Inc.: pilot-scale unit: 100-500 /
Ib./hour .',""
4. , EM&C Engineering Assoc.; bench-scale; hoped to go full-
scale in 1993 _ -
5. Geosafe Corp.; full-scale unit: 4'-6 tons/hour; i unit
constructed, 1 other unit planned.
6. J.M. Huber Corp.
7. Penberthy Electromelt International, Inc.
8. Pyrogenics, Inc.
9. Stir-Melter, Inc.(subsidiary of Glasstech, IncO; full-
scale unit: 2 tons/hour
10. Texaco Syngas, Inc.; full-scale unit: 2-4 tons/hour
11. Thagard Research .Corp.
12. Western Product Recovery Group, Inc.: full-scale unit:
600-1000 Ib./hour; 1 planned unit . , '
13. Vortec Corp.: pilot-scale unit: 20 tons/day
14. ' Vulcan Resources, Ltd.
15. Westinghouse Electric Corp. ^ . ...
* NOTE: Many of the above-mentioned bench-scale/pilot-scale
systems for each of the treatment technologies were reported as
being such nearly a year ago. Thus,.it is quite feasible that at
least some of these systems are now commercially available as
full-scale systems. -...'.
-------
APPENDIX E "
COMMENTER DATk
-------
-------
EXHIBIT E-l
COMMENTS SUBMITTED IN RESPONSE TO THE ANPRM
Commenter
Koppers Industries, Inc.
Vulcan Chemicals
American Wood
Preserving Institute ,
James Graham Brown
Foundation
Beazer East
Hazardous Waste '
Treatment Council
Beazer East
(Second Comment)
Issues Addressed
F032/34 wastewaters are usually
discharged to POTWs.
F032 wastes may be difficult to 1
because of dioxins.
Wood preserving waste generati
and management.
The number of wood preserving
plants has declined.
F035 wastewaters are recycled ii
process. .
Remedial actions at former woo<
preserving plants owned by the
foundation.
Remedial actions at wood preset
sites.; . '
. Incineration capacity will be
overwhelmed by contaminated s
F032 wastes may "contain dioxin
be very difficult to treat.
Impact of LDRs on closed wood
preserving sites.
F032 wastes" may contain dioxin
be very difficult to treat.
Biotreatment for wood preservir
soils is currently prohibited as h
disposal.
'
reat
>n
i
1
ving
oil.
sand
sand"
g
hd
.Data Submitted
None.
None.
None. - '
One site has 8,000 cubic yards
of contaminated soil.
At 31 wood preserving sites,
2,180,800 cubic yards of
contaminated soil was
removed.
The entire wood preserving
.universe could generate '
85,300,000 cubic yards of
contaminated soil through
remedial actions.
None.
One remedial site in Montana
has 75,000 cubic yards of
contaminated soil and rock. .
-------
-------
EXHIBIT E-2
COMMENTS TO THE PHASE IV PROPOSED RU
,E (60 FR 43654. May 10.1996)
Comment Number
1
2
3
.4
5
6
7 ,
8
9
10
11
12
13
14 ,
15 -
16
17 .
18
19
20
,21
22
23 ,
24 .
25'
26
27 . . "
28
29
30 .
31 '-..'.
32
33
34
35
36 ' , .
37 ....
38 -
39 -
Commenter Name
Grady-White Boats
Olympic Boat Company
Sunfish Laser
Larson Boats .
Arctco Inc.
Regal Marine Industries
Godfrey Marine
Florida Department of En\
National Marine Manufact
Coalition on West Valley ]
Blue Water Boats, Inc.
Coastal Corporation
New York State Departme
Silver Coalition
BPOil
Universal Forest Products
Eastman Kodak
Mobil Oil Corporation
ASARCO Incorporated
Exxon Company, USA .
Georgia-Pacific Corporati
Phelps Dodge Corporation
Beazer East, Inc.
Union Camp Corporation
Magma Copper Company
The TDJ Group
Rollins Environmental
Texas Utilities Services, Ii
The Acrylonitrile Group, '.
National Petroleum Refin<
Department of Energy
Penta Task Force
Carbon Disulfide Panel/C
Association
Underground Injection Cc
Manufacturers Associatio
Utility Solid Waste Activ
Institute, American Publk
Rural Electric Cooperativ
American Iron and Steel
Natural Gas Pipeline Con
,
, .
\ .
ironmental Protection
irers Association
Nuclear Wastes
it of Environmental Conservation
.
.'
^
" v '" ,
>n
s >
c. -
nc.
rs Association
'
lemical Manufacturers
ntrol Task Group/Chemical
i. -. '
ties Group, Edison Electric
Power Association, National .
: Association . ,
istitute .
pany . .- '
Association of Battery Relcyclers "
American Wood Preservers Institute
-------
EXHIBIT E-2
COMMENTS TO THE PHASE IV PROPOSED RULE (60 FR 43654; May 10,1996)
Comment Number
40
41
42
43
44
,45 -
46
47
48
49
50
51
52 . - '
53 .;
54
55 " -
56 «.-
57
58 ' .
59
60
61
62
63
64
65
66
67
68 '
69.
70
71 .
72
73
74 .
75
76 -
77"
78
79 - ,
80
81
82
Commenter Name
Interstate Natural Gas Association of America
Sterling Chemicals
Monsanto -
Lead Industries Association, Inc.
American Forest and Paper Association -
Battery Council International
National Mining Association
Merck & Co., Inc.
ChemicalWaste Management, Inc.
Molten Metal Technology
Natural Gas Pipeline Companyjsf America (Identical to 37)
State of Ohio Environmental Protection Agency
Pacific Gas and-EIectric Company
Texaco ..-.
Total Petroleum, Inc.
American Industrial Health Council
Westinghouse Electric Corporation ,
Richard L. Anderson
J.H. Baxter and Co.
Exxon Chemical Americas
American Dental Association
BP Chemicals
Remediation Technologies, Inc.
Laidlaw Environmental Services
Dow Chemical Company
Safety-Kleen Corporation ,
American Petroleum Institute :
Horsehead Resource Development.Company, Inc. and Zinc
Corporation of America
Amerada Hess Corporation
Steel Structures Painting Council "
Doe Run Resources Corporation
Synthetic Organic Chemical Manufacturers Association
Non-ferrous Founders' Society
Outboard Marine Corporation
Department of Defense
Elf Atochem North America, Inc. . 7
The Society of the Plastics Industry, Inc.
American Foundrymen's Society , .
Battery Council International
The Society of the Plastics Industry, Inc. (Identical to 76)
Eastman Chemical Company
Rohm & Haas Company
Brush Wellman, Inc. ' '
-------
EXHIBIT E-2
COMMENTS TO THE PHASE IV PROPOSED RUHE (60 FR 43654. May 10,1996)
Comment Number
83
84'
85
86
87
88
89
90
91
92
93
94
95
96,
97 .
98
99
100 '
101
102
103 '
104 .
105
106
107
108
109
110
111
112 ...
113
114
115
116
117
118
119
L001
L002.
LXXX
Commenter Name
Steel Manufacturers Associ
Specialty Steel Industry of
Environmental Defense Fur
American Gas Association
Doe Run Resources Corpor
Texas Utilities Services, In(
Hazardous Waste Implemer
Association of State and Te
Management Officials
The Cadmium Council
FMC Corporation
Union Carbide Corporation
Heritage Environmental Sei
General Motors Corporatioi
General Electric Company'
International Metals Reclan
Hazardous Waste Managerr
New York State Departmen
(Identical to 13)
State of Ohio Environments
51)
Phillips Petroleum Compan
Oregon Department of Env
Chevron -
Giba-Geigy Corporation
Specialty Steel Industry of '.
Steel Manufacturers Associ
ition
forth America
d '
ition (Identical to 70)
. (Identical to 28)
tation Task Force of the
rritorial Solid Waste
'
vices, Inc.
i .
i
lation Company, Inc.
lent Association (HWMA)
t of Environmental Conservation
1 Protection Agency (Identicalto
jy.
ronmental Quality
'forth America (Identical to 84)
ation (Identical to 83)
Pharmaceutical Research aijid- Manufacturers of America
Uniroyal Chemical Company
S2 Yachts
Ford Motor Company
American Foundrymen's Sc
Specialty Steel Industry of
Steel Manufacturers Associ
Chemical Manufacturers A
1 Gradient Corporation
Courtaulds Fibers
Occidental Chemical Comp
Boston Whaler
FMC Corporation
Rohm and Haas Company
University of Rochester -
Distilled Spirits Council of
-FMC Corporation
-
ciety '
forth America
ation
ssociation
> '
any (OxyChem) .
t . . ' .
The United States
-------
EXHIBIT E-2
COMMENTS TO THE PHASE IV PROPOSED RULE (60 FR 43654, May 10,1996)
1 Comment Number
LXXX
Commenter Name
I
Penta Task Force , |
-------
EXHIBIT E-3
COMMENTS
NOTICE OF DATA AVAILABILITY
i TO THE PHASE IV PROPOSED
RULE
(61 FR 21418)
Comment Number
Nl
"N2 . -
N3
N4 -
N5- ' '
N6
N7
N8
N9-
N10
Nil
N12
N13
N14, ' -
N15 -
N16 .
N17
N18
N19
N20 . -
N21
Comment Name
Environmental Technologies In
Battery Council International ai
Vulcan Chemicals (Penta Task
Eastman Kodak Company
National Mining Association
RSR Corporation ' :
The Silver Council
Battery Council International ai
Dow Chemical Company
Environmental Defense Fund
Vinyl Institute
Beazer East, Inc. -
Georgia Dept. of Natural Resoi
Environmental Technology Co
Cement Kiln Recycling Coaliti
DuPont Engineering
FMC Corporation
Chemical Waste Management,
Rollins Environmental, Inc.
CONDEA Vista Company '
J.H. Baxter & Company, ;
ternational, Inc. .
id Association of Battery Recyclers
Force) .
*
id Association of Battery Recyclers
. ,
.
'
rces ..
uncil
on .
Inc.
-------
-------
Appendix F
COMMUNICATION LOGS
-------
-------
MEMORANDUM
DATE: February 19, 1997v
TO: Docket .'
FROM: . C. Pan Lee, OSW/HWMMD/AIB
SUBJECT: Phone Conversation with Steve Ladrier of Kerr-lflcGee (405/270-2625)
Mr. Steve Ladner has great concern on capacity determination
with F034. He represents a wood treating company, Kerr-McGee
Oklahoma City, Oklahoma.
Mr. Ladner noted that his company has seven facilities and been
years. He added that 5 out of 7 sites used to use surface i
but the facilities excavated and closed all Si's ten to twelve years
still have big areas contaminated witlvF034 surrounding these cl
migration of contaminants. His company had provided comments
(AWPI) who submitted its comment (P42A-0039) in response to
(published August 22, 1995).
status about soil and debris contaminated
arid is from its headquarters at
in wood treating business for 80 to 90
impounc ments (SI) for processing wastewater ^
ago. He emphasizes that these sites
>sed Si's due to possible extensive
to American Wood Preservers Institute
the LDR Phase IV proposed rule
/
Its seven operating wood treating facilities are around residential areas and located in the following
places: ' , . . , . '
(1) Madison, Illinois, .
(2) Indianapolis, Indiana, * ' " .
(3) Columbus, Mississippi, . ;
(4) Springfield, Missouri, ^
(5) Dalles, Oregon, - . , , ,
(6) Avoca, Pennsylvania, and
(7) Texarkana, Texas. - . -
None of them are Superfund sites, but 4 out of 7 facilities are um ler various stages of corrective action
process with on-going investigation phase as minimum. Mr. Lac ner noted that the sites are in different
planning stages, for example, Regions/states are in the process o
reviewing some corrective action plan
(CAP) and the facilities have no control on clean-up levels for c< >ntaminants and time table of clean-up
approved by EPA or states. He added that quite extensive contaminated areas really make sites clean-up
difficult. Mr. Ladner is aware that a CAMU allows an area of a facility to be remediated without ',.
triggering LDR standards if the remediated material is placed back into the area, but asserted that also
there is existing legal interpretation issue of whether the contaminated areas are definitely designated as a
big CAMU. He would guess'at least a few thousands tons of hazardous soil and debris could be
generated if excavated for disposal due to the immediate effective date of the LDR standards. The sites
would have to plan very differently to comply with regulatory requirements with immediate effective
date or with a delayed effective date to the Phase IV LDR stand* rds. He indicated that it can cost about
$500/ton to cover landfllling, transportation, and other miscellaneous expenses if the sites have to ship
contaminated soil and debris for off-site disposal and four or fivi 5 times more for incineration.
-------
DATE: ' January 16,1997 ' . . ^
SUBJECT: Phone Log with Jim Brown re: NODA Comment Letter (P42A-00013)
* s
.FROM: C. Pan Lee, Staff, OSW/HWMMD/AIB
> ' ' s
TO:' Docket ' % ...
Mr. Jim Brown (Technical staff, Environmental Protection Division (EPD), Georgia Department of
Natural Resources; phone: 404/657-8600) has provided me with some detailed information regarding the
quantity and wood preserving wastes mentioned in EPD's comment letter (P42A-00013) in response to
Notice of Data Availability for LDR Phase IV Proposed Rule (61 FR 21418; May 10,1996).
Mr. Brown'noted that EPD has been negotiating contracts for removal of soil contaminated with wood
preserving wastes (F032, F034 and/or F035) or has ongoing Superfund cleanup activities in coordination
with EPA Region IV for six abandoned wood treating facilities in the next two years. He provided the
following information: ..
(l)Escambia site, Brunswick, Georgia: ,
Excavate about 100,000 tons of soil contaminated with F032 and F034 mixture from spill at storage, .
production and drippage areas. Of the 100,000 tons of soil contaminated with F032 and F034,30,000,
tons had been removed and the rest will be removed within next two years or so.
This site has closed two surface impoundments (S.I.) which was used to treat F035 wastewater. Mr.
Brown added that the excavated soil contaminated with F035 from the impoundments is currently stored
in another cell and amounts to about 20,000 tons. The 20,000 tons of contaminated soil will be removed >
within next two years. ' . .
Besides a lot of volatile creosote compounds in the contaminated soil (to be conservative, also identified
as F034), the concentration levels of other contaminants in the hazardous soil are as follows:.
pentachlorophenol 8 ing/kg (passed TCLP and therefore, not D037 wastes)
arsenic 170 mg/kg in total composition (TCLP: 0.25 mg/1)'
chromium - 190 mg/kg in totalcomposition (TCLP: 0.19 mg/1)
(2) .Of the 12,000 tons of soil contaminated with F032, F034 and F035 mixture in another site, Mr.
Brown noted that EPD has removed around 10,000 tons. ' .
(3) The rest of contaminated soil are under contract negotiation for its excavation and removal.
In summary, Mr. Brown confirmed that about 130,000 tons (150,000 minus 40,000 equals 110,000 tons
of soil contaminated with F032 and/or F034 plus 20,000 tons of soil contaminated with F035) in total
will be removed in next two years or so. He also noted that no KOOl-contamination in these soil and that
EPD does not want on-site treatment for contaminated soil in these sites because all six sites are around
the residential areas. . s
-------
DATE: January 10, 1997 .
SUBJECT: Phone Log on Comment Letter of Georgia Department of Natural Resources
FROM: C. Pan Lee, Staff, OSW/HWMMD/AIB
TO: , Docket -,
I called Mr. Harold Rebels (phone: 404/656-4713), Director, Environmental Protection Division (EPD),
Georgia Department of Natural Resources on January 10,19971
comment letter submitted in response to LDR Phase TV Noticf
10, 1996). His assistant, Mr. David Word, answered the phone;
noted that EPD had some characteristics information of six aban
ask technical staff of EPD to answer my questions.
gain some details regarding his
of Data Availability (61 FR 21418; May
nee Mr. Reheis was not in. Mr. Word
oned wood treating facilities and would .
-------
DATE: July 24,1996 .
SUBJECT: Meeting Summary with Members of AWPI
FROM:. C. Pan Lee, OSW/HWMMD/AIB . . > . .
TO: Docket File '
AWPI and its members came to the EPA for a-1997 Biennial Reporting meeting (the main purpose of the
meeting) in which Dave Bussard, Sara Rasmussen, Robert Buchard, Dave Levy and I of the EPA .
participated. I had asked the representatives from wood treaters for some questions at the end of their
meeting regarding wastewater management practices of wood preserving wastes, especially F032, F034,
and F035 in the LDR Phase IV. ,
Mr. Stephen Smith, Environmental Manager of Koppers, Inc. (Headquarter: Pittsburgh, PA, phoney
412/227-2677) noted that CCA plants,(which may generate F035) had no wastewater generated. He
added that three quarters of oil-borne plants (i.e., using cresol, PCP for wood preserving) used to use
surface impoundments (S.I.) in managing wastewater but now'no one use S.I. and all their facilities have
switched to use tanks or an enclosed system. Since wood preserving wastes identified as F032, F034,
and/or.F035 will be impacted by LDR Phase IV if managed in a non-MTR S.I. or other land-based units
without meeting LDR standards, Mr. Smith noted again that their facilities do not have a wastewater
management problem. He added that a couple of plants in Pennsylvania and West Virginia do send their
F-code wastewaters to Chambers Work, New Jersey (about 10 trucks per year) when generating.
-------
DATE:
January.21, 1997
SUBJECT: Phone Log with Beth Sheldrake, Region X
FROM: . C. Pan Lee, OSW/HWMMD/AIB .
TO:
Docket
Beth Sheldrake provided the following site information in relation to soil contaminated with wood
treating wastes.
'Oesers Company in Washington State was proposed as one of ^PL sites on December 23,1996. It has a
total area of 23.5 acres and has been treating wood since the late 1930's.
The wastes include discarded product, contaminated soil and debris, and possibly sludges and other
wastes from a groundwater pump and treat system.
The contaminants in the site have PCP and creosote. Dioxinjs
that total concentration of PCP could be as high as 165 ppm anc
She also mentioned that 23 gallons of discarded creosote is on t
She estimated that about 5,000 tons of soil and debris contamin
>ossibly an issue. Ms. Sheldrake noted
that.they did not run TCLP test for PCP.
he site.
ted with F032 and F034 from the most
contaminated area (hot spots including some from waste pond on the site) will be .excavated and removed
for disposal if the rule becomes effective in 90 days after the treatment standards for wood preserving
wastes in the LDR Phase*IV is promulgated. She'does not antic ipate in-situ treatment will be used for the
highly contaminated area. Also, she indicated that they definite ly: will excavate the 5,000 tons [for
treatment?-- uncertain] even though they won't know the types of remediation for this site until several
years later. - ,
-------
From: JUDISCHWARZ
To: DCCS01.DCCSPO2.LEE-CPAN
Date: 12/13/96 2:46pm , ' '
Subject:' Wood treaterLDR-need info!-Reply-Forwarded
Here is another SF wood treater cleanup site in this region. If you need more information, please contact
Beth Sheldrake at 206 553-0220. . . -
Even though Beth does not have volume numbers at this time, and.we are trying to remove and dispose.
off-site the most grossly contaminated, material prior to April, sites like this one make an important point
- namely, new wood treater sites that will require extensive cleanup are still showing up. If I remember
correctly, neither the Federal nor the state SFnor RCRA programs were aware of the extent of .
environmental problems at this facility until the past year.
' .* . ~ ' '
CC: SHELDRAKE-BETH
-------
From: PETER RUBENSTEIN
To: RTPMAINHUB:DCWIC01:DCCS01.DCCSPO2(LEE-CPAN)-''
Date: 12/19/962:46pm . /
Subject: wood treater LDR - need info! -Reply -Forwarded -Reply -Reply
Wyckoff Soil OU (used to be named Wyckoff Facility OU) '
1) K001 is NOT one of the waste codes for this material ,,
2) ROD in 1998, RD in 1998-99, RA start in 1999 : ... ' ,
3) Non-time critical removal action underway this February, removal of asphalt and pipe, not soils.
4) If all of the contaminated soils are removed it will be approximately 12 acres x 10'. However, this
very unlikely. Most likely treated/capped in place. ,
-------
-------
Appendix G
BIENNIAL REPORTING SYSTEM REPORT
-------
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-------
Appendix.H
METHODOLOGY FOR ESTIMATING QUANTITY OF SOIL AND DEBRIS
CONTAMINATED WITH WOOD PRESERVING WASTES
-------
-------
Volume of Wood Preserving Remediation Waste Requiring Combustion Under
the Phase IV Land Disposal Restrictions
In this Appendix, EPA presents a low-end arid high-end estimate59 of the quantity of wood
preserving waste requiring additional combustion capacity using a revised version of a direct estimate
approach.* EPA identified 21 RODs signed between 1991 and 1993 that contain information on soil and
debris volumes at wood preserving sites. EPA used the information contained in these RODs, as well as
the 30 RODs identified in the Beazer East analysis61, to develop these estimates.62 (See Attachment 1 to
the February 14,1997 memorandum included in this appendix.) EPA has excluded three wood
preserving sites from this analysis, presented in Exhibit 1, because treatments other than combustion are
indicated in the RODs for these sites and because they are contaminated only with chromium copper
arsenate (CCA) and other metals; EPA has thus assumed that combustion would not be used to treat
remediation wastes from these sites. . .
Exhibit 1
Wood Preserving Site RODs Contaminated Only with CCA or Other Metals
ROD Date
Sep-87
Sep-89
. Sep-91
Site Name
Palmetto Wood Preserving
Burlington Northern, Montana
Valley Wood Preserving
Contaminants'
CCA
Metals
Metals
> Volume of Soil or
Sediment Managed
Ex-situ (yd3)
19,900 .
11,700
15,000 .
Source
Beazer
Beazer
ICF
Using the Superfund RODs signed between 1986 and 1993, EPA constructed a direct estimate of
the annual volume of soil and debris from wood preserving sites that might be combusted under the status
quo and following the Phase I LDRs. To do this, EPA first directly summed the .volumes of excavated
soil and debris from RODs signed in the same year. Because remedial actions do not often begin
immediately after the ROD signature date, but are delayed as the remedial design (RD) is completed,
EPA had to develop an estimate of the time from signature of a ROD to the beginning of a remedial
action (RA). The Brookings Institution estimates that it takes an average of approximately. 18 months
from the issuance of the ROD to complete the remedial design, after which the remedial action can
begin.63 For this analysis, EPA assumed a delay of two years from the issuance of the ROD to the
beginning of remedial action. '
59 The terms "low-end" and "high-end" rather than-lower bound and upper bound have been used to reflect the
possibility that the actual quantities lie outside this'range.
60 For a detailed history of the methodology, see in this Appendix "Methodology and Data Sources for Estimating the
Volume of Wood Preserving Waste Requiring Combustion Under the Phase IV Land Disposal Restrictions,"
memorandum to Bill Kline, EPA/OSW (cc: C Pan Lee, EPA/OSW) from Scott Breffle and Jim Laurenson, ICF
Incorporated, January 29,1997 and "Updated Results for Estimating the Volume of Wood Preserving Waste
Requiring Combustion Under the Phase IV Land Disposal Restrictions," memorandum to Bill Kline, EPA/OSW (cc:
C. Pan Lee, EPA/OSW) from Scott Breffle and Jim Laurenson, ICF Incorporated, February 14,1997.
61 The table presented in the Beazer East comment includes 31 RODs. However, the two November 1986 RODs for
Mid-South Wood.Products appear to be duplicates.
62 Information on these RODs is presented in Attachment 1 of the February 14,1997 memorandum-included in this
Appendix (see footnote 2)., ' . -
63 Thomas W. Church and Robert T. Nakamura, Cleaning Up the Mess. Implementation Strategies in Superfund. The
Brookings Institution, 1993, page 8. , .
-------
Once remedial action begins, actual soil excavation can proceed relatively quickly. Small sites
may be excavated within.months, while large sites may take two or three years. The Blockings
Institution estimates that the completion of a remedial action (other than long-term maintenance, such as
groundwater pump and treat) takes an average of 25 months. For this analysis, EPA assumed that the
excavations would take an average of two years. Thus, EPA estimates that the total period of time from
the signing of a ROD to the completion of a remedial action is approximately four years. As a result of
these two assumptions about remedial pace, a site associated with a ROD signed in 1988, for example,
would generate soil in 1990 and 1991 (i.e., in years two arid three following the ROD date of signature.)
EPA has calculated a low-end and a high-end estimate for the volume of soil and debris requiring
additional combustion capacity (i.e., the volume that will require combustion above and beyond the
volume that is currently being combusted). To estimate the current (i.e., baseline or pre-LDR) volumes
being combusted, EPA examined the RODs for volumes that were planned to be combusted and, using
the assumptions about the remedial pace discussed above, distributed these volumes over the appropriate
years. The results are presented in Exhibit 2. Because the most recent RODs used in this analysis were
issued in 1993, the remedial actions have already.been completed, based on the above assumptions.
Nevertheless, the data can be used to project the future trend in annual volumes of soil and debris being
excavated from wood preserving sites.
The second column of Exhibit 2 presents the total volume of soil and debris that was planned for
combustion for each of the ROD years that EPA examined. The subsequent columns use the two
assumptions discussed above regarding initiation and completion of remediation to estimate when
Exhibit2
Annual Ex-Situ Soil and Debris Volumes from Wood Preserving Site Remedial Actions
Planned for Combustion During 1989 to 1995
ROD Signature
Date /
. 1986 '
1987
1988
1989
1990
1991
1992
' 1993
Ex-Situ Volume
(cubic yards)
9,000
170,000
131,000
6
98,000
, 0 v
2.930
.24,930
Annual Volume
Average Annual Volume
Expected Annual Volume (cubic yards) >.
1989
4,500
85,000
89,500
1990
85,000
65,500
150,000
1991
65,500
0
65,500
1992
0 '.
49,000
49,000
1993
49,000
0
49,000
1994
0
1,465
1,465
1995
i
1,465'
12,465
13,930
59,842
the volumes from each year ought to have been excavated and combusted. As Exhibit 2 shows, the
projected annual volume ranges from 1,465 cubic yards'in 1994 to 150,000 cubic yards in 1990. Because
of the uncertainty associated with our assumptions about the remedial pace and the lack of any
discernible trends to use for projections, EPA used the average annual volume to estimate the baseline
' volumes using combustion over the next two years. This baseline annual volume of soil and debris
requiring combustion under the status quo is 59,842 cubic yards, resulting in a quantity of approximately
72,000 tons per year over the next two years (using a conversion factor of 1.2 tons per cubic yard).
-------
To calculate the low-end estimate of the required additional combustion capacity, EPA estimated
the portion of soil and debris planned for treatment using methods other than combustion prior to '
promulgation of the LDRs that would likely be combusted under the LDRs. Historically, media '
contaminated with dioxins and furans has been the most likely to be treated using combustion. For this
rule, the UTS limits promulgated for organics and for dioxins and furans regulated in nonwastewater
forms of F032 waste are based on the performance of combustion technologies.. As discussed in the
BDAT background document, EPA believes that non-thermal treatment technologies may be optimized "
to meet the UTS limits within the context of a treatability variance under 268.44(h)64, but that the
feasibility of such treatment technologioes may require the use of treatment trains to meet the UTS
standards. Optimizing treatments or developing treatment trains can take time. In addition,,EPA believes
that the alternative combustion treatment standard for dioxins and furans in F032 waste, because it
waives the testing requirement, will provide a strong incentive to combust these wastes even if non-
combustion treatment technologies are viable and effective alternatives. Because of this incentive, the
possible time required to develop and optimize non-thermal tratment trains, and because treatability
variances are not likely be immediately available following promulgation of the LDRs, EPA assumed
that all soil and.debris contaminated with dioxins and furans that is not currently being combusted would
be combusted under the LDRs. The second column of Exhibit 3 presents these volumes of media
contaminated with dioxins and furans by the year in which the ROD was signed. Using the above
assumptions about remedial pace, Exhibit 3 distributes over the appropriate years the volumes of media
that EPA assumes will shift to combustion. As with the baseline estimate, EPA used the average annual
volume .;'.." ' . . "'
' l > , .
-Exhibits ,
Annual Ex-Situ Soil and Debris Volumes from Wood Preserving Site Remedial Actions
Expected to Shift to Combustion During 1989 to 1995 . ,
ROD Signature
Date
1986
. 1987 .
, 1988
1989
1990
1991
1992 .
1993
Ex-Situ Volume
(cubic yards)
" 93,000
0
16,100
293,000
. 0
25,000
78,120
254,650
Annual Volume
Average Annual Volume '
Expected Annual Volume (cubic yards)
1989
46,500
0
46,500
1990
0
8,050
8,050
1 1991
8,050'
.146,500
154,500
1992
146,500
0
146,500
-1993
0 '
12,500
12,500
1994
12,500
39,060
51,560
1995
39.060/
127,325
127,325
. 83,721
projected using this method to estimate a low-end additional required combustion capacity over the next
two years. As seen on the last line of Exhibit 3, the additional required combustion capacity is estimated
" See Section 6.5 of Final Best Demonstrated Available Technology Background Document for Wood Preserving
Wastes - F032. F034. and F035 for a discussion of the UTS limits and the performance of remedial treatment
technologies.' " - - ' . " -
-------
to be 83,721 cubic yards per year, resulting in a quantity of about 100,000 tons per year over the next two
years.65 .. ,. > '
' , /
For the high-end estimate, rather than estimate what portion of soil and debris would shift to
combustion, EPA assumed that the total volume of media (excluding media contaminated only with CCA
and other metals) currently not being combusted would be combusted under the LDRs. As seen in
Exhibit 4, the projected annual volume ranges from 55,100 in 1993 cubic yards to 505,750 cubic yards in
1989. .As with the baseline and low-end estimates, EPA used the average annual volume projected using -
. this method to estimate required combustion capacity over the next two years. As seen on the last line of
Exhibit 4, this average annual volume of soil and debris potentially requiring additional combustion
capacity is 217,594 cubic yards per year, resulting in a quantity of about 260,000 tons per year over the
next two years.
, i
Exhibit4
Expected Annual Ex-Situ Soil and Debris Volumes During 1989 to 1995 '
from Wood Preserving Site Remedial Actions l
.
ROD Signature
Date
1986
1987
1988
1989
1990
1991
1992
1993
Ex -Situ Volume
(cubic yards)
1,011,500
' 0 '
231,200
338,700
85,200
25,000
104,520
465,570
Annual Volume
Average Annual Volume
. - Expected Annual Volume (cubic yards)
1989
505,750
0
505,750
. 1990
0
115,600
. "'
115,600
1991
115,600
169,350
\
284,950
1992
,
169,350
42,600
211,950
1993
42,600
12,500
55,100
1994.
12,500
52,260
64,760
1995
52,260
232,785
285,045
217,594 .
Soil and debris from wood preserving sites is also likely to be generated during cleanup of hon-
NPL sites as well'as from cleanups under programs other than Superfund, such as through RCRA
corrective actions and closures, State cleanups, or voluntary cleanups. For example, Kerr-McGee has
said that four o'f its.seven facilities are undergoing RCRA corrective actions.66 As a result, the quantity
of soil and'debris contaminated with the newly identified wood preserving wastes is likely to be much
higher than the low-end estimate presented above. (See the February 14,1997 memorandum in this , .
appendix for a discussion of Beazer East's estimate). As discussed in Section 3.6.2 of this Background
Document, however, EPA determined that the low-end estimate of required alternative treatment capacity
was greater than available capacity, and therefore the Agency did not develop a high-end estimate of the
quantity of soil and debris contaminated with newly identified wood preserving wastes that would
require additional alternative treatment capacity. . -
65 Given that this quantity only includes Superfund NPL sites, the quantity might properly be considered a lower-
bound rather than a low-end estimate. See the next section.
66 See February 19, 1997 phone log in Appendix F detailing EPA discussions with Steve Ladner of Kerr-McGee.
-------
Thus EPA calculates that between about 100,000 and 260,000 tons per year of contaminated soil
and debris from wood preserving sites will require additional combustion capacity over the next two
years ~ ,-.''''
-------
-------
ICF
CONSULTING GROUP
ICF Incorporated
9300 Lee Highway
Fairfax, VA 22031-1207
703/934-3000 Fax 703/934-9740
February 14,1997
MEMORANDUM
TO: Bill Kline, EPA/OSW
CC: C.Pan Lee, EPA/OSW
FROM: Scott Breffle and Jim Laurenson
SUBJECT: Updated Results for Estimating the Volume of Wood Preserving Remediation Waste
Requiring Combustion Under the Phase IV Land Disposal Restrictions
We have completed our review and analysis of data on excavated soil, sediment, and debris67 at
wood preserving sites contained in Records of Decision (RODs) signed between 1991 and 1993. Based
on these data and ROD data contained in the Beazer East comment, this memorandum presents a range of
estimates of required combustion capacity for wood preserving wastes subject to the pending Phase IV
land disposal restrictions (LDRs). The basic methodology and preliminary results for this analysis are
described in two previous memoranda.68
Results
We have developed two ranges of estimates of the required alternative combustion capacity for
wood preserving remediation wastes. Our first set of estimates includes several'refinements of the
Beazer East methodology such that we've now labeled it the "Beazer East-based" approach. This update
also incorporates into the analysis the more recent ROD data that we have obtained. Our second set of
estimates is calculated directly based on the excavated soil volume for all wood preserving RODs in each
year and an estimate of the average duration of a Superfund remedial action. Each of these two ranges of
estimates is discussed below.
*
Beazer East-Based Analysis
In our January 31, 1997 memorandum, we presented information on soil, sediment, and debris
volumes for 9 of the 19 wood preserving sites RODs signed between 1991 and 1993 that we had
67 The excavated portion of the soil, sediment, and debris, and not the in-situ portion, is potentially subject to LDRs
and thus combustion. /
68 "Methodology and Data Sources for Estimating the Volume of Wood Preserving Waste Requiring Combustion
Under the Phase IV Land Disposal Restrictions, memorandum to Bill Kline, EPA/OSW (CC: C. Pan Lee,
EPA/OSW) from Scott Breffle and Jim Laurenson, ICF, January 29,1997; and "Preliminary Results for Estimating
the Volume of Wood Preserving Remediation Waste Requiring Combustion Underline Phase IV Land Disposal
Restrictions," memorandum to Bill Kline, EPA/OSW (CC: C. Pan Lee, EPA/OSW) from Scott Breffle and Jim.
Laurenson, ICF, January 31,1997.
-------
identified. We have since identified two additional wood preserving site RODs and have examined the
full text of all 21 RODs for information on soil, sediment, and debris volumes. The information
contained in these RODs as well as the 30 RODs used in the Beazer East analysis69 are presented in
Attachment 1.
The methodology presented in the Beazer East comment to calculate the potential volume of soil,
sediment, and debris requiring combustion was to calculate the average volume of these media managed
ex-situ at each site and then extrapolate this average to the universe of wood preserving sites to obtain a
total volume. Using RODs signed between 1986 and 1990, Beazer East reported an average volume per
site of approximately 84,000 cubic yards. In our January 31,1997 memorandum, we reported that the
RODs signed between 1991 and 1993 also yielded an average of about 84,000 cubic yards, but cautioned
that this average was based on only nine of the 19 RODs that we had identified. We have now completed
review of these 19 RODs, as well as the two additional RODs recently identified, for information on the
volume of soil, sediment, and debris managed ex-situ. For this analysis, we have excluded six wood
preserving sites, presented in Exhibit 1, because treatments other than combustion are indicated in the
RODs for these sites and because they are contaminated only with chromium copper arsenate (CCA) and
other metals; we've thus assumed that combustion would not be used to treat remediation wastes from
these sites.
Exhibit 1
Wood Preserving Site RODs Contaminated Only with CCA or Other Metals
ROD Date
Sep-87
Jun-89
Sep-89
Sep-89
Sep-89
Sep-91
Site Name
Palmetto Wood Preserving
Cape Fear Wood Preserving
United Creosoting
Koppers, Oroville, CA
Burlington Northern, Montana
Valley Wood Preserving
Contaminant
s
CCA
CCA
CCA
CCA
Metals
Metals
Volume of Soil or
Sediment
Managed Ex-situ
(yd3)
19,900
30,500
93,000
200,000
11,700
15,000
Source
Beazer
Beazer
Beazer
Beazer
Beazer
ICF
The resulting average per-site volume of soil, sediment, and debris planned for ex-situ
management each year is presented in Exhibit 2. As seen in Exhibit 2, the volumes of these media
projected to be managed ex-situ were significantly higher in 1986 and 1987, at approximately 170,000
cubic yards per site, relative to subsequent years. Among the RODs signed in 1986 was one site with a
projected ex-situ volume of soil of 800,000 cubic yards, as seen in Attachment 1. Only one wood
preserving site ROD was signed in 1987, which planned for ex-situ management of 170,000 cubic yards.
The Beazer East comment projected an average volume of soil, sediment, and debris managed;,
ex-situ at wood preserving sites of about 84,000 cubic yards per site. Removing the sites that are
contaminated only with metals or CCA raises the average per site to about 87,500 cubic yards. As seen
69 The table presented in the Beazer East comment includes 31 RODs. However, the two November 1986 RODs for
Mid-South Wood Products appear to be duplicates.
-------
Exhibit 2
Average Per-Site Volume of Soil, Sediment, and Debris Planned for Ex-Situ
Management at Wood Preserving Sites
in Exhibit 3, when the RODs signed between 1991 and 1993 are incorporated, the average falls to about
70,000 cubic yards per site. The average volume for the RODs signed between 1991 and 1993 is even
less, at about 44,000 cubic yards per site. When RODs back to 1988 are included (i.e., excluding 1986
and 1987), the average per-site volume remains at about 44,000 cubic yards. Therefore, using the
assumption that the worst (i.e., largest remediation waste volume) wood preserving sites have been
remediated, we used the 1988 to 1993 average to project to the universe of sites.
Exhibits
Average Per-Site Volume of Soil, Sediment, and Debris Projected for Ex-Situ Management
RODs Considered
1986-1990
1986-1993
1991-1993
1988-1993
Average Volume Projected
to be Managed Ex-Situ per
Site (cubic yards)
87,555
69,829
43,840
44,506
Using the average per-site volume of 44,500 cubic yards reduces Beazer East's estimate of the
total volume potentially requiring combustion by almost half, from 85.3 million cubic yards to
approximately 45.2 million cubic yards of soil, sediment, and debris.70 As discussed in our previous
memoranda, using this total to estimate the volume potentially requiring combustion over the next two
years is still likely to be overestimated for two reasons. First, although long-term trends remain difficult
to discern, Exhibit 2 indicates that the average per-site volumes requiring excavation may be declining.
Thus, the eventual total of soil, sediment, and debris requiring excavation over all wood preserving sites
is likely to be less than 45 million cubic yards. Second, there is no chance that all 45.2 million cubic
70
This calculation uses Beazer East's estimate that approximately 85 percent of the estimated 1,200 wood preserving
sites will require excavation of contaminated soil and sediment as part of a cleanup remedy.
-------
yards will be excavated over the next two years. Nevertheless, if remediation of, say, a tenth of the sites
were underway, and soil excavation were evenly distributed over the next ten years,71 the volume
potentially requiring combustion over the next two years would be approximately 450,000 cubic yards
per year (45.2 million cubic yards x 0.1/10 years). Thus, the upper bound estimate of wood preserving
soil, sediment, and debris requiring combustion during the next two years (using the Beazer East
approach) is approximately 450,000 tons per year (using a conversion factor of 1 ton per cubic yard).
We next calculated a pre-LDR or baseline estimate using the Beazer East-based approach. Nine
of the 51 RODs (17.6 percent) examined recommended combustion as the treatment method. The
average volume per site of soil, sediment, and/or debris that requires combustion at these sites is 48,444
cubic yards. Using Beazer East's methodology, about 10 million cubic yards (1,200 sites x 0.176 x
48,444 cubic yards) of soil could require combustion. Once again, however, this volume is not likely to
be seen in the next two years, and all future sites may not require the same level of remediation as current
sites. If remediation of, say, a twentieth of the sites were underway, and soil excavation were evenly
distributed over the next ten years, the baseline estimate of the volume potentially requiring combustion
over the next two years would be approximately 50,000 cubic yards per year (10 million cubic yards x
0.05/10 years), or 50,000 tons per year.
To estimate the low-end quantity requiring additional combustion capacity, we developed a ratio
of additional combustion over baseline combustion using all of the ROD data in Attachment 1 and an
assumption similar to the one used more rigorously and described in more detail in the next section.
Briefly, this assumption is that contaminated media planned for bioremediation, critical fluid extraction,
or thermal desorption would need combustion under the LDRs, while media planned for other
management would not be combusted. The calculated ratio is 894,090yd3/435,930yd3 = 2.05, and
therefore the estimated low-end quantity of soil, sediment, and debris contaminated with newly listed
wood preserving wastes requiring additional combustion capacity is approximately 100,000 tons per .
year. Subtracting the baseline combustion quantity from the upper-bound combustion quantity results in
an estimated high-end quantity of soil, sediment, and debris contaminated with newly listed wood
preserving wastes requiring additional combustion capacity of approximately 400,000 tons per year.
Thus, the Beazer East approach, with our assumptions, results in a quantity of waste requiring
additional combustion ranging between 100,000 and 400,000 tons per year over the next two years. The
estimate generated by this approach is subject to many uncertainties, however. Beazer East's approach,
as described in previous memoranda, assumes that all wood preserving sites will undergo remediation in
the near future, and that the quantity of soil, sediment, and debris removed at each site will be similar to
that removed at current wood preserving Superfund sites. Neither assumption is likely to be realized.
We have tried to correct this assumption by assuming that remediation wastes will be generated by
between a tenth and twentieth of the total number of wood preserving sites over the next ten years. This
assumption itself is subject to significant uncertainty. In addition, the Beazer East methodology does not
factor out of the analysis the current quantity of soil, sediment, and debris that requires combustion. This
quantity is treated with current capacity, and should not be considered as part of the quantity that will
require additional treatment capacity over the next two years. We therefore incorporated an assumption
regarding this additional capacity. The approach described in the next section attempts to address these
shortfalls more thoroughly.
71 The average duration of remedial actions at nonfederal sites proposed to the Natioanl Priorities List (NPL) was
reported as 9.6 years in "Analyzing the Duration of Cleanup at Sites on Superfund's National Prioroties List," March
1994, Congressional Budget Office.
-------
Direct Estimation
As a supplement/replacement of the Beazer East methodology, we constructed a direct estimate
of the annual volume of soil, sediment, and debris from wood preserving sites that might be combusted.
To do this, we first directly summed the volumes of excavated soil, sediment, and debris from RODs
signed in the same year. Because remedial actions do not often begin immediately after the ROD
signature date, but are delayed as the remedial design (RD) is completed, we had to develop an estimate
of the time from signature of a ROD to the beginning of a remedial action (RA). The Brookings
Institution estimates that it takes an average of approximately 18 months from the issuance of the ROD to
complete the remedial design, after which the remedial action can begin.72 For this analysis, we assumed
a delay of 2 years from the issuance of the ROD to the beginning of remedial action.
Once remedial action begins, actual soil excavation can proceed relatively quickly. Small sites
may be excavated within months, while large sites may take two or three years. The Brookings
Institution estimates that the completion of a remedial action (other than long-term maintenance, such as
groundwater pump and treat) takes an average of 25 months. For this analysis, we assumed that the
excavations would take an average of two years. Thus, we estimate that the total period time from the
signing of a ROD to the completion of a remedial action is approximately four years. As a result of these
two assumptions about remedial pace, a site associated with a ROD signed in 1988 for example, would
generate soil in 1990 and 1991 (i.e., in years two and three following the ROD date of signature.)
We have calculated a low-end and a high-end estimate for the volume of soil, sediment, and
debris requiring additional combustion capacity (i.e., the volume that will require combustion above and
beyond the volume that is currently being combusted). To estimate the current (i.e., baseline or pre-
LDR) volumes being combusted, we examined the RODs for volumes that were planned to be combusted
and, using the assumptions about the remedial pace discussed above, distributed these volumes over the
appropriate years. The results are presented in Exhibit 5. Because the most recent RODs used in this
analysis were issued in 1993, the remedial actions have already been completed, based on our
assumptions. Nevertheless, the data can be used to project the trend in annual volumes of soil, sediment,
and debris being excavated from wood preserving sites.
The second column of Exhibit 5 presents the total volume of soil, sediment, and debris that was
planned for combustion for each of the ROD years that we examined. The subsequent columns use the
two assumptions discussed above regarding initiation and completion of remediation to estimate when
the volumes from each year ought to have been excavated and combusted. As Exhibit 5 shows, the
projected annual volume ranges from 1,465 cubic yards in 1994 to 150,000 cubic yards in 1990. Because
of the uncertainty associated with our assumptions about the remedial pace, we used the average annual
volume projected using this method to estimate the baseline volumes using combustion over the next two
years. This baseline annual volume of soil, sediment, and debris requiring combustion is 59,776 cubic
yards, resulting in a quantity of approximately 60,000 tons per year over the next two years.
To calculate the low-end estimate of the required additional combustion capacity, we estimated
the portion of soil, sediment, and debris planned for treatment using methods other than combustion that
would be combusted under the LDRs. We based our estimate on the current treatment technology being
applied to the media. We assumed that soil, sediment, or debris to be treated using bioremediation,
critical fluid extraction, or thermal desorption would contain sufficient concentrations of
72 Thomas W. Church and Robert T. Nakamura, Cleaning Up the Mess. Implementation Strategies in Superfund. The
Brookings Institution, 1993, page 8.
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Exhibits
Annual Ex-Situ Soil, Sediment, and Debris Volumes from Wood Preserving Site Remedial Actions
Planned for Combustion During 1989 to 1995
ROD
Signature
Date
1986
1987
1988
1989
1990
1991
1992
1993
Ex-Situ
Volume (cubic
yards)
9,000
170,000
131,000
0
98,000
0
2,930
25,000
Annual Volume
Average Annual Volume
Expected Annual Volume (cubic yards)
1989
4,500
85,000
89,500
1990
85,000
65,500
150,000
1991
65,500
0
65,500
1992
0
49,000
49,000
1993
49,000
0
49,000
1994
, 0
1,465
1,465
1995
1,465
12,500
13,965
59,776
wood preserving wastes such that combustion would be needed under the LDRs. In contrast, we assumed
that soil, sediment, or debris to be managed using land disposal, soil washing, stabilization/solidification/
fixation would not be combusted under the LDRs. Based on our assumption about remedial pace,
Exhibit 6 distributes over the appropriate years the volumes of media that we assume will shift to
combustion. As with the baseline estimate, we used the average annual volume projected using this
method to estimate a low-end additional required combustion capacity over the next two years. As seen
on the last line of Exhibit 6, the additional required combustion capacity is estimated to be 90,186 cubic
yards per year, resulting in a quantity of about 90,000 tons per year over the next two years.
Exhibit 6
Annual Ex-Situ Soil, Sediment, and Debris Volumes from Wood Preserving Site Remedial Actions
Expected to Shift to Combustion During 1989 to 1995
ROD
Signature
Date
1986
1987
1988
1989
1990
1991
1992
1993
Ex-Situ
Volume (cubic
yards)
101,500
0
165,000
15,200
85,200
25,000
78,120
424,070 .
Annual Volume
Average Annual Volume
Expected Annual Volume (cubic yards)
1989
50,750
- 0
50,750
1990
,/
0
82,500
82,500
1991
82,500
7,600
90,100
1992
7,600
42,600
50,200
1993
42,600
12,500
55,100
1994
12,500
39,060
51,560
1995
39,060
212,035
251,095
90,186
-------
For the high-end estimate, rather than estimated what portion of soil, sediment, and debris would
shift to combustion, we assumed that the total volume media (excluding media contaminated only with
CCA and other metals) currently not being combusted would be combusted under the LDRs. As seen in
Exhibit 7, the projected annual volume ranges from 50,200 in 1992 cubic yards to 505,750 cubic yards in
1989. As with the baseline and low-end estimates, we used the average annual volume projected using
this method to estimate required combustion capacity over the next two years. As seen on the last line of
Exhibit 7, this average annual volume of soil, sediment, and debris potentially requiring additional
combustion capacity is 170,379 cubic yards per year, resulting in a quantity of about 170,000 tons per
year over the next two years.
Thus, using direct estimation, we calculate that between about 90,000 and 170,000 tons per year
of contaminated soil, sediment, and debris from wood preserving sites will require additional combustion
capacity over the next two years. In comparison, our calculations and assumptions designed to improve
the Beazer East approach estimate that between about 100,000 and 400,000 tons per year of soil,
sediment, and debris would require additional combustion over the next two years. Both ranges contain .
significant uncertainty, however. In addition to the caveats discussed previously, for example, both
ranges depend on the assumption regarding planned treatments that are expected to shift to combustion
under the LDRs. Some of these shifts may not occur and thus the amounts of additional required
combustion capacity conceivably could be lower than estimated. On the other hand, land disposal, which
for purposes of this analysis is not expected to shift to combustion, could actually indicate that
constituent concentrations are very high such that combustion would be needed under LDRs. Other
caveats involve the extent to which all remediation sites have been captured. For example, the Beazer
East-based methodology accounts for non-ROD sites, while the current approach for the direct estimate
does not.
Exhibit?
Expected Annual Ex-Situ Soil, Sediment, and Debris Volumes During 1989 to 1995
from Wood Preserving Site Remedial Actions
ROD
Signature
Date
1986
1987
1988
1989
1990
1991
1992
1993
Ex-Situ
Volume (cubic
yards)
. 1,011,500
0
231,200
15,200
85,200
25,000
104,520
465,570
Annual Volume
Average Annual Volume
Expected Annual Volume (cubic yards)
1989
505,750
0
505,750
1990
0
1 15,600
115,600
1991
115,600
7,600
123,200
1992
7,600
42,600
50,200
1993
42,600
12,500
55,100
1994
12,500
52,260
64,760
1995
52,260
232,785
285,045
170,379
Possible Next Steps
Several next steps could be taken to strengthen this analysis. For example:
-------
The assumptions regarding the length of time before remediation begins and ends following
the ROD could be improved. Alternatively, a sensitivity analysis could be conducted to
determine the relative importance of these parameters.
The assumptions regarding which non-combusted wastes will shift to combustion could be
examined. As indicated above, this assumption could be resulting in either an under- or
over-estimation.
The handling of the universe of sites, especially for the direct approach, could be improved
to include non-ROD sites. Improvements here, however, would only increase the additional
combustion required capacity. '-
* * *
Please call Scott at (703) 934-3917 or Jim at (703) 934-3648 if you have any questions or
comments on this memorandum.
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Attachment 1
List of Wood Preserving Site Record's of Decision, 1985 to 1993
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.... . January 29,1997
MEMORANDUM
TO: Bill Kline, EPA/OSW . ; -
CC: C. Pan Lee, EPA/OSW .
FROM: Scott Breffle and Jim Laurenson ' .
SUBJECT:* Methodology and Data Sources for Estimating the Volume of Wood Preserving Waste ,
Requiring Combustion Under the Phase IV Land Disposal Restrictions
This memorandum presents our methodology and data sources for refining the estimates of
required combustion capacity for wood preserving wastes subject to the pending Phase IV land disposal
restrictions (LDRs). We plan to have preliminary results by Thursday or Friday of this week.
1. Methodology
' >
We are refining the estimate of soil contaminated with newly listed wood preserving wastes
(presented in Section 3.4 of the draft wood preserving capacity background document) in three ways:
1. updating the projected volumes of excavated wood preserving wastes that were presented in
response to the ANPRM by Beazer East, Incorporated73 using more recent Superfund ^
'Records of Decision (RODs); .
2. refining the Beazer East methodology by estimating the annual excavated soil and sediment
volumes directly, based on the excavated soil volume for all RODs in each year and an
estimate of the average duration of a Superfund remedial action; and
- .1 ' -
3. incorporating new data obtained from the Biennial Reporting System (BRS) and other
commenter data. . '
1.1 Update of Beazer East Estimate . .
To update the estimate of wood preserving wastes potentially requiring combustion, we are first
duplicating the methodology of Beazer East using more recent ROD data. The Beazer East analysis used
RODs from 1982 to 1990. We will incorporate RODs from wood preserving sites from 1991 to the most
recent RODs that are obtainable. The basic methodology used by Beazer.East is as follows:
1. Determine the number and percentage of wood preserving site RODs examined that have
contaminated soil and sediment (i.e., excluding sites with only contaminated ground water);
73 "Wood Treating Review Project," memorandum to Beazer East, Inc. from National Environmental Technology
Applications Corporation, December 2,1991, RCRA Docket No. CSP-00020.A.
-------
2. Determine the number and percentage of wood preserving site RODs that have contaminated
soil and sediment that will undergo excavation;74 . ,
3. Calculate the total volume (across all RODs) of wood preserving site soil and sediment to be
excavated; ...
4. Based on steps 2 and 3, calculate the average volume to be excavated per site among those
wood preserving sites requiring soil and sediment excavation; and.
5. Based on an estimate of total number of wood preserving sites in the United States,
extrapolate to a national total waste quantity using the percentage of sites with contaminated
soil and sediment, the percentage of sites requiring excavation, and the average volume per,
site (i.e., step 1 *step 2*step 4*the total number of wood preserving sites in the United
States). , . ' ' .
This methodology produces an upper-bound estimate (and possibly an unreasonable upper-bound
estimate; see Section 1.2) of total soil and sediment requiring combustion by assuming that all soil and
sediment that is managed ex-situ, including the portion that undergoes non-thermal treatment, will need
to be combusted. In addition, this methodology essentially assumes that all wood preserving sites in the
United States,will generate excavated remediation volumes similar to volumes excavated at current
Superfund sites, and that these remediations will occur in the near future.
Our revised estimate may differ from that provided by Beazer East because more recent RODs
may indicate that more or less volume is being treated ex-situ. For example, the earlier Superfund RODs
could have addressed sites that are larger or more contaminated than sites addressed by more recent
RODs. As a result, future volumes of soil and sediment that require combustion may be less than that
projected by Beazer East. We may be able to refine the upper-bound volume requiring combustion by
estimating the fraction of currently excavated soils and sediments that may be treated by methods other
than combustion to meet the LDRs; For example, wood preserving sites that are contaminated with only
F035 wastes (i.e., inorganics) will not use combustion as a treatment method. These volumes of F035
wastes .can be subtracted from the upper-bound estimate. The RODs that are being reviewed will
generally contain data on current treatment methods. .
* ' *
Next, we plan to estimate the subset of the total volume of soil and sediment that will require
treatment within the next two years. That is, many of the sites represented by the RODs likely have
already excavated and treated their soils and sediments, while some sites are likely to take longer than the
two-year variance window to implement that portion of the ROD. Analysis conducted for the. Hazardous
Waste Identification Rule for Contaminated Media (HWIR-Media) has generated estimates of the total,
volume and number of Superfund sites expected to be remediated annually over the next five years. This
information, in conjunction with an estimate of the relative proportion of wood preserving site RODs to
the total number of RODs, can be used to estimate the volume of excavated soil and sediment that will
require treatment withui the next two years. . . '
A lower-bound estimate of the total required combustion capacity will be estimated by assuming
that, at a minimum, all volumes currently being excavated and combusted will continue to be treated in
that manner after the LDRs are effective. We may be able to refine this lower-bound volume by adding
soil and sediment to this volume using assumptions about what proportion of waste undergoing non-
thermal treatment will require combustion.
74 It is the excavated portion of the soil and sediment that is potentially subject to LDRs and thus combustion.
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Finally, another possible refinement includes subtracting possible K001 and D037 wastes
undergoing combustion from the upper-bound and lower-bound estimates.
1.2 Directly Estimate the Annual Volume of Soil and Sediment Excavated from Wood Preserving
Sites . . .'','. - .
'As a supplement toand possbly a replacement of75the Beazer East^methodology, we will use
the data from the previous analysis (Section 1.1) to construct a direct estimate of the annual volume of
soil and sediment expected to be excavated from wood preserving sites. To do this, we will directly sum
the volume of excavated soil and sediment from RODs signed in the same year. Because Superfund
remediation actions are likely to span more than one year, however, each annual volume will be spread
over an appropriate number of years. The final estimate of the annual volume of excavated soil and
sediment from wood preserving sites will be a sum of the volumes from remedial actions begun in the '
recent past years as well as the current year. We will use data contained in the HWIR-Media proposed
rule (which came from a Report to Congress on the Superfund Program) to estimate the average length of
Superfund remedial actions. . '
. \
2. .- Data Sources " . :
;*...'.
2.1 Records of Decision '
i , ...
We have currently identified approximately 20 RODs signed between 1991 and 1993 that
address contamination at wood preserving sites, or sites where wood preserving operations were
conducted. We are in the process of extracting from these RODs information on volumes of soil and
sediment, and the recommended treatment methods. Tliese RODs are contained on a March 1995 CD-
ROM disc76 that ICF possesses. - " '
More recent RODs can be obtained by purchasing a newer version of the above CD-ROM disc
($325). Alternatively, we plan to investigate the quality of information that can be obtained through on-
line databases such as the Right to Know Network (RTK-Net), which houses the CERCLA Superfund
Information System (CERCLIS) and National Priority List (NPL) databases.
2.2 BRS WR Form
We are currently reviewing data submitted on the BRS waste received (WR) form in an effort to
refine the estimates of soil and sediment requiring treatment. The WR form will provide information on
wood preserving wastes received from off-site, and may capture volumes of wood preserving wastes that
were not reported on the BRS dM form, such as wastes from small quantity generators or wastes that
were assigned the wrong.treatment method by the generator! A tally of the total quantity of wood
preserving wastes requiring land disposal will provide an upper-bound estimate of wood preserving
wastes requiring treatment under the LDRs..
75 A detailed review of the Beazer East methodology indicates that several unreasonable assumptions have been used
to estimate total soils.- For example, Beazer East essentially assumes that all wood preserving sites will undergo
remediation in the near future, and that the quantity of soil removed at each site will be similar to that removed at
current wood preserving Superfund sites. .Neither assumption is likely to be realized.
76 EPA Superfund Records of Decision on CD-ROM, National Technicallnfprmation Service (NTIS), PB95-
593551FCD, March 1995. ... ,
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2.3 Corrective Action
Information on the volumes of soil and sediment from RCRA corrective actions is limited.
While RCRIS theoretically contains data on volumes at RCRA corrective action sites, in practice that
data are frequently missing from the files or are ambiguous. Furthermore, based on a brief review of the
. Corrective Action Regulatory Impact Analysis database, relatively few wood preserving sites appear to
be undergoing RCRA corrective action compared to Superfund remediation. We therefore propose at
this time to not use corrective action data to estimate soil and sediment volume potentially subject to
combustion.
. , - - . ';***
- Please call Scott at (703) 934-3917 or Jim at (703) 934-3648 if you have any questions or
comments on this memorandum. - '
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