United States Solid Waste and EPA530-R-97-037a
Environmental Protection Emergency Response NTIS: PB97-177 422
Agency (5305W) , June 1992
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&EPA Background Document
for Capacity Analysis
for Newly Listed
Wastes and Hazardous
Debris to Support 40
CFR 268 Land Disposal
I Restrictions (Final Rule)
Volume 1: Capacity Analysis
Methodology and Results
Appendix A - Organic Waste Phone
Logs
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Appendix B - Hazardous Debris
Issues and Concerns
Printed on paper that contains at lest 20 percent postconsumer fiber . .
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Background Document for Capacity Analysis for
Newly Listed Wastes and Hazardous Debris to
Support 40 CFR 268 Land Disposal Restrictions
(Final Rule)
Volume 1: Capacity Analysis Methodology and Results
- Appendix A - Organic Waste Phone Logs
Appendix B - Contaminated Debris Issues and Concerns
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United States Environmental Protection Agency
Office of Solid Waste
' 401 M Street, N.W.
Washington, D.C 20460
June 1992
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BACKGROUND DOCUMENT FOR CAPACITY ANALYSIS' FOR .
NEWLY LISTED WASTES AND HAZARDOUS DEBRIS TO SUPPORT
40 CFR 268 LAND'DISPOSAL RESTRICTIONS- (FINAL RULE) ,
I
, _ TABLE OF CONTENTS
VOLUME 1:' CAPACITY ANALYSIS .METHODOLOGY AND RESULTS
I.
INTRODUCTION. '...... 1-1
1.1 .Legal Background " 1-1
1.2 Capacity Analysis Methodology '. 1-6
1.2.1 Determination of Required Commercial Treatment Capacity ... 1-6
1.2:2 Determination of Available Commercial Treatment .....:...; .' 1-8
1.3 Summary of Capacity Analysis Conducted for Final Rule '. 1-8
1.4 Organization of Background Documents Supporting -
. Capacity Analysis "..'.,..'.._ 1-12
,2. COMMERCIAL TREATMENT CAPACITY ....'. .' 2-1.
, 2.1 Commercial Combustion Capacity Summary .; ,' 2-1
2.2 Commercial Incineration Capacity . '. .- 2-6
. 2.2.1 General Approach and Assumptions ..." 2-6
2.22 Individual Incineration Facility Capacity Analysis : -.. 2-9
2.2.3 Sludge and Solid Incineration Capacity Beyond 1992 ..-....... 2-24
2-3 .Commercial Cement Kiln Hazardous Waste Capacity ' .... 2-25
'2.3.1 General Approach and Assumptions 2-25
' 2.3.2 Individual Facility Analysis Methodology . 2-33
2.3.3 Individual Facility Results . '. 2-32
2.3.4 Sludge and Solid Cement Kiln Capacity Beyond June 1992 2-40
2.3.5 Facilities not Included in this Capacity Analysis 2-43-
2.3.6 Packaging Capacity for the Cadence Solid Fuels Technology at
Cement Kilns ". . ..- 2-43
2.4 Other Treatment System Capacities :: ' 2-46
2.4.1 General Approach and Assumptions ..; ;........ 2-46
2.4.2 Summary' of Available Capacity for Biological Treatment,
Chemical Precipitation, and Stabilization . 2-46
3. CAPACITY "ANALYSIS FOR F037 AND F038- ,'
PETROLEUM REFINING WASTES .,'. .3-1
3.1 Introduction 3-1
3.1.1 Background ; ' 3-1
3.1.1.1 Regulatory History ... 3-1
3.1.1.2' Industry and Wastewater Treatment'Process
. ' - Overview ..' 3-2
'III
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1 3.1.J.3 Waste Stream Definitions ...'.... 3-3.'
3.1.2 Overview of Capacity Analysis 3-5
. 3.2 ' Data Sources ....'... 3-6
3.2.1. Data Sources Used for F037/8 Capacity Analysis .' 3-7
3.2.2 Data Sources Examined But Not Used for F037/S Capacity ;
Analysis ' .3-14
3.3 Methodology, Assumptions, and Preliminary. Results .v 3-15
3.3.1 Step 1: Identify Research Needs and Existing Data- 3-16
3.3.2' Step 2: Apply Engineering Judgement To Existing Data .'....3-17
3-3.3 Step 3: Collect and Evaluate New Data 3-20
. 3.3.4 'Step 4: Apply Engineering Judgement to fill Data Gaps ..... 3-21
3.3.4.1 Refinery Categories. . ... : 3-21
3.3.4.2 Refinery Groups . 3-22
v , 3.3.4:3 Material-balance Calculation' for Category 2
' Refineries -. . : :.'... 3-26
... 3.3.4.4 ' Non-dewatered F037/8 Waste Generation 3-27r
3.3.4.5 Reductions as a Result of Dewatering 3-29
3.3.4.6 Reductions as a Result of Using On-Site Cokers . 3-30
3.3.4.7 Reductions as a Result of Other'Treatrnent 3-31
3.4 Summary of Required Capacity and Comparison ' to Available
Capacity ...'......' . 3-33
3.4.-1 F037/8 Waste Generation and Management1 on the Effective '
Date of the LDR (June 1992) ..:... 3-33
3.4.2 F037/8 Waste Generation During Two Years Following the
LDR (June 1992 to June 1994) 3-33
. 3.4.3 Available Commercial Capacity, and Comparison to Required
Capacity . .;......: 3-34
4. CAPACITY ANALYSIS FOR OTHER NEWLY LISTED WASTES .- 4-1
4.1 Data Sources and Methodology .....'. ..:...... " 4-1
4.2 Capacity Analysis Results -.- " 4-2
, ' 4.2.1 Unsymmetrical Dimethylhydrazine (UDMH) Production
Wastes (K107, K108, K109, and K110) 4-9
4.2.2 2-Ethoxyethanol (U359) .......,..'.. : ' 4-9
4.2.3 Dinitrotoluene and Toluenediamine Production Wastes
(Klll-Kli2, U328 and U353) .-.. .4-10
4.2.4 Ethylene Dibromide (EDB) Production Wastes
(Kl 17, Kl 18, and K136) and Methyl Bromide Production
Wastes (K131 and K132) ;'. : . . 4-14
4.2.5 Ethylenebisdithiocarbamic (EDBC) Acid Production Wastes
(KI23, K124, K125, and K126) ' 4-17
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5. : CAPACITY ANALYSIS FOR SURFACE-DISPOSED.
MIXED.RADIOACTIVE.WASTES : .' 5-1
, 5.1 Background . 5-1
5.2- Analysis of Alternative Treatment Capacity .;....'.....;.... 5-3
; 5.3 ' National'Capacity Variance for Mixed RCRA/Radioactive Wastes ... 5-7
6. CAPACITY ANALYSIS FOR DEBRIS CONTAMINATED ' - .'
WITH NEV/LY LISTED WASTES ^ '..'... . ; , 6-1
6.1' Introduction and Key Findings .-...;. '. 6-1
6.2 Available Information Sources 6-2
6.2,1 Comments to; the Proposed Rule : '-6-2
6.2.2 Comments to the ANPRM ., 6-3
' 6.2;3 Roundtable Meetings - . . -. 6-5
6.2.3.1 Quantities and Composition of Hazardous Debris .... 6-6'
. / 6.2.3.2 Sources of Hazardous Debris ". 6-7
6.2.3.3 Current Management of Hazardous Debris . 6-11
6.2.3.4 Other Issues of Concern 6-13
6.2.4 National Survey of Treatment, Storage, Disposal and Recycling
Facilities (TSDR Survey) .- . ' 6-13
6.2.5 Other Information Sources '. 6-14
6.3 , Current Generation of Hazardous Debris Which Will Require . - .-
Treatment Capacity ; : 6-16
6.3.1 Estimates of Total Hazardous Debris....". %. 6^16
6.3.1.1 Method 1: Approach and Results .6-17
6,3.1.2 Method 2: Approach and Results -; ' 6-1?
6.3.2 .Debris Contaminated with the Newly Listed Wastes ...'...'... 6-28 .
6.4 Available Capacity for Managing Hazardous Debris : . 6-29
6.4.1 Current Treatment of Debris ..' '......,.... 6-29
6.4.2 Materials Handling Problems 6-30
6.4.3 Available Treatment Capacity ..'......'....:.. .6-30
7. , K061, K062, AND F006 WASTES ....;. ./.... 7-1
7.1 Background '.........-. 7-1.
7.2 K061 Waste Generation ..: , ,..!.... .... 7-1
7.3 Available Treatment Capacity For K06I Wastes 7-2
. 7.4 Capacity Implications ..-..........: '.......... 7-2
APPENDIX A: ORGANIC WASTE PHONE LOGS .
APPENDIX B: HAZARDOUS DEBRIS ISSUES AND CONCERNS ' '. .
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VOLUMES 2, 3, AND 4: APPENDIX C - BACKGROUND DATA FOR INCINERATION
AND CEMENT KILN CAPACITY ' - -
VOLUME 5: APPENDIX D - CATEGORY i FACILITIES FOR THE FO37/8 CAPACITY
ANALYSIS ' - ' .
VOLUME 6: APPENDIX E - CATEGORY 2 FACILITIES FOR THE F.O37/8 CAPACITY
ANALYSIS - ' . ".-. ' '.
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VOLUME 7: .APPENDIX F - CATEGORY 3 FACILITIES FOR THE FO37/8 CAPACITY
ANALYSIS ' , .. -. .
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. ' ; ' - CHAPTER I . -
INTRODUCTION
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This document presents, the capacity analysis EPA conducted to support the final
rule on the Land Disposal Restrictions (LDRs) of Newly Listed Wastes and Hazardous
Debris. EPA conducts the capacity-analysis to evaluate the need for national capacity
..variances from the land disposal prohibitions.1 The capacity analysis provides estimates
of the quantities of wastes that will require alternative commercial treatment and , '
recovery prior'to land disposal as a result of the LDRs and estimates alternative
commercial treatment and recovery capacity available to manage wastes restricted from
land disposal. In this final rule, EPA is prohibiting the land disposal of certain wastes
listed between November 1984 and June 1990, These wastes are'summarized in Exhibit
1-1. ' ' - :
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1.1 LEGAL BACKGROUND . ..'.
, The Hazardous and Solid Waste Amendments (HSWA) to RCRA, enacted on
November 8, 1984, set basic new priorities for hazardous waste management. LanJ
disposal, which had been the most widely used method for managing hazardous waste, is,
now the least preferred option. Under HSWA, the U.S. Environmental Protection '
Agency (EPA) must promulgate regulations restricting the land disposal of hazardous
wastes according to a strict statutory schedule." As of the effective date of each
regulation, land disposal of untreated wastes covered by,that regulation is prohibited
unless :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 Land Disposal Restrictions 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, EPA prefers to
, define treatment in terms of performance (i.e., levels of treatment, expressed as a
concentration of hazardous constituents in residuals from treatment) rather than in terms
of specific treatment methods. EPA's standards are generally based on the performance
of the best demonstrated available technology (BOAT), 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 when promulgated unless the Administrator grams a national capacity variance
from Ihe otherwise applicable date and establishes a different dale (not en exceed m> years beyond (he
statutory deadline) based on:... the earliest dale on which adequate alternative treatment, recovery, or disposal
capacity which protects human health and the environment v.ill be available (RCRA Section 30Q4(h)(2)}.
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RCRA defines land disposal 'to include, but hot 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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The land disposal restrictions are effective immediately upon promulgation unless
the Agency grants a national capacity variance from-the statutory date because of a lack
of available treatment/recovery capacity. For every waste. EPA considers, on a national
basis, both the capacity of.commercially available treatment or recovery technologies and
the'quantity of restricted wastes currently sent to land disposal for which on-site
treatment.or recovery capacity is not available. If EPA determines that adequate
alternative treatment or recovery capacity is available for a particular waste, the .land
disposal restriction goes into effect immediately. If not, EPA establishes an alternative -
effective date based on the earliest date on which adequate treatment or recovery
capacity will .be available, or two-years, whichever is less. ,
RCRA allows EPA to grant national variances if, there is insufficient capacity
available arriong the nation's hazardous waste treatment facilities to manage the quantity
of wastes requiring treatment as a result of the LDRs (RCRA Section 3004(h)(2)). Once
the variance expires, the wastes must meet the LDR treatment standards prior to being
placed on the land. . ' ' '
RCRA also allows generators to apply for. extensions on a case-by-case basis for
specific wastes generated at a.specific facility (RCRA Section 3004(h)(3)). EPA may
grant case-by-case extensions to applicants, who can demonstrate that: (1) no capacity
currently exists anywhere in the U.S. to treat a specific waste, and (2) a binding
contractual commitment is in place to construct or otherwise provide alternative capacity,'
but due to circumstances beyond the applicant's control, such alternative capacity cannot ,
reasonably be made available by the effective date (40 CFR 268.5).
.' . ' ' '
HSWA's schedule divided hazardous wastes into four' broad categories: Solvent
and Dioxirr wastes; California list wastes3, and scheduled wastes. The second category,
whose final rule was issued on July 8, 1987, covers wastes originally listed by the State of
California and adopted intact within HSWA. The "scheduled" wastes refer to the ' .
Agency's statutory timetable that restricted one-third of these wastes by August 8, 1988,
two-thirds by June 8, 1989, and the remaining third by May 8, 1990. For hazardous
wastes that are newly identified or listed after November 8, 1984, EPA is required to
promulgate land disposal prohibitions within six months of the date of identification or
listing (RCRA Section 3004(g)(4)).' However, the statute does not provide an automatic
prohibition of land disposal of such wastes if EPA fails to meet' this deadline. Exhibit 1-2
summarizes the previous LDR rulemakings and their respective promulgation dates.
3 The 'California lilt* comprises the following classes of wastes: liquid hazardous wastes with a pH of
less than or equal to 2.0 (acidic corrosive wastes); all'liquid hazardous wastes containing free cyanides, various
meials. and polychforina'ied biphcnyls (PCBs) exceeding statutory concentration levels; and all wastes (liquid,
sludge, or solid) containing halogenated organic compounds (HOCs) in concentrations greater than or equal
to specified statutory levels. " . '
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EXHIBIT 1-2 .
SUMMARY OF PREVIOUS LAND DISPOSAL RESTRICTIONS RULEMAKINGS
Rulemaking '
Solvents 'and .Dioxins
(surface disposed)
Solvents and Dioxins .
(deepwell-injecied)
California List
(surface disposed) ' '
California List
(deepwelt injected)
First Third Rule
First Third Rule
(decpwell injected)
Second Third Rule
Third Third Rule ,
Federal Register Notice
51FR40572 -
53 FR 28188
52 FR 25760
53 FR 3090S
53 FR31138
54 FR 25416
54 FR 26594
55 FR 22520
Promulgation Date
November 7, 19S6
July 26, 1983 '
July a. 1987
July 26, 1958.
August 8, I9S8
June 7, 1989
June 8; 19S9
May 8, 1990
1.2 CAPACITY ANALYSIS METHODOLOGY .
In evaluating the need for national capacity variances, EPA estimates the
quantities of waste requiring alternative treatment as a result of the. land disposal -
restrictions and the capacity available at commercial treatment/delivery facilities to
manage the restricted wastes. This section provides ah overview of EPA's methodology
in estimating required-and available capacity. By comparing the required capacity with
the available commercial capacity, EPA can identify capacity shortfalls and make
determinations concerning national capacity variances.
1.2.1
Determination of Required'Commercial Treatment Capacity.
Required commercial treatment capacity represents the quantity of wastes -
cuirently being land disposed that can not be treated on site and, consequently, will
require commercial treatment to meet a treatment standard prior to being land disposed.
Required commercial.capacity also includes the residuals generated by treatment of these
wastes (i.e., the quantity of generated residuals that will require treatment prior to/land
disposal). ' . - '" '
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EPA identifies the-waste streams potentially affected by the -land disposal '
restrictions -by type of land disposal unit, 'including surface impoundment; waste pile: land
treatment unit; landfill; and underground injection well. Salt dome formations, sail bed
formations, and underground mines and caves are additional methods of land disposal
that are affected by the'land disposal restrictions rulemakings.' -Since insufficient -
information is available to document the quantity of wastes disposed of by these three
methods, they are not addressed in the^analysis of.quantities and required alternative '
capacity. , '
To determine the type of alternative capacity required by the affected wastes,
EPA conducts a "treatability analysis" of each waste stream. Based on the waste's
physical and chemical form data and information on prior management practices, EPA
assigns the quantity of affected waste to the appropriate best, demonstrated available
technology (BOAT). Waste groups (i.e.,' waste streams described by more than one
-waste code) present special treatability concerns because they often contain constituents
(e.g., organies and metals) requiring different types of treatment. To treat these wastes,
EPA de%-elops 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, 'EPA has
estimated the amount of residuals that would be generated by treatment of the original
quantity of waste and has included these residuals in the quantities requiring alternative
treatment capacity. . .
1 EPA excludes from the estimate of required capacity the quantity of wastes that
are treated on site. EPA collects information to identify the availability and use of on-
stte treatment at facilities. EPA identifies the-quantities of waste requiring alternative
treatment on a facility'Ievel basis; if the appropriate treatment/recovery 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. -
v Generation and management information concerning the wastes.. was collected by
EPA during 1990 and early 1991 under the authority of section 3007 in RCRA. this
capacity analysis incorporates. data from that section 3007 information request, from the.
National Survey of Hazardous Waste Treatment, Storage, Disposal, and Recycling .
Facilities (the TSDR Survey); and from the National Survey of Hazardous Waste ,
Generators (the Generator Survey). In addition, the Agency has contacted other
facilities in order to obtain further information concerning waste generation, management
practices, and residuals. The Agency also received voluntary capacity data from several
facilities in response to the AN'PRM (56 Federal Register 24444. May 30, 1991) and in
response to the proposed rule (57 Federal Register 957 January 9. 1992). -. .
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1-.2.2 Determination of Available Commercial Treatment. ; ..
The. determination of'available capacity for this capacity analysis used data from
commercial facilities. Consequently, all estimates of capacity presented'in'this document
represent commercially available (not private) capacity."4 To'.determine whether to grant
.a national capacity.variance for newly identified wastes regulated in today's rule, EPA
analyzed available commercial capacity for alternative treatment or recovery technologies
capable of meeting the final LDR treatment standards. This capacity analysis generally
included estimating the maximum or design capacity (maximum) 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 final rule, EPA analyzed commercial capacity for hazardous.'.
waste combustion (including incineration and reuse as fuel), biological treatment,
chemical precipitation, and stabilization.. In its analysis of incineration capacity, EPA '
requested voluntary waste quantity and capacity information from major commercial
incineration firms. To assess reuse as fuel capacity, EPA analyzed ihe results of a survey
"conducted by the Cement Kiln Recycling Coalition (CKRC) in cooperation with EPA.
The CKRC is'a trade association representing cement kilns that bum wastes as fuel. For
the'remaining technologies, EPA based its capacity analysis on data compiled and
analyzed as part of the Third Third rule. (See Chapter 2 for a detailed discussion of the
data sources used for the analysis). ...
13 SUMMARY OF CAPACITY ANALYSIS CONDUCTED FOR FINAL RULE
EPA is promulgating treatment standards for certain wastes listed between -
November 1984 and June 1990 and debris contaminated with these newly listed wastes'.
To estimate the need for national capacity Variances, EPA estimated the quantities of.
waste requiring alternative treatment as a result of the land disposal restrictions and the .
capacity available at commercial treatment facilities to manage the restricted wastes. -..
Exhibit 1-3'indicates the total quantities of surface disposed (deepwell injected quantities.
are not included) wastes that will require alternative commercial treatment capacity as a
result of the final rule. ....
Exhibit 1-4 summaiizes commercially available capacity fpreach alternative
treatment or recovery technology that will be required for newly listed petroleum refining
and other, organic wastes.' This exhibit also summarizes the required capacity for each
, Available treatment capacity can be categorized by facility status into four groups: 1) commercial
capacity - capacity at facilities thai manage waste from any facility, 2) on-site (private capacity! - capacity at
facililies that manage only waste generated on-site; 3) captive capacity - capacity at facilities that manage only
waste from other facilities under the same ownership; and -t) 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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EXHIBIT 1,3
Quantities Requiring Commercial Treatment As a Result of the LDRs
^ Surface Disposed
,' Quantities Requiring
-aste Alternative Capaciiy
Code . . (tons/year) ,
' F037/8 - S.I.( 1992-93)'
F037/8 - S.I.(1993-94)
F037/8 - Routine
K107
. K10S
K109
K110
Kill . ' "
. 'K112
K117
K118- .
K123 . .
K124 ' '
K125
K126
K.131,
K132' .--
. K136
U328 --.-
' U353
U359
Mixed Rad. Waste
Hazardous Debris
.
. 173,000
. 99,000 -
69,000
0 ' . . .
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0
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1 - 10
EXHIBIT 1-4 '
COMPARISON OF REQUIRED AND COMMERCIALLY AVAILABLE CAPACITY
.FOR SURFACE-DISPOSED NEWLY LISTED PETROLEUM REEININjG AND
OTHER ORGANIC WASTES
a. a. -
2 a. ;
Technology
Biological Treatment '
Chemical Precipitation
Combustion of Liquids
Combustion of Sludges and Solids
(Cement Kilns) . '
Combustion of Sludges and Solids .'
(Commercial Incinerators)
Stabilization
Available Capacity /
(thousand tons/ year)
. . ' 188'
813
. . ' 526
'121
' . 116
1,204
- Required Capacity
(thousand tons/ year)
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' - . ' EXHIBIT 1-5
SUMMARY OF NATIONAL CAPACITY VARIANCES
FOR SURFACE-DISPOSED WASTES
Waste .
F037 Removed-Prom Surface
Impoundments
F038 Removed From Surface
Impoundments - .
F037 Managed in Surface Impoundments
F038 Managed in Surface Impoundments
Routinely Generated F037
Routinely Generated F03S
Mixed Radioactive Wastes
Hazardous Debris . ,
Final Effective Date of
.Land Disposal Prohibition
June 1994 . .
/
June 1994 . "
June .199.4
.June 1994
June 1993
June 1993 ,
June 1994 '
June 1994
generated from tanks, including equalization tanks and oil/water/solids separators (such
as CPI separators and IAF units) that are not API separators or DAF.units.
Petroleum refining wastes from surface impoundments that have not yet closed or
retrofitted will require alternative treatment to meet the LDR treatment standards. EPA
has evaluated these wastes separately from routinely generated F037/8 wastes.
Because incineration capacity for bulk solids is inadequate for treating the quantity
of F037/S wastes that will J>e removed from surface impoundments and require treatment
by incineration, EPA is granting a two-year national capacity variance for F037/8 wastes
from surface impoundments. ' . ' " ,
In the analysis of mixed radioactive wastes, EPA determined that there is currently
a treatment capacity shortfall for all mixed radioactive wastes that are surface-disposed. ' ,
Consequently, EPA is granting a two-year national capacity variance for ail.surface-
disposed mixed radioactive wastes. EPA has no information on the deepwell-disposal of
mixed radioactive wastes and, therefore, EPA is not granting a national capacity variance
for these wastes. "
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EPA is promulgating three separate treatment. options (or hazardous debris:
extraction, destruction; and immobilization. In the analysis ul" hazardous debris. EPA
determined that there will not be sufficient capacity in June 1992 to treat debris
contaminated with newly listed and identified wastes. This lack of capacity is due .
' primarily to the increased demand for destruction and immobilization capacity to treat
debris contaminated with Third Third wastes for which 'the national capacity variance
expired in May 1992. In addition, EPA has received information indicating that there is
currently insufficient permitted capacity for extraction technologies. Consequently, EPA
is granting a two-year national capacity variance for ail surface-disposed debris
contaminated with newly listed and'identified wastes covered under this final rule.
i
. For the analysis of underground injected wastes, EF'A identified no quantities of
K107, K1QS, K109, K110, K123, K124, K125, K126, KI3f>, U328, U353. and U359 that
' are currently 'being disposed via underground injection wells. Therefore, these wastes are
prohibited from injection upon the effective date of the rule. Current data- indicates that
FQ37, F03S. K117, KI1S. Kill, K112/K131, and K132 arc being underground injected by
UIC Class 1 hazardous waste injection wells. Because adequate capacity exists to
manage deep well-injected F037. F038, K112, and K112 wastes, EPA is not granting a
variance for these wastes. Comments received on the proposed rule indicate that 300
million gallons of K117, K118, K131, and K132 wastewaters are currently being deep .
well-injected. Because insufficient capacity exists to treat this quantity, the Agency is
granting a two-year national capacity variance for deep well-injected K117, K118, K131, '
and K132 wastewaters. , ' ':
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1.4 ORGANIZATION OF BACKGROUND DOCUMENT SUPPORTING CAPACITY
ANALYSIS . ,
EPA .has prepared this background document to present the capacity analysis
conducted for the final LDRs for newly listed wastes, mixed radioactive wastes, and
hazardous debris. The document is organized into seven chapters and appendices, as are
described below:
Chapter 1: Introduction . ;
Chapter 2: Commercial Treatment Capacity. Describes the methodology
and data used to determine available commercial capacity for biological
j ; treatment, chemical precipitation, combustion of liquids and solids, and
- . stabilization. , . '
Chapter 3: Capacity Analysis for F037"and F038 Petroleum Refining
Wastes. Discusses' methodology and data used- to conduct the capacity
analysis for petroleum refining wastes (F037/8).
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Chapter -4: Capacity Analysis for Other Newly Listed Wastes. Describes
the capacity analysis for organic U "wastes (U328; U353, and U359). wastes
from the production of unsymmetrical dimethylhydrazme (K107, K108,
K109, and K110), wastes from the production of dinitrotoluene and
toluenediamine (Kill and K112). \vastes from the production of ethylene
dibromide (K117, KliS, and K136), and wastes from the production of
.methyl bromide'(K131 and K132).
Chapter 5: Capacity Analysis for Mixed Radioactive Wastes. Provides the
methodology used for the capacity.analysis.of radioactive wastes mixed with
newly listed wastes for which LDRs are being promulgated in the final rule.
Chapter 6: Capacity Analysis for Debris Contaminated With Newly Listed
Wastes. Discusses the methodology and data used to conduct the capacity
analysis for debris contaminated with newly listed for which LDRs are
being promulgated in final, rule. _.'.-
Chapter.?: K061, K062, and F006 Wastes. Provides a description of the.
revisions to treatment'standards for K061, K062, and F006 in the final rule.
. Appendices A F: Appendix A provides phone logs of contacts wiih
facilities for the capacity analysis of other newly listed.wastes; Appendix B
addresses some issues and concerns related to the analysis of hazardous
debris; Appendix C contains background data on the-determination of
available incineration and. cement kiln capacity; Appendices D through F .
contain information on petroleum refineries used for estimating required
F037/8 capacity. . - . .
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CHAPTER 2
COMMERCIAL TREATMENT CAPACITY
Chapter 2 presents EPA's estimates of available commercial treatment capacity
for newly listed and newly identified wastes. Section 2.1 summarizes the results of EPA's
analysis of commercial combustion capacity at incinerators and cement kilns. Section 2.2
discusses EPA's estimate of available,cdmmercial'incincration capacity for sludges and
solids, the methodology;used to arrive at its estimate, capacity at individual incineration
facilities, planned expansions to commercial incineration capacity. Revisions resulting
from public comments received in response to the proposed rule are discussed in .
individual facility sections. These comments are summarized and discussed in detail in
Response to-Comments Background Document for the Newly Listed Wastes and 'Hazardous
Debris Proposed Rule. Section 2.3 discusses EPA's estimate of available cement kiln
capacity for sludges and solids, the methodology used to estimate available'cement kiln
capacity, each facility included in the estimate, and planned expansions of commercial
cement kiln capacity. Section 2.4 discusses capacity for commercial treatment other than
combustion, including stabilization, biological treatment, and chemical precipitation.
2.1 COMMERCIAL COMBUSTION CAPACITY SUMMARY
This section summarizes the results of EPA's analysis of commercial combustion
capacity at incinerators and cement kilns^as EPA expects the majority of treatment
capacity for newly listed wastes to come from cement kilns and incinerators. Exhibit 2-1
summarizes EPA estimates of commercial hazardous waste capacity by waste form and
facility. Exhibit 2-2 lists the incineration facilities included in the commercial combustion
capacity estimate, along with the waste forms each facility can burn. Each of these
facilities is discussed in greater detail in section 2.1.2. Esthibit 2-3 lists the cement kilns
included in this capacity update, and ths types of wastes accented at each" facility. Each
of these facilities is discussed in greater detail in section 2.2.3. Exhibit 2-4 is a map
showing the location of cement kilns and incinerators 'considered.in EPA's estimate of
commercial sludge and solid hazardous waste burning capacity in May 1992. Specifically,
.the map shows all cement kiln and incinerator facilities with available capacity that were. .
included, in the capacity estimates. Two incinerator facilities on the map, LWD, Calvert
City,.Kentucky, and Chemical Waste Management, Chicago, Illinois, were not included in
the capacity estimates due to permit disputes with state regulatory authorities which .
make their future operating status uncertain. .
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Exhibit 2-2 '
' Incinerators Included in May 1992 C;ipaciJy Estimate
Facility Name and Location J Types of Wastes Burned ,
Aptus, Coffev-\i!Ie, KS
Aptus, Tooele, UT
Chemical Waste Management
Port Arthur; TX
Chemical Waste Management
Sauget, IL . .
ENSCO, El Dorado, AR
Rhone-Poulenc Basic Chemicals
Baton Rouge, LA >
Rhone-Poulenc Basic Chemicals
Houston, TX
Rollins Environmental Services
Baton Rouge, LA
Rollins Environmental Services
Bridgeport, NJ . -
Rollins Environmental Services . .
Deer Park, TX .. / ,
Ross Incineration Services, Grafton, OH
ThennalKEM, Rock Hill, SC
liquids, containerized solids, bulk solids
liquids, containerized solids, bulk solids
pumpahlc sludges, nonpumpable sludges,
containerized solids, bulk solids
liquids, pumpable sludges, nonpumpable
sludges, containerized solids, bulk solids
liquid.-;, .\ludges and solids
liquids, pumpable sludges
liquids, pumpable sludges ' ,
liquids, pumpable sludges, containerized
solids :
liquids, pumpable sludges, containerized .
solids
liquids, pumpable sludges, containerized
solids, bulk solids
liquids, nonpumpable sludges,
containerized solids, bulk solids
liquids, pumpable sludges, nonpumpable
sludges, containerized solids, bulk solids
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2-4
.. Exhibit 2-3
Cement Kilns Included in May 1992 Capacity Estimate
Facility Name and Location Types of Wastes Burned
Ash Grove Cement, Chanute,.KS
Ash Grove Cement,. Foreman, AR -
Ash Grove Cement, Louisviite, NE
ESSROC Cement Group, Logans port.. IN
Giant Cement, HarleyviHe, SC
Heartland Cement, Independence, KS
Keystone Cement, Bath, PA
Lafarge,.AJpena, MI
Lafarge, Demopolis, AL
Lafarge, Fredonia, KS
Lafarge, Pautding, OH
Lone Star Industries, Green Castle, IN
Medusa Cement, Wampum, PA
National Cement, Lebec, CA
River Cement, Festus, MO
.San Juan Cement, San Juan, PR
Southdown, Fairborn, OH
Southdown, Knoxville, TN
liquids,' containerized sclids .
liquids, containerized solids
liquids,^ containerized solids
liquids, containerized solids
liquids, dry solids
drv solids ' - . '
liquids
liquids
liquids
liquids, dry solids
liquids
liquids, containerized solids
liquids, purnpable sludges, nonpumpable
sludges
liquids ' . ;
liquids, pumpabie sludges, nonpumpable
sludges t
liquids .
liquids ' , " -
liquids, containerized solids
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2.2 COMMERCIAL INCINERATION CAPACITY' -'
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; This section focuses on the combustion capacity of the nation's commercial
hazardous waste incinerator facilities. Sections 2.2.1 discusses how EPA collected and
analyzed information. Section 2.2.2 discusses capacity at individual facilities. Section
2.2.3 discusses'sludge and solid incineration capacity additions planned for 1992 to 1994.
Phone logs documenting calls to incineration facilities are in Appendix C.
2.2.1 General Approach and Assumptions
To support its'capacity analysis for newly listed and newly identified wastes, EPA '
'contacted currently operating hazardous waste incineration companies prior to the , -
proposed rule to update the Agency's available capacity estimates for RCRA hazardous
sludges and^solids. For this analysis, EPA categorized hazardous waste into the following
forms: liquids, pumpable sludges, nonpumpable sludges, containerized solids, and bulk,
.solids. Since the proposed; rule,'EPA :has incorporated information contained in public
comments on the proposed rule, and collected additional data to resolve specific issue's
raised in public comments. . .
Analysis for the Proposed Rule . , '
'..',-
/ '
Commercial-hazardous waste incineration firms that can incinerate sludges and
vsolids were contacted prior to the proposed rule and asked if they would be willing to
participate in a voluntary capacity update. The companies that responded to the capacity
update were Aptus, Chemical Waste Management, Ross Incineration Services,
ThermalKEM, Rhone-Poulenc, and Rollins. In August 1991, these companies were sent
a capacity guideline form indicating the types of information EPA could use in its
'capacity analysis. To arrive at accurate facility estimates, EPA requested both facility-
specific and unit-specific information including permit status, number of incinerator units
currently operating and expected to operate by 1994, acceptable physical form of
receiving wastes, acceptable RCRA waste codes, maximum bromine limits (high bromine
concentrations are characteristic of K117 and K118 waste), and future changes to the
facility that may increase or decrease capacity. Unit specific questions included: type of
unit, thermal rating, annual ave'rage operating hours, feed mechanisms, waste- burned in
first half of 1991, permitted waste-feed capacity for each form of waste, and practical.
waste feed capacity for each form of waste. Capacity guideline forms submitted by ''
hazardous waste incinerator facilities are in Appendix C.' Responses from facilities
requesting that their capacity information be maintained as Confidential Business
Information are also in the docket, in a separate document entitled Background Data Set
for Commercial Hazardous Waste Incinerator Capacity Analysis - Confidential Business
Information. ' ". ...
To estimate maximum and available capacities, EPA used unit-specific capacity
information including average operating hours per year, .RCRA hazardous waste volume
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burned in the first half of 199!, permitted maximum waste feed capacity; and practical
waste feed capacity. EPA categorized wastes into the following -forms: liquids, .pumpable
sludges, nonpumpable sludges, containerized solids, and bulk solids.
/
' . Data submitted by each facility varied in detail. All facilities reported waste
volumes burned during the first half of 1991, and indicated that these volumes were
typical for the year: Therefore, EPA estimated annual utilization by multiplying the
volume of waste burned in the first half of 1991 by' two.
EPA estimated practical yearly maximum capacities for each waste form using
several methods, depending on the information provided by each facility. Several
facilities submitted both practical and permitted waste feed capacities. If the permitted'
and practical capacities differed, EPA used the lower of the two reported capacities.
Some facilities reported capacity estimates in pounds per hour. EPA converted hourly
estimates to yearly estimates by multiplying them by average operating hours per year. If
the facility did not report average operating hours per year, EPA assumed a typical
operating year of 7,200 hours; Some -facilities reported lota! capacities, but did not
distinguish between specific waste" forms. EPA distributed total capacity estimates into
.specific waste forms based on volumes of each waste form burned in 1991. -
^ ..''
EPA adjusted reported maximum practical capacities using reduction factors for,
two different scenarios. Reported capacities for new facilities were reduced by 50 -
percent to account for the likelihood that new capacity will experience start-up delays. It .
is EPA's experience that such start-up delays are common for new incinerators (e.g.
Chemical Waste Management's Port Arthur facility.) Capacity estimates at existing
facilities were reduced by 10 percent to account for the likelihood that not all facilities
will achieve their reported maximum, capacity. To determine adjusted available capacity,
EPA subtracted utilized capacity from adjusted maximum practical capacity. The
following hypothetical example indicates how EPA used reported information to arrive at
adjusted available capacity estimates.
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Facility Information: ' ,
Operating Status:
Operating hours per year:
Maximum practical capacity:
Waste volume burned during first half of 1991:
existing facility
unreported
25,000 ibs/hour
6,500 tons liquids,
3,500 tons containerized solids,
10,000 tons bulk solids
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25,000 ibs/hour x (1 ton/2,000 Ibs) x (7,200 hours/year), = 90;000 tons/year
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Calculate practical svaste feed capacities for .each specific waste form.
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(a)
Annualize utilized capacity by multiplying the waste'volume burned in the
first half of 1991 Bv two.'
Liquids:
Pumpable sludges:
Nonpumpable sludges:
Containerized soiids:
Bulk Solids:
Total:
(6,500 tons x 2) =
(3,500 tons x 2) =
nO.OOO tons x 2)=
13,000 tons
0 tons
0 tons
7,000 tons
20,000 tons
40,000 tons
(b) Calculate waste ratios based on-current burning practices by dividing
utilized capacity for each waste form by.total utilized capacity.
Liquids:
Containerized solids:
Bulk solids:
(13,000 tons/40-,000 tons) = 32.5%
(7,000 tons/40,000 tons)= 17.5%
(20,000.tons/40,000 tons)= 50:0%
(c) ' Distribute reported total 'practical capacity among specific waste forms by
multiplying waste ratios for each type of waste by total waste capacity.
i, . .' , ". '
Liquids: 32.5% x 90,000 tons/year = 29,250 tons/year
Containerized solids: 17.5% x £0,000 tons/year = 15,750 tons/year
Bulk solids: 50.0% x 90,000. tons/year = 45,000 tons/year
3. Adjust reported 'practical capacities by 10% reduction factor for existing facilities.
Liquids:
Containerized solids:
Bulk solids:
29,250 tons/year x 90% =
15,750 tons/year x 90% =
45,000 tons'/year x 90% =
26,325 tons^ear
14,175 torts/year.
40,500 tons/year
Calculate available capacity by subtracting utilized capacity from maximum
" capacity. . "
Liquids:
Containerized solids:
Bulk soiids:
,29,250 - 13,000 tonsftear = ,
15,750- 7,000 tons/year =
45,000 - 20,000 tons/year =
16,250 tons/year
'8,750 tons/year
. 25,000 tonsftear
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Calculate adjusted available capacities by subtracting annual utilized capacity from
adjusted practical capacities. . . " .
' Liquids:
Containerized solids:
1 Bulk solids:
26,325 - 13,000 tons/year
14.175 r 7,000 tons/year
40,500 - 20,000 tons/year
13,325 tons/year
7,175 tons/year
20,500 tons/year
Revisions to the Analysis since the Proposed Rule
EPA received several public comments on the proposed rule regarding v -
commercial.incineration capacity2. As a result of information and issues contained in
public comments, EPA revised its capacity estimates for the following incinerators:
Rollins, Deer Park; Texas; Chemical Waste Management, Port'Arthur, Texas; and Aptus,
Tooele, Utah. Specific changes to these estimates are discussed in Section 2.2.2 below,
and background documentation for these changes is provided in Appendix C,
After the.public comment period ended, EPA received additional capacity
information from the Hazardous Waste Treatment Council. Even though it was received
well after the comment period closed, EPA reviewed the information to determine
whether it could potentially affect EPA's variance 'decision. Based on review of the
information,,EPA determined that it could not use the information as received because it
was not company- or facility-specific, it was not presented at a level of detail that would
have allowed it to be compared to other information on which EPA's capacity analysis
was based (e.g., whether capacity was from pumpable sludge, bulk solids, or container
systems), and it was unclear 'how HWTC defined available.
EPA contacted HWTC to clarify the information (telephone logs documenting
these calls are also in Appendix C). In response, HWTC provided confidential company-
specific information. HWTC also noted that it was not clear whether reported excess
capacity was already committed by current contracts to other .wastes, or what specific ;
.waste feed systems (e.g., bulk solids versus drums) were accounted for in the estimates.
Because of these limitations and the fact the company-specific data were not faciiity-
specific, EPA was unable to reconcile the new information with that already used.in the
analysis. Although time constraints precluded EPA from clarifying details of this new
information, EPA does not believe that it would have changed EPA's variance decision
because EPA has already received more detailed capacity information from each of the
firms'included in the HWTC data. The only new facility noted in any communication :
with EPA is a lightweight aggregate kiln which, although it is permitted as a hazardous
waste incinerator, is subject to product-quality based minimum waste heating value
constraint of about 5,000 BTU/lb. EPA believes that, like cement kilns, this facility
For a detailed discussion of public comments pertaining to commercial incineration capacity, refer to
Chapter 2 of Response to Comments'Background Document for Phast One Lund Disposal Resaicnons Proposed
Rule. '.-.-'.
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cannot reduce the required bulk solids incineration capacity for incineration of !o\v-BTU
wastes. .
2.2.2 Individual Incineration Facility Capacity Analysis ' ' '
Exhibit 2-5 presents utilized, maximum, and available, capacity for each unit at each
commercial incineration facility. As indicated'by Exhibit 2-5, EPA estimates that roughly
116,000 tons per year of commercial sludge/solid incineration capacity was available as of
May 1992 (51,000 tons pumpabie sludges, 1,000 tons nonpumpable sludges, 4!,000 tons
containerized solids, and 23,000 tons buik solids).' Thist section summarizes the specific
method and results for each commercialhazardous waste incinerator included in the
capacity analysis. This section includes capacity information received by EPA between
the proposed and final rules.
Aptus, Coffeyville, Kansas ' .
Aptus, a Westinghouse company, has a TSCA-and RCRA permit. The'incinerator
unit is a slagging rotary kiln with a maximum permitted Heat release of 61.9 MBTU/hour.
This facility can process several physical forms of waste. Liquids are directly
injected into the rotary kiln. Containerized solids are ram-fed into the rotary kiln.
Recycle feed anddrop feed systems are used to feed bulk solids into the incinerator unit.
Prior to July 1991, this facility burned only PCB contaminated wastes. It is currently
working to expand its RCRA v/aste receipts and the firm intends to distribute its capacity'
between TSCA and RCRA wastes based on market conditions.
Capacity information' provided by the facility included the total hourly maximum
permitted capacity and the.maximum hourly permitted capacity for solids. Based on
discussions with facility managers, EPA estimated the maximum practical capacity to be.
80'percent of the maximum permitted capacity. EPA estimated that 50 percent of
maximum practical capacity could be devoted to burning RCRA waste by May 1992, and
considered this capacity as new capacity. Consequently, 20 percent of the reported
permitted solids capacity was considered available for RCRA wastes (80 percent of the
permitted limit is practical x 50 percent of practical capacity for RCRA wastes x 50 ,
percent -adjustment for new capacity).
, / -
This facility is permitted to accept'F037, F038, K117, and K118. The facility
reported that there is no bromine limit, but its permit does limit total halogen feed.to
l,9QQlbs/hour. This facility does not accept K048-52. This was a management decision .
rather than a technical restriction, and the facility is currently investigating whether it will
accept F037 and F038. EPA did not revise its estimate of the facility's available capacity
because it is able to take F037 and F038. If it does not burn F037 and F038, it can
accept other bulk solids and would therefore be able to accept wastes that are currently
ff
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2-11 '
EXHIBIT 2-S
of - rr
ft S f>
a < * *
SUMMARY OF. COMMERCIAL SLUDGE/SOLID INCINERATION CAPACITY THROUGH 1992. .
FACILITY NAME
APTUS ' ,
COFFEYVILLE, KS
KS0981506025
/
' N
APTUS (WESTINGHOUSE)
TOOELE. UT '
CHEMIQAL WASTE MANAGEMENT
SAUGET, !L
ILD098642424
UNIT .'
. TYPE
RK
WASTE
TYPE
LIQ
PUMP. SL.
NPU. SL.
CONT. SOL.
BULK SOL.
FACILITY TOTAL '
RR
.
LIQ
PUMP. SL.
NPU. SL
CONT. SOL.
BULK SOL
FACILITY TOTAL
FH
LIQ
PUMP. SL
NPU. SL.
CONT. SOL.
BULK SOL
UNIT TOTAL
FH
LIQ
PUMP. SL
NPU. SL.
CONT. SOL.
BULK SOL.
UNIT TOTAL
FH
LIQ
PUMP. SL.
NPU. SL
CONT. SOL
BULK SOL.
UNIT TOTAL
1991
UTILIZED ,
CAPACITY .
(TONS/YR)
.' 0
0
0
0
0
. o
0
-
CBI
CBI..
CBI
CBI
'CBI
CBI
CBI1
CBI
CBI '
CBI
"CBI'
CBI
csi
CBI
C8I
CBI
CBI
CBI
MAY 1992
ESTIMATED
MAXIMUM '
CAPACITY
(TONS/YR)
7,221
0
o
2.500
2,500
12,221
' SEE NOTE
0
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI -
CBI
CBI .
CBI
. CBI
CBI
CBI
CBI
CBI
CBI
CBI
MAY 1992
ESTIMATED
AVAILABLE
CAPACITY
(TONS/YR)
7,221
0
0
2,500
2,500
12,221
3ELOW *
,0
CBI
CBI
CBI .
CBI
CBI
CBI
CBI:
CBI
CBI
CSI
CBI
CBI
CBI
CBI
CBI
CBI
CSI
CBI
»
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2-12
EXHIBIT 2-5 (CONTINUED)
SUMMARY OF COMMERCIAL SLUDGE/SOLID INCINERATION CAPACITY THROUGH 1992
FACILITY NAME
'!
CHEMICAL WASTE MANAGEMENT
SAUGET, IL
ILD098642424
(CONTINUED)
' '
CHEMICAL WASTE MANAGEMENT
FORT ARTHUR, TX
TXDQ083889S
'
j
ENSCO
ELDORADO, AR
ARD069748192
. . ' '
'
' *
,
>
UNIT
-TYPE '
MRK'
-
WASTE
TYPE
LIQ '
PUMP. SL.
NPU. SL.
CONT. SOL.
BULK SOL
UNIT TOTAL
FACILITY TOTAL
HK
LIQ
PUMP. SL
NPU. SL.
CONT. SOL.
BULK SOL.
FACILITY TOTAL
RK
t 4 *
LIQ
PUMP. SL.
NPU. SL.
CONT. SOL-
BULK SOL.
UNIT TOTAL
RK .
LIQ
PUMP. SL.
NPU. SL.
CONT.'SOL.
BULK SOL.
UNIT TOTAL
MRK
' '
LIQ
PUMP. SL.
NPU. SL
CONT. SOL.
BULK SOL
UNIT TOTAL
FACILITY TOTAL
1991
UTILIZED
CAPACITY
(TONS/YR)
1 CBI
C8I
CBf
CBI
CBI
CBI
CBI
. CBI ,
CBI
CBI
CBf .
CBI
car
32,076
32.076
0
/
/
11,664
1 1 ,664
43.740
MAY 1992
ESTIMATED
MAXIMUM
CAPACITY
(TONS/YR)
CBI
CBI
CBI
CBI
CBI
CBI '
CBI
.CBI
CBI .,
CBI
CB!
CBI
CBI
35.640
35.640
o
12,960
12,960
48,600
MAY 1992
ESTIMATED
AVAILABLE
CAPACITY
(TONS/YR)
CBI
CBI
. 'CBI
CBI
CBI
CBI
CBI ' .
CBI
' CBI
CBI
' ' CBI
CBI '
CBI .
' -
3,564
3.564
, \
0
t
1,296
1,296
4,860
» "
3-2.
X o
-------
2- 13
EXHIBIT 2-5 (CONTINUED)
SUMMARY OF COMMERCIAL SLUDGE/SOLID INCINERATION CAPACITY THROUGH 1992
j
.
1\
\ . .
" \
FACILITY NAME
RHONE-POUIENC
jBATON ROUGE.'LA ,
LAD003161234
'"
1 \
RHONE-POULENC -
HOUSTON. TX
TXD008099079
ROLLINS ENVIRONMENTAL
BATON ROUGE, LA
LAD01 03951 27
'
ROLLINS ENVIRONMENTAL -
BRIDGEPORT, NJ
NJOOS3288239 , , "
UNIT
.TYPE-
SR
.WASTE
TYPE
LIQ
PUMP. SL.
NPU. SL
CONT. SOL.
BULK SOL
UNIT TOTAL
SR
LIQ
PUMP. SL
NPU. SL. .
CONT. SOL,
BULK SOL.
UNIT TOTAL
FACILITY TOTAL
SR
LIQ
PUMP. SL
NPU. SL. '
CONT. SOL
BULK SOL.
FACILITY TOTAL
RK
LIQ
PUMP. SL
NPU. SL.
CONT. SOL
BULK SOL.
FACILITY TOTAL
RK
LIQ
PUMP. SL.
NPU. SL
CONT. SOL
BULK SOL
FACILITY TOTAL
/
1991
UTILIZED ;
CAPACITY
(TONS/YR)
CBI .
C8I
CBI
' ' CBI
CBI
CBI
CBI ,
CBI
CBI
CBI
CBI
CBI *
CBI
CBt
CBI
CBI -
CBI
CBI
CBI
26,281
1.592
. \ . 0
10,445
, 0
38.318
26,457
2,532
0
9^016
0
38,005
MAY 1992
ESTIMATED
: MAXIMUM
CAPACITY
(TONS/YR)
CBI
CBI
CBI
"CBI
C8I
. CBI
CBI
CBI
CBI '
CBI
CBI
CBI
CBI
CBI
C8I. .
CBI
CBI
. CBI
. CBI
43,797
2.606
0
17,162
0
63,564
30,699
4,052
0
14.367
0
- 49.118
MAY 1992
ESTIMATED
AVAILABLE
CAPACITY .
(TONS/YR)
- CBI
CBI
CBI
-. CBI
CBI
CBI '
CBI
' CBI
CBI '
CBI
CBI .
CBI
CBI
CBI
CBI
C8I
CBI
CBI
CBI
' 17,516
1,014
0
6,717
0
25.246
. 4.242
1.520
0
5.351 '
0
11.113
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2- 14
EXHIBIT 2-5 (CONTINUED)
.-» re a
SUMMARY OF COMMERCIAL'SLUDGE/SOLID INCINERATION CAPACITY THROUGH 1992
1
FACILITY NAME
ROLLINS ENVIRONMENTAL ,
DEER PARK, TX
TXD055141378 .
*
\
.
-
/
-
ROSS INCINERATION SERVICES
GRAFTON, OH
OHD04841S665 "
THERMALKEM
ROCK HILL, SC
SCD044442333
UNIT
TYPE
' RK
CP
1 -j 1991
WASTE
TYPE
LIQ
PUMP. SL
NPU. SL.
CONT. SOL.
BULK SOL.
UNIT TOTAL
RK/RR
CP
LIQ
PUMP. SL.
NPU. SL. .'
CONT. SOL.
BULK SOL
UNIT TOTAL -
FACILITY TOTAL
CBI-
LIQ
PUMP. SL
NPU. SL
CONT. SOL.
BULK SOL'
FACILITY TOTAL
FH
LIQ ,
PUMP..SL.
NPU. SL
CONT. SOL.
BULK SOL.
FACILITY TOTAL.
UTILIZED
CAPACITY
(TONS/YR)
25,500
8,500
0
17,000
. 0
51.000
23,800
11.050
0
16,575
18.615
70.040
121,040
CBI -
CBI
CBI .
CBI
C8I
CBf '
. CBI
CBI
cai"
cat
CBI
' CBI /
MAY '1992
ESTIMATED
MAXIMUM
CAPACITY
(TGNS/YR)
39.098
13,033
0
26,066
0
78,197
37,427
17,377
o-
* 26,066
35,103
115,973
194,170
CBI
CBI-
CSI -
CBI
CBI
CBI
. CB!
CBI
"' CBI
CBI
VCBI '
CBI
MAY 1992
ESTIMATED
AVAILABLE
CAPACITY
(TONS/YR)'
13.598
' 4,533
0
" 9,066
0
27.197
13,627
- 6,327
0
9.491
16.488
- 45,933
73,130
CBI
. CBI
CBI
. CBI
CBI
CBI
CBI
CBI
CBI \
CBI
CBI
CBI
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"2- 15
EXHIBIT 2-5 (CONTfNUED)
SUMMARY OF COMMERCIAL SLUDGE/SOLID INCINERATION CAPACITY THROUGH 1992
FACILITY NAME
7 'AGGREGATE CBI
[TOTAL LIQUID
[TOTAL PUMPABLE SLUDGES
[TOTAL NONPUMPABLE SLUDGES
ITOTAL CONTAINERIZED SOLIDS
[TOTAL BULK-SOLIDS
JTQTAL (TONSA'EAR)
UNIT
TYRE »
WASTE
TYPE '
LIQ.
PUMP. SL. .
NPU'SL.
CONT. SOL.
BULK SOL
TOTAL CBI
NOTES:
Some totals may be inexact due to rounding errors.
1991
.UTILIZED.
CAPACITY
(TONS/YR)
77,196
42.634
2,200
40,016
30.978
1.93,024
179,234
66,308
2,200
136,792
49.593
MAY 1992
ESTIMATED
MAXIMUM
.CAPACITY
fTONS/YH)
192,900
80,286
3,120
43,084
35,424
354,813
351.142
117,333
3,120
177,844
73,027
434.127
722,486
MAY 1992-
ESTIMATED
AVAILABLE
CAPACITY
(TONS/YR)
'115,704
37,652
920
3,068
4,446
161,789
171,908
51;045
920
41,052
23,434
288,359
UNIT TYPES:
CP a Concrete Pump
- FB = Ruidized Bed
'. FH = Fixed Hearth Kiln
IR = Infrared Unit
. LI'= Liquid Injection
MRK = Mobile Rotary Kiln
RK = Rotary Kiln (often include liquid injection ports)
RR = Rotary Reactor .
SR a Sulfur Recovery Furnace . '
* NOTE * EPA assumed no available capacity for this facility because it has yet to receive approval
ot its trial burn results, and its permit modification for F037 and F038. -
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2- !6
going to facilities that take F037 and F03S. thereby frct/ini: capacity.- nt these facilities, '
This facility reported'no plans to change capacity within the next three years.
Aptus, Toncle, Utah . . .''.
This new facility received a RCRA Part B permit in March 1990 that allowed the
construction of the incinerator and .waste storage buildings. The final permit will be
issued pending successful trial burns conducted in May 1 W2 (at the time of the proposed
rule, trial burns were scheduled for January- 1992). Aptus also has applied for a TSCA
permit to burn PCS contaminated waste. The incinerator system at this facility is a
slaszcing rotary kiln with an afterburner. This system hns a total heat release of 120
MBTU/hour. - ' '' . ' '
This facility will be equipped with several mechanisms for feeding waste into the
slagging rotary kiln. Liquids will be injected directly from a storage tank into the kiln
and/or afterburner chamber. Pumpable sludges, having a viscosity lower than 10,000
centipoise, will be fed via a cement pump'. Bulk solids and nonp'umpable-sludges wiil be
placed into holding tanks. From these tanks, the waste will bs moved by a clamshell to
an apron feeder where the waste wiil be fed'directly into ihu kiln feed chute.
Containerized solids that do- not require shredding (e.g., soils) will be fed directly into the
kiln via' an elevator feed system. Containerized solids and hulk solids that require
shredding will be processed through a shredder prior to being" placed into storage tanks." -'
During its'shakedown period, the facility is accepting petroleum refining wastes for bulk
solids incineration. They rejected one load in a tanker intended for pumpable, sludge .
incineration because it was too viscous for the pumpable sludge feed system. The facility
indicated petroleum refining wastes in drums could also be fed through its containerized ,
solids feed system. - .
* '
Capacity information provided by .the facility included hourly maximum permitted
and hourly maximum practical capacities. The facility reported that. its entire capacity
could be dedicated to RCRA wastes if warranted by demand. Because this facility. did
,not have final approval of permitted operating parameters, and required a permit'
modification for F037 and FQ38 at the time of the final rule, EPA-did not include its
capacity in its May 1992 capacity estimate of available capacity. for F037 and F038.
Aptus, Utah, expects to add F037 and F038 to its permit in August 1992. The
facility is currently permitted to b'urn KI17 and K118 wastes. The maximum permitted
bromine feed 'rate at this facility is 4,100 Ibs/hour. This f.'icitity reported plans to add
storage capacity in coming years if warranted by demand, but it does not currently, plan
to add incineration capacity. ' ' ,
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2'- 17
Chemical Waste Management (Trade Waste Incineration), Sauget, Illinois
This RCRA-permitt'ed facility operates four incinerator units. 'Three of the units
are of the fixed hearth design. Two of these units have maximum permitted heat
releases of 16 MBTU/hour and'one has a maximum permitted heat release, of 14 <
MBTU/hour. The fourth unit, a rotary kiln, has a maximum permitted heat release of 50
MBTU/hour. "''.-. ' ...
.This facility can accept all physical forms of wastes. Liquids are blended in tanks
and transferred to atomizers for direct injection into the incinerator unit(s). "Pumpable
'sludges are injected into the incinerator unit(s) via a sludge lance! Nonpumpable sludges
and containerized solids are repackaged into burnable containers and ram-fed into the
incinerator units. Bulk solids are unloaded into pits and transported via clamshell into
the rotary kiln unit.
For each unit, this facility provided waste volumes .burned during the first half of
1991, total hourly maximum permitted and practical waste capacities, and hourly -
maximum permitted and practical waste capacities for each physical form of waste. EPA
v applied the standard 10 percent reduction factor to the maximum capacity of this facility.
Chemical Waste Management requested that capacity data submitted for this facility be
classified as Confidential Business Information. Capacities for each accepted waste form'
are included in .the aggregate CBI capacity estimates.
This facility can accept F037, F038,'Kll7,.and K1I8. Bromine in the feed is kept
below 0.5 percent due to operational constraints. . '
Chemical Waste Management reported that it may build a mate Hal processing
. facility that'would increase its containerized solid processing capacity, but it would not
increase overall incineration capacity.
Chemical Waste Management, (SCA) Chicago, Illinois
This RCRA Interim Status-and TSCA-permitted facility is not currently operating
due to operational and permit problems. EPA did not include this facility's capacity in
its national commercial incinerf.tor capacity estimate due .to the facility's current
operating status, and uncertainty regarding future operation at the facility. The
incinerator unit at this facility is a rotary kiln with a maximum heat release of 120
MBTU/hour. ' . ' . . . '
The feed mechanism for this unit consists' of a drum conveyor and ram-feed for
containerized solids. In general, bulk solids and pumpable sludges are not accepted at
this, facility. Nonpumpable-sludges.are generally accepted only as containerized solids.
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.2-18 _ "...
The facility submitted waste volumes burned in tlic first half of 1991.-hourly -
maximum waste. capacities for liquids .and containerized solids (limited due to Interim
Status conditions), and estimated hourly maximum pr;ictit;il waste capacities-for liquids-
and containerized solids.- Chemical1-Waste Management requested that capacity data for
this facility-be classified as Confidential Business Information.
' Due to Interim Status restrictions; F037, F03S, Kl 17. and K11S waste will not be
accepted at the facility when it becomes operational. In addition, operational constraints
will limit amount of bromine to be burned to 10,000 Ihs/ycar.
Chemical Waste Management reported that this facility's expansion plans will
depend on the outcome of final permitting decisions. .
Chemical Waste Management, Port Arthur, Texas
This RCRA-permitted facility operates a rotary kiln system'that Has an overall
maximum permitted heat release'of 150 MBTU/hour. The facility has applied for a
TSCA permit in order to burn PCB.contaminated wastes. '
This facility can
-------
2- 19
Chemical Waste Management indicated this facility plans to add storage capacity,
a magnetic separator, and a processing building which will increase operating efficiency
and maximum practical throughput capacity over.the next year.
ENSCO, EL Dorado, Arkansas
This facility did not participate in the voluntary capacity update. For this analysis,'
EPA applied the standard 10 percent reduction factor to maximum sludge and solid
capacity estimates from the Third-Third rule3. Lacking current utilization data, EPA .
conservatively estimated that 90 percent of this'facility's maximum sludge and solid
capacity is utilized, and that this capacity is for containerized wastes.
L.W.D. Inc., Calvert City , Kentucky .
i' ^
This Interim Status facility was dented a Part B permit by the state regulatory agency.
LLW.D. Inc. appealed the.decision and will continue to operate underlnterim Status
while the appeal is processed in court. EPA did hot include the facility in the
commercial hazardous waste incinerator capacity update due to the uncertainty of its ,
future operating status. . .
Rhone-Poulene Basic Chemicals Company (formerly StaufTer Chemical
Company), Baton Rouge, Louisiana ' , .
This RCRA-permitted facility operates two sulfuric acid regeneration furnaces
rated at 180 MBTU/hour each. This facility can accept liquids and piimpable sludges.
The pumpable sludges must either be.slum'ed or have a sufficiently low viscosity to be
injected into the.fumace. This facility currently receives K04S-52 from 3 major refineries,
and is in'the process of approving waste profiles for several additional refineries. Some
DAF float (K048) is also carrying the F037 and F038 codes. The.Baton Rouge plant
.received 14,000 tons of petroleum refining wastes in 1991; which it incinerated as,
pumpable sludge. . .
Rhone-Poulenc submitted average.operating hours, waste volumes burned-in the
first half of 1991, and hourly maximum .permitted and practical waste feed capacities.
EPA reduced reported available pumpable sludge capacity by 60 percent to account for
-this facility's relatively low solids content and viscosity limits relative to the types of
sludges and solids included in today's final rule. EPA applied the.standard 10 percent
reduction factor to the maximum capacity of this facility, Rhone-Poulenc requested that
s- rT '
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-------
' ' 2-20' '
capacity data for this facility be'classified as Confidential Business Information.
Capacities for each accepted waste form are included in the aggregate CBI capacity
estimates.
This facility can accept F037, F033, K117, and K11S. No bromine limits are
imposed an wastes accepted by this facility. . ' ,' ,
' J
Rhone Poulenc's Baton "Rouge facility is limited by its storage capacity, and for
petroleum refining wastes by the fact that it only accepts pumpable wastes in tanker
trucks. Under current constraints, the Baton Rouge facility'could accept about one third
more petroleum refining wastes than it is currently receiving. The facility plans to '
complete a 157,000-gallon tank in October 1992. This tank will increase the facility's
practical throughput capacity. '
Rhone-Poulenc Basic Chemicals Company (formerly Stauffer, Chemical
Company), Houston, Texas '
This RCRA-permitted! facility operates one suifuric acid regeneration furnace
rated at ISO MBTU/hour. TruYfacility can accept liquids and pumpable sludges. The
punipable sludges must either be slurried or have a sufficiently low viscosity to be
injected directly into the furnace. '',:'
Rhone-Poulenc submitted average operating hours, waste volumes burned in the
first half of 1991, and hourly maximum permitted and practical waste feed capacities.
EPA recfuced reported available pumpable sludge capacity by 60 percent to account for
this facility's relatively low solids content and viscosity limits relative to the'types of
sludges-and solids included in today's final rule. EPA applied the standard 10 percent
reduction factor to the maximum capacity of this facility. Rhone-Poulenc requested that
capacity data for this facility be classified as Confidential Business Information.
Capacities for each accepted waste form are included in the aggregate CBI capacity -
estimates. '
This facility can accept F037, F038, K117, and K118. No bromine limits are
imposed on wastes accepted by this facility. ' .
This facility plans to expand its storage capacity by constructing additional '
blending tanks, but reported no .plans to increase.its burning capacity.
Rollins Environmental Services, Baton Rouge, Louisiana .
This incinerator facility operates under Interim Status. The facility has submitted a
RCRA Part B application which is. pending approval from the Louisiana Department of
Environmental Quality. This facility's integrated system consists of a rotary kiln, Loddby
(liquid) burner, and an afterburner. The total heat release from the train is limited to
."=f5
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. 2-21
95.6 MBTLJ/huur. Interim Status operatin^'requirements limit the facility's maximum
feed rate to 21.732 Ibs/hour and 70,627 tons/year. " '
Severn! mechanisms are used to iced waste into ilic incinerator system. Liquids
are atomized under air pressure and injected into the Loddby liquid burner and',,
afterburner cha'mher. A positive displacement pump feeds pumpable sludees into the
rotary kiln. N'onpumpable sludges are" usually accepted only in containers^and are fed .
into the unit via a"conveyor belt. This facility generally di'ics not accept bulk solids.
/ ' ' '
' Capacity information provided by the facility'included the waste volumes burned
during the first half of 1991, average operating hours per year, and the hourly total
. maximum waste feed capacity (limited due to Interim Status conditions).. The facility
N indicated that the hourly totai practical waste feed.capacity equals hourly total maximum
waste fee'd capacity. EPA determined hourly practical-maximum capacities for each
svaste form by distributing the total limit according to the ratii) burned in the first half of
. 1991. EPA applied the standard 10 percent reduction factor, to the maximum capacity of
this facility. The facility indicated that "final permit conditions may affect its future
capacity, but is uncertain whether permit conditions will increase or decrease capacity.
This facility can accept "F037, F03S, K117, and Kl 18; and has a bromine"
acceptance limit of 34 Ibs/hour.
. Rollins Environmental Services, Bridgeport, New Jersey
This RCRA-permitted facility includes a rotary kiln, Loddby (liquid) burner, and
an afterburner. The total heat release from the system is 115 MBTU/hour. The facility
has a.maximum permitted waste feed rate of 15,575 Ibs/hour.
Several mechanisms are used to feed waste into the incinerator system. Liquids
are atomized under air pressure and injected into the Loddby liquid burner and
afterburner chamber., A positive displacement pump feeds pumpable sludges into the
rotary kiln. Nonpumpable sludges are generally accepted only in containers and are fed
into the unit via a conveyor belt. This facility generally does not accept bulk solids. " -
This facility submitted hourly maximum practical waste capacities for each waste
form. Because the facility did'not submit average number' of operating hours per year,
EPA assumed that.the facility operates 7.200 hours/year. EPA applied the standard 10-
percent reduction factor to the maximum capacity of this facility.
This facility'accepts F037 and F038 wastes. Presently, this facility cannot accept
Kl 17, Kl 18. or other brominated wastes. - "
a o
it " n
?
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2-22
This facility plans 10 increase sludge/solid capacity by adding a rotary reactor unit
and associated feed 'systems in 1993. Additional storage areas will also be constructed to
accommodate extra capacity. '
Rollins Environmental Services, Deer Park, Texas , '
' This RCRA-perrhitted facility has two independent incinerator systems or trains.
The first train includes a rotary kiln (SO MBTL'/hour) and an afterburner (100
MBTU/hour): The second train 'includes a rotary kiln (80 MBTL'/hour}, 'a fluidized bed
rotary reactor, (33 MBTU/hour) and an afterburner (100 MBTU/hour). Train #! has a
'-permitted waste feed capacity of 23,400 Ibs/hour (13.400 !bs/hour for rotary, kiln and
8,000 fbs/hour for the afterburner). Train #2 has a permitted waste feed capacity of
32,000 Ibs/hour (8,000 Ibs/Tiour for rotary kiln, 12,000 Ibs/hour for rotary reactor, and
8,000 Ibs/hour for the afterburner).
. ' Each train has several feed mechanisms. Both trains utilize concrete pumps to ,
feed pumpable sludges and an elevator feed for containers: Train. #2 also has a
clamshell/shredder that feeds-bulk solids into the fluidized bed rotary reactor;
For each train, the facility provided the following capacity information: waste
volumes burned during the first half of 1991, the hourly maximum permitted and waste
feed capacities 'for. liquids and solids, and average operating hours per year. Because the
facility reported a combined sludge and solid category, EPA distributed waste volume
and capacities evenly among the specific sludge and solid categories. EPA applied the
standard 10 percent reduction factor to the maximum capacity of this facility. .This
facility can accept F037, F038, K117, and K11S. No bromine limits are imposed on
wastes accepted at this facility. - - '
Between the proposed and final rule, EPA contacted the facility to clarify issues .
raised in public comments and confirm it's capacity estimates. Contacts at this facility
noted that previously, reported nonpumpable sludge capacity should have been reported
as containerized solids and bulk solids capacity. EPA revised its estimates based on this
correction. The facility routinely accepts K048-5.2 petroleum refining wastes, which it
describes as. "crumbly" rather than'"tacky", and did not notice an increase in the
quantities of K-wastes during the second half of 1991. Petroleum' refining K-wastes are
not amenable to the pumpable sludge system, and are fed through the bulk solids feed
system. The facility requires that bulk solids wastes have a heating value of less, than
5,000 BTU/lb, and reported that petroleum refining K-wastes received by the facility
generally have heating values between 3,000 and'4,000 BTU/lb. The facility would reject
wastes with very high metals concentrations (i.e., thousands of parts per million of lead,
arsenic or chromium.) EPA revised its estimates of this facility's available capacity based
on the heating value of petroleum refining wastes, the facility's maximum practical
throughput capacity and current utilization: ' . .
a. a. - "
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- 2-23 ' -
This facility is building a gas injection system so thai it can accept pressurized
cylinders.. It is also permitted to construct another fluidized bed rotary reactor to .
increase sludge/solid capacity, but it will not be constructed before July 1994.
Ross Incineration Services, Graftoit, Ohio . : . '
This facility has'obtained a RCRA-Pan B permit from the U.S. EPA, but is
awaiting approval for a Part B permit from the Ohio'EPA. Ross Incineration Sen-ices
has requested information submitted in the voluntary data collection form be classified as
'Confidential Business Information. This information included maximum permitted and
practical capacities, type of unit, technical specifications, and feed mechanisms. EPA
applied the standard 10 percent reduction factor to the maximum capacity of-lhis facility.
Capacities for different physical types of waste are included in the Aggregate CBI
capacity estimates. . s,
. This facility can accept K-listed and F-listed petroleum refining wastes. The
facility does not accept Kl 17 and Kl IS waste. The facility currently.accepts K-wastes in
' bulk solids form, and reported that the quantities decreased during the second half of
1991, due to competition from cement kilns. .
This facility replaced its rotary kiln in December 1991. Between the proposed and
final rule, EPA contacted the facility to update its capacity estimate. Because detailed
capacity estimates were not available at the time of the update, EPA did'not revise its
estimates of available capacity at this facility. Information submitted in the. voluntary
data collection form concerning future capacity was requested to be. classified as
Confidential Business Information. .
' - ! " '
ThermaiKEM, Rock Hill, South Carolina
' This RCRA-permitted facility uses a fixed hearth incinerator with a total heat
release limit of 42 MBTU/hour. This facility can accept liquids, purnpable sludges,
. nonpurnpable sludges, bulk solids, and containerized solids. ThermaiKEM requested that
feed mechanism information submitted in the voluntary data collection form be classified
as Confidential Business Information. . ' .
t
- Capacity data provided by. the facility include waste volumes burned during first
half of the year, hourly maximum permitted and practical capacities, and average
operating hours per year. EPA applied the standard 10 percent reduction factor to the
maximum capacity of this facility. ThermaiKEM requested that capacity data for this
.facility be classified as Confidential Business Information. Capacities for each physical
type of waste are includ.ed in the Aggregate CBI capacity estimates.
ThermatKEM can 'accept F037; F038, KI17, and Kl 18 waste. The permit requires
that wastes fed into the fixed hearth not exceed 5 percent in total bromine content.
'Ill
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2-24, '
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' The facility plans to increase sludge/solid capacity by adding an additional unit, a
waste fired boiler, and additional storage areas. '
< , , ' '
2.23 Sludge and Solid Incineration Capacity Beyond 1992 '
The incineration capacity update focussed only on commercial incinerators that
are currently operating or are expected .to begin operating by May 1992. Several of these
companies, however, reported plans to add sludge and/or solids capacity over the next
two years: . '* . -, '
- . ThermaiKEM, Rock Hill, South Carolina reported that a second
incinerator unit and- a waste-fired utility waste boiler will be on-line by July
1994. The facility is'constructing a new solids handling-feed system, and a
, , " bulk solids storage system to facilitate handling increased amounts of solids.
« American. NuKEM, the parent company of ThermaiKEM, has recently
acquired a RCRA-permitted lightweight aggregate kiln from Norlite
Corporation. Information regarding available capacity for this unit was' not
available at the present time.
' Rollins, Bridgeport, New Jersey reported that a rotary reactor unit
currently under construction will be on line in 1993. This unit will increase
i the facility's capacity to burn sludges and solids;
In addition to facilities where incinerators currently exist, several planned
commercial incinerators appear to be sufficiently advanced in the permitting and siting '
process to potentially come on line by 1993. EPA contacted state regulatory agencies for
information regarding these facilities: , "
USPC1, Tooele, Utah has its RCRA Part B permit and at the time of the
proposed rule was scheduled to begin'trial burns in May. 1992. The facility
has also applied for a TSCA permit to burn PCB contaminated waste.
, Pending successful trial burns, the facility is expected to come on line in
late 1993. The total permitted capacity is 130,000'tons per year.
At the time of the proposed rule, Waste-Tech, Kimball, Nebraska expected
. to receive a draft Part B Permit in March 1992 to begin constructing a
fluidized bed incineratipn facility. Trial burns are scheduled for late 1992.
, Pending successful'trial bums, the facility is expected to come on line in
late 1993.. The maximum permitted total capacity for this facility will be
43,000 tons per year. .' ,
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" '2-25
Waste-Tech, East Liverpool. Ohio has its RCRA Part B permit, and at the
time of the proposed rule'was scheduled to begin trial burns'in May 1992.
Pending successful trial burns, the facility is expected to be on line in
'.-.-' February 1993. ' -'
2J COMMERCIAL CEMENT KILN HAZARDOUS WASTE CAPACITY
, This chapter covers EPA's assessment of the combustion capacity available in
cement kilns in the U.S. Sections^2.3.1 and 2.3.2 explain how the information was
collected, from individual firms and analyzed. Section 2.3.3 contains a summary of the
information'reported by each facility, regarding its current and future waste fuel burning
practices. Section 2.3.4 discusses facilities expected to begin burning hazardous waste
between May 1992 and May 1994. Section 2.3.5 discusses facilities not included in this
capacity analysis. Finally, Section 2.3.6 discusses EPA's assessment of the packaging
capacity available for-putting hazardous wastes into containers suitable for containerized
solids feed systems.
2 J.I General Approach and Assumptions . . '
The Cement Kiln Recycling Coalition (CKRC) is a trade association representing
firms involved in the'use of wastes as fuel or feedstocks in cement production. CKRC
notified EPA of its interest in providing capacity information to support EPA's capacity
analysis for newly listed wastes. EPA informed CKRC of the types of data it needed to
conduct the capacity analysis, and CKRC surveyed its members. The survey asked a
.variety of questions pertaining to the types of wastes accepted, the amount of waste
currently burned, maximum practical waste burning capacity, and the regulatory status of
surveyed facilities. CKRC divided'the universe of hazardous wastes as fed to cement
kilns into six categories: liquids, pumpable sludges, nonpumpable sludges, containerized
solids, dry solids, and bvilk.solids. Firms were also asked about their hazardous waste
'storage capacity, their fuei processing capabilities, the fuels blenders from whom they
receive their hazardous waste fuels, and the physical and chemical specifications their
fuel must meet. Responses to the CKRC survey were provided directly to the EPA for
inclusion in the capacity analysis for newly listed wastes. These completed survey forms
are available, in a separate document in Appendix C. Survey forms from facilities
, requesting that part of their information be classified as CBI are in a separate document
in the docket, entitled Background Data Set For Commercial Hazardous Waste Cement
Kiln Capacity Analysis - Confidential Business Information.
In-the subsequent data analysis, EPA asked several firms to clarify their responses
to gain a more complete understanding of whether they will be able to provide capacity
for newly listed wastes. Phone logs documenting these calk can be found in Appendix C.
EPA also asked various firms whether they expect to burn .wastes with heating values
. below 5,000 BTU/Ib, once they certify compliance with interim status requirements of the
Boiler and Industrial Furnace (BIF) Rule (56 FR 7134, February 21, 1991). BIF
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' requirements, however, will supersede sham recycling policy guidelines once a facility
certifies compliance with BIF Interim Status requirements. Currently, the EPA Sham .
- Recycling Polio' Guidelines specify that wastes should have a minimum of 5,000 BTU/lb
to be considered legitimate fuel,substitutes, and several states .impose higher heating
value limits. Cement companies indicate that while some changes may be made, the
overall limit wiU'not decrease much, because of the high temperatures that must be
maintained to produce cement clinker.. .Ash Grove Cement, a major burner of solid
hazardous wastes, indicated that it will decrease its solid fuel heat content limit to 4,000
. BTU/lb, specifically to accommodate petroleum refiner)' wastes.
2.3.2 Individual Facility Analysis Methodology
The CKRC survey asked facilities for their maximum practical hazardous waste
burning'capacity, and the volumes burned in 1991 to August 21. EPA annualized this .
number by dividing it by 0.64, the,fraction of a full year represented by the period
January 1 through August 21. Some facilities submitted hazardous waste utilization data
' 'through other dates in July and August, and the annualization factor was adjusted -
accordingly. This method-assumes that hazardous waste burning practices for January
through August are representative of the remainder of the year. In its capacity analysis,
EPA estimates available capacity on an annuatized basis by>ubtracting waste volumes
burned (utilized capacity) from the maximum practical capacity. By using annualized
volume.and capacity data, EPA attempts to account for seasonal fluctuations'and
scheduled'downtimes. Though the CKRC survey asked cement firms to estimate the ,
amount of solids typically entrained in their liquid hazardous waste feed, these estimates
were not included in the final estimates of available solid capacity because of the
technical limitations on the types of solids amenable to this type of blending.
Exhibit 2-6 reports utilized, maxiinum'and available capacity;' EPA adjusted the
maximum capacity estimates reported by facilities, to be conservative in its estimate of
the national available capacity. To account for-the likelihood that not ail facilities will-be
able to operate at maximum capacity, maximum capacities reported by facilities that have
well established hazardous waste burning practices (referred to as "existing" capacity)
were reduced by 10 percent. Maximum capacities of firms just beginning to burn
hazardous waste (referred to as "new" capacity) were decreased by 50 percent to account
for potential start-up problems and delays. In no case was maximum capacity adjusted ,
below utilized capacity.' Several firms currently .burning containerized solids indicated
that they could increase their capacity by feeding two containers per feed cycle, instead
of the usual one. EPA considered the increment representing the first container per feed
cycle as existing capacity, and the incremental second part as new capacity, and adjusted
both accordingly. To determine the amount of available capacity for newly listed wastes,
EPA subtracted the annualized utilized capacity from the adjusted maximum capacity.
Calculations were performed for each unit at a facility, and summed to obtain the total
capacity available :at the facility. . ' \
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2-27'
' EXHl'SIT-2-6
SUMMARY OF COMMERCIAL CEMENT KILN CAPACITY THROUGH MAY 1992.
NAME
ASH GROVE
CHANUTE, KS
KSD031203318
/
ASH GROVE-
FOREMAN, AR
ARD981512270
ASH GROVE
LOUISVILLE.NE
NED007260672
ESSROC
LOGANSPORT, IN
GIANT CEMENT CO.
(GIANT RESOURCE RECOVERY)
HARLEYVILLE, SC
' . - '
UNIT
TYPE
CK
WASTE
TYPE
LIQ.
CONT. sol:
CK
LIQ.
CONT. SOL.
FACILHYTOTAL '
CK
'. LIQ.
CONT. SOL.
CK
LIQ.
CONT. SOL.
' CK - .
LIQ. .
CONT, SOL.
FACILITY TOTAL
i
CK
LIQ.
CONT. SOL.
CK
LIQ. '
CONT. SOL.
FACILITY TOTAL
CK | LIQ.
CK
LIQ.
FACILITY TOTAL
. CK.
LIQ.
DRY SOL.
' CK
LIQ.
DRY SOL
CK .
LIQ.
DRY SOL.
CK
.LIQ.
DRY SOL. .
FACILITY.TOTAL
>
1991
UTILIZED
CAPACITY
.(TONS/YR)
21,531
9.236
21,531
' 9,286
61,634
16,206
5,531
16.206
5,531
16,206
'5,531
65.211
3,598.
1.381
3,598
1,381
9,958
17,402
17,402
34,804
14,400
1,128
13.302
898
1 1 ,578
. 51 1
, 13,231
. .483
55,531
MAY 1992
MAXIMUM
CAPACITY
(TONS/YR)
33.750
17,500
'
. , 33,750
' 1 7.500
102,500
31.104
15,590
31,104
15,590
31,104
15.590
' 140,083
31.500
12.528
. 31,500
12,528
88,056
23,400
23.400
46,800
23,400
3,700
23,400
' 3.700
23.400
3,700
--
23.400
3,700
108.400
. MAY 1 992
AVAILABLE
CAPACITY
(TONS/YR)
12,219
- . 8,214
12,219
,- 8,214
. .40,866
14,898
10,059
14,898
10,059
- 14,898
10,059
74,872
27,902
11,147
27,902
11,1.47
78,098
5,998
'5,998
11,996
9.000
2,572
10.098
2,802
11,822
3,189
^ 10,169
3,217
' ' 52,869
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- , 2 - 28- . . ''
" ' EXHIBIT 2-5 (CONTINUED)
SUMMARY OF COMMERCIAL CEMENT KILN CAPACITY THROUGH MAY 1992
NAME
HEARTLAND CEMENT CO.
(CEMTECH)
INDEPENDENCE, KS
KSD980739999
s. ' .'
-
KEYSTONE PORTLAND CEMENT
SATH, PA
PA0002389559
" ,
LAFARGECORP. ,
(SYSTECH)
ALPENA, Ml
MID98120083S
LAFARGE CORP. .
(SYSTECH) "*
DEMOPOLIS. AL .
ALD98101904S ''
1
LAFARGECORP.
(SYSTECH)
FORMERLY GENERAL PORTLAND
FREDONIA, KS
KSD980633259 .
LAFARGECORP. -
(SYSTECH)
FORMERLY GENERAL PORTLAND
PAULDING.OH
OHD005Q48947 - '
LONE STAR INDUSTRIES ;
GREEN CASTLE. IN
IND006419212
*~
\*
UNIT. ;
TYPE
CK
WASTE
TYPE
DRY SOL.
' CK
DRY SOL.
CK
DRY SOL
. CK
DRY SOL.
FACILITY TOTAL
CK
-LIQ. . '
CK
, LIQ.
FACILITY TOTAL . '
CK
LIQ. .
CK
LIQ.
FACILITY TOTAL
CK
i
LIQ. ,
k
CK
LIQ.
-~>
CK
LIQ.
DRY SOL
FACILITY TOTAL
CK
' LIQ.
CK
LIQ.
FACILITY TOTAL
.CK ,
LIQ.
CONT; SOL.
FACILITY TOTAL
1991
' UTILIZED
CAPACITY
(TONS/YR) ,
MAY 1992
MAXIMUM
CAPACITY
(TONS/YR)
' 938 | 3.750
' 938
3,750
I- '
. 938
938
3,750
. 1,992
37.872
39,864
25,870
25,870
51,740
31,748
-26,263
40.404
6.067
72,734
27,532
27,532
55,064
26,970
. 2,634
29,604
' 3,750
3,750
1 5,000
13,000
54,000
72,000
30,600
30,600
61,200
32.000
28.760
46,116
6,917
81,793
30,150
30,150
60,300
42,750
3,564
46,314
MAY 1992
AVAILABLE
CAPACITY
(TONS/YR)
. 2.813
,
-2,813
2.S13
2,813
1 1 ,250
16,008
. 16.128
32.136
4.730
4.730
9,460
. 252
2.497
5,712
850
9.059
, '
2.618
2,618
5,236
1 5,780
930
16,710
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"'., 2-29- .
. EXHIBIT 2-6 (CONTINUED)
ifs?
SUMMARY OF COMMERCIAL CEMENT KILN CAPACITY THROUGH MAY 1992
NAME-
MEDUSA CEMENT CO.
(CEMTECH)
WAMPUM, PA
PAD083965S97 . '
NATIONAL CEMENT CO.
LEBEC.CA
CAT080Q31628
\ '
,
RIVER CEMENT
(CEMTECH)
FESTUS, MO '
MOOOS0232560
SAN JUAN CEMENT , , .
(ESSROC)
SAN JUAN. PR
SOUTHWESTERN PORTLAND
(SOUTHDOWN, INC.)
FAIR8ORN, OH
OHD981 195779 .
'
SOUTHDOWN INC.
KNOXVILLE, TN ' .
* . ' ' \
'
UNIT
TYPE
CK
WASTE
TYPE'
UO.
PUMP. SU-
NPU. SL
CK
' UQ.
PUMP. SL.
NPU. SL.
CK
^-LIO.
PUMP. SL
NPU. SL.
FACILITY TOTAL
>
CK
LIQ.
FACILITY TOTAL
, CK
LIQ:
PUMP. SL.
NPU. SL
CK
LIQ.
PUMP.SL.
NPU. SL
FACILITY TOTAL '.
CK
LIQ.
CK
LIQ.
FACILITY TOTAL
CK
CK
LIQ.
LIQ.
CONT.SOL.
FACILITY TOTAL
'
1991
UTILIZED " ,
CAPACITY
(TONS/YR)
4,375
1 ,563
313
4,375
1,553.
. ' 313
4,375
1,563
313
18.750
30,578
. . 30.578
15,625
5,469
1.172
15,625
5.469
1,172
44.531
18,750
781
19,531
4,478
2,958
4.559
7,517
MAY 1992
MAXIMUM'
CAPACITY
(TONS/YR)
13,500
- .'2,66.7
500
1.3,500
; 2,667
.500
13,500
2,667
500
50.000
31,320
31.320
,- 27,900
9.900
1,800
27,900
'9,900
1.800
79.200
19.000
31',500
. 50,500
17,500
10.800
18.200
29,000
" MAY 1 992
AVAILABLE
. CAPACITY
(TONS/YR)
9.125
1,104
188,
9.125
, 1,104
. 183
9.125
1,104
188
31 .250
742
742
12.275
4.431
628
12,275
4.431
628
34,669
250
30.719
30.969
13.022
7.842
13.641
21,483
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EXHIBIT 2-6 (CONTINUED)
r
~
SUMMARY OF COMMERCIAL CEMENT KILN CAPACITY THROUGH WAY 1992 "
!.'.'-," -
' NAME
TOTAL LIQUJD
UNIT1
TYPE
' ' .
JOTALPUMPABLE SLUDGES I
tTOTAL NON-PUMPABLE SLUDGES
TOTAL- CONTAINERIZED SOLIDS
TOTAL DRY SOLIDS
.
TOTAL HAZARDOUS WASTE
-
WASTE
TYPE
,
,
1991
UTILIZED
CAPACITY
(TONS/YR)
' ' 560.164
. 1S.625'
MAY 1992'
MAXIMUM
CAPACITY
(TONS/YR)
913,758
27,300
3,281 | -. .5,100
45,120 | 128,591
' 12,837
' ..
-
637.028
36,717
MAY 1992
AVAILABLE .
CAPACITY
(TONS/YR)
353,594
12.175
' 1,819'
83.471
23,880
.1,111,966 | 474,939
NOTES: CK = CEMENT KILN.. SOME TOTAL'S MAY BE INEXACT DUE TO ROUNDING ERRORS.-
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The following example of a'one-kiln facility demonstrates how EPA used reported'-
information to arrive at its available capacity estimates. '
Facility information: - \
. ' Liquid hazardous waste burned to August 21, 1991: 15,000 tons
Containerized solid waste burned to August 21,-1991: ' 8,000 tons
Maximum practical liquids burning capacity: 35,000 tons per year
. ' Maximum practical containerized solids burning capacity: " 24.000 tons per year
1. Annualtze volume liquid hazardous waste fuel burned to August 21. 1991: .
, 15,000 tons of liquid'hazardous. waste fuel burned
.H- . ' 0.64 year .
23,438 tons of liquid waste fuel utilized per year ' .
2. Adjust maximum annual capacity: ' . . :
35,000.tons maximum'liquids per year .. ' '
x ' 0.9 existing capacity adjustment factor
31,500 tons adjusted maximum capacity per year
3. Subtract to determine annual available capacity:
31,500 tons adjusted maximum capacity per year
23.438 tons of liquid waste fuel utilized oer year
8,062 tons' of available liquid burning capacity '
4. Anniialize volume containerized solid waste fuel burned to August 21, 1991:
8,000 tons of containerized solid hazardous waste fuel burned . -
* 0.64 year \ . ' .
12,500 tons of containerized solid waste fuel utilized per year
5.' Adjust maximum annual capacity:
A. Existing capacity: one container per cycle:
24,000 tons maximum solids capacity per year
* 2.the factor from first container per cycle
x 0.9 adjustment for existing capacity
10.300 tons adjusted maximum capacity for one container per cycle
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B. New capacity: ihe second container per cycle:
24,000 tons maximum solids capacity per year
:-? 2 the factor from second container per c\c!e
x 0.5 adjustment factor for new capacity
6,000 tons adjusted maximum capacity for second container per cycle
' C. Total adjusted maximum capacity for containerized solids: . . -
I '
. 10,800 tons per year from one container per cycle .
- + 6.000 tons per year from second container per cvcle
' ' 16,800 tons per year total adjusted maximum capacity
6. Subtract to determine annual available capacity:
16,800 tons adjusted maximum solids capacity per year
12.500 ions of containerized solid waste fuel utilized per year >
' 4,300 tons of containerized solids capacity available per year
Some firms reported the volume of waste burned in gallons. These numbers 'were
converted to tons by assuming the waste has the same density as water.c For example, if
a firm reported burning 1,000,000 gallons_as-of August 21, 1991, annualized utilized
capacity would be obtained as follows: *'.,.''
. . 1,000,000 gallons , .
+ 0.64 year ' ' .
x > 8.34 pounds/gallon . ' .
, . * 2.000 pounds/ton ;
6,516 ions/year . ' '
Revisions to the Analysis since the Proposed Rule .
EPA received several public comments on the proposed rule regarding cement
kiln combustion capacity4. As a result of the information and issues contained in public
comments, EPA conducted calls to various cement-kilns to confirm their operating status
and capacity. Information collected from these activities is discussed in Section 2.3.2
beiow; and background documentation is provided in Appendix C. EPA did 'not revise
any. facility-specific capacity estimates since the proposed rule as a result of new"
information. However, EPA did collect additional information to assess capacity for
packaging wastes for cement kilns. This assessment is discussed in Section 2.3.6 below.
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For a detailed discussion of public comments pertaining .to commercial combustion capacity, refer 10
Chapter 2 of Response w Comments Background Document for Phase One Land Disposal Restrictions Proposed
Rule.
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After the.public comment periodended.'-EPA receis-ed additional information from
Cadence Chemical Resources regarding cement kiln capacity. This information, which is
documented in Appendix C, was not received in time for EPA to use it to revise its
capacity analysis and meet the court-ordered deadline for promulgating :his rule.
However. EPA does not believe this information would have affected its Variance
decision because it dealt only with cement kilns, not incinerators. EPA's primary reason
for granting a variance to routinely generated F037 and:F03S is the lack of adequate bulk
solids incineration capacity for F037 and F03S wastes that are not amenable to cement
kilns. .
2.33 Individual Facility Results
Exhibit 2-6 reports annualized capacity utilized by facilities, maximum-practical
hazardous waste burning capacity, and the total available capacity for hazardous waste .
combustion in cement kiins. EPA estimates that the facilities responding to the CKRC;
will have approximately. 121,000 tons' of sludge/solid capacity available by May 1992
(83,000 tons containerized solids, 24,000.tons of dry solids, and 14,000 tons of sludges).
This section discusses the hazardous waste burning practices of individual facilities, '
including their available capacity for sludge and solid hazardous waste fuel combustion,
. feed mechanisms, permit status for newly listed wastes, and plans for changes to their
current hazardous waste burning practices. .Bromine limits for each facility are discussed
in response to concerns that the bromine content of Kl 17 and K118 would be
prohibitively high for some commercial hazardous waste incinerators. . '
Ash, Grove, Chanute, Kansas .
The Ash Grove Chanute facility, currently operates two cement kilns, both of
which burn liquid and containerized solid hazardous wastes. The kilns bum' hazardous
waste fuel during 80 percent of their operating time. Based on reported maximum
practical feed,rates, and 1991 utilized capacity, EPA estimates the facility's available
liquid waste capacity to be 24,438 tons-per year and its available solids capacity to be
, 16,428 tons per year. The estimate for liquid capacity reflects the'standard reduction for
existing capacity discussed in the methodology section above. The estimate for
containerized solids reflects the standard reduction for new and existing capacity,
discussed above. All Ash Grove facilities report their liquids contain up to'30 percent
entrained solids. The acceptable bromine content in.hazardous waste fuel at Ash Grove
Chanute is limited by a total permitted halogen limit of 5 percent for both liquids and
containerized, solids, but this is not broken down by element. This facility reported no
plans to "change its hazardous waste burning practices before June 1994. In response to
the proposed rule, EPA received comments stating that EPA overestimated available v
capacity ..at Ash Grove facilities. In response to these comments, EPA contacted Ash
Grove to update its capacity analysis. Ash Grove confirmed the available capacity and
'utilization estimates from the August CKRC survey, estimating that they have
approximately 10,000 tons per year, per kiln available for containerized solids. Ash
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Grove mentioned that it is possible during winter month's, when kilns arc rotated through
their maintenance schedule. 10 be .operating "at 'capacity" on a given day. but trial over-.
the course of the year, they have excess capacity. All three Ash Grove facilities receive,
petroleum refining wastes, and' Ash Grove describes F037 and F03S as "ideal" kiln feed;
with low metals and moderate heating values. As a result of these confirmations.' EPA
did not revise its previous estimates of available capacity at this facility. :
Ash Grove, Foreman, Arkansas . .
There are three wet process rotary cement kilns currently burning hazardous
waste at this facility^ They all inject liquid hazardous waste fuel into the clinker discharge
end of the kiln, and charge containerized solids to the calcining zone. EPA estimates
that together the three kilns have 44,694 tons of liquid capacity available'per year and
30,177 tons of containerized. solid. capacity available.' This estimate is based on the
reported maximum practical feed rates and 1991 utilized capacity estimates. The liquid
available capacity estimate reflects the adjustments for existing capacity explained in the
methodology section above, and the containerized solids available capacity estimate
. reflects the .reductions for new and existing capacity, discussed above. All Ash Grove
facilities report that as burned, their liquids contain approximately 30 percent solids.
Acceptable bromine levels are limited at this facility by its total. permitted halogen limits
.of 10 percent for liquids' and 8 percent for solids. The facility is authorized to' receive
-K117. K11S, F037 and F038 wastes. In June. 1992, this facility is planning a test burn to
broaden fuel specifications and change its air permit in order to increase, its maximum
solids capacity from 46,770 tons per year for the three kilns. to 90,000 tons per year. In
response to the proposed rule, EPA received comments stating, that EPA overestimated
available capacity at Ash Grove facilities. In response to these comments, EPA .
contacted Ash Grove to update its capacity analysis. Ash Grove confirmed the available
capacity and utilization estimates from the August CKRC survey, estimating that they
have approximately 10,000 tons per year, per kiln available for containerized solids. Ash
Grove mentioned that it is possible during winter months, when kilns are rotated through .
their maintenance schedule, to be operating "at capacity" on a given day, but. that over
the course of the year, they have excess capacity/ All three Ash Grove facilities receive
petroleum refining wastes', and Ash Grove describes F037 and F03S as "ideal" kiln feed,.
with low metals and moderate heating values.' As a result of these confirmations,' EPA
did not revise its previous estimates of available capacity at this facility.
Ash Grove, Louisville, Nebraska .
The Ash Grove Louisville facility currently burns liquid and containerized solid
waste fuel in'rwo rotary preheater cement kilns. Liquid hazardous waste fuej is injected
into the clinker discharge end of the kiln, and charge containerized solids, to the calcining
zone. Both kilns burn waste 290 days out of 365, slightly less than the total operating
time -of the kilns. Based on the reported maximum practical feed rates and 1991 utilized
capacity, EPA estimates that the facility has 5.5,804 tons of liquid combustion capacity
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available per year, and 22.294 tons of containerized solids capacity.available per year.
The liquid available capacity estimate reflects the adjustments for existing capacity
explained in the methodology section above, and the containerized solids available
capacity estimate reflects the reductions for new and existing capacity, discussed above.
.Ash Grove reports that as burned, their liquids contain approximately 30 percent solids.
Bromine is limited at this facility by a total permitted halogen limits of 6.66 percent for
liquids and 7.3-percent for solids; It is authorized to burn Kl 17, K1IS, F037 and F038
wastes. At the time of the proposed rule this facility was-planning to'conduct compliance
testing in June 1992 to increase the range of hazardous waste fuels it can burn, and to
increase the firing rate.. The testing is planned at 1.5 to 2 times the currently permitted
rate. In response .to the proposed rule, EPA received comments stating that EPA -
overestimated available capacity at Ash Grove facilities. In response to these comments,
EPA contacted Ash Grove to update its capacity analysis. Ash Grove confirmed the
available capacity and utilization estimates from the August CKRC survey, estimating -
that they have approximately 10,000 tons per year, per kil.n available for containerized
.solids. Ash Grove mentioned that it is possible during winter months, when kilns are
rotated through their maintenance schedule, to be operating "at capacity" on a given day,
but that over the course of the year, they have excess capacity. All three'Ash Grove
facilities'receive petroleum refining wastes, and Ash "Grove describes F037 and F038 as
"ideal" kiln feed, with low metals and moderate heating values. As a result of these
confirmations, EPA-did not revise its previous estimates of available capacity at this '
facility. . . "
ESSROC, Logansport, Indiana
r
This'facility bums liquid hazardous waste fuel in two wet process cement-kilns.
Based on the reported maximum practical feed rates, and capacity utilized in 1991, EPA .
estimates that'this facility has 11,996 tons per year capacity available for liquid hazardous
waste.. This estimate reflects the,adjustments made for existing capacity, discussed in the
methodology section above. After the close of the public comment period, EPA learned
that this facility has begun to burn solids. This information, which is presented in
Appendix C, was not received in time to revise this analysis, but will be incorporated into
future capacity analyses. This facility did not report bromine limits or its' ability to,burn
K117andKll& , '
Giant Cement Company, Harleyville, South Carolina
This facility bums liquid and dry solid hazardous waste in four wet process cement
kilns. Both types of wastes are fed into the clinker discharge end of the kiln. Based on
the reported maximum practical feed rates and 1991 waste volumes, EPA estimates that
together the kilns have 41,089 tons per year liquid.combustion capacity available, and
11,780 tons per year available capacity for dry solids. The liquid available capacity
estimate reflects the reduction made for existing capacity, and the dry solid capacity >
estimate reflects the new capacity adjustment, discussed in the meti.oJology section
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.', above. Giant Cement is permitted to receive F037 ,ind F038 petrdleum'refining wastes.
They did not report plans to burn Kl 17 and KI IS, but the bromine content of Giant.'s.
hazardous waste feed is limited by a total halogen permit limit of 8 percent for solid
feed, and 4 percent for liquid feed. This facility did.not. report plans to change its
hazardous waste burning practices before 1994. In response to the proposed rule, EPA
received comments stating that EPA overestimated available .capacity at this facility. In
response to these comments, EPA contacted Giant, Giant Cement confirmed-EPA's
estimates of their available capacity, and confirmed that they do receive dewatered
petroleum refining wastes. As a result of these confirmations, EPA did not revise its
previous estimates ^of available-capacity at this'facility. -
Heartland Cement Company, Independence, Kansas (Cemtech)
' This facility burns dry'solids in foundry process.cement kilns. They each feed dry
.solid hazardous waste into the clinker discharge end ofjthe kiln. Based on the reported-
maximum permitted feed rates and' I991waste volumes, EPA estimates that together the
four kilns have 11,252 tons'per year available capacity, for dry solids.1 The standard
approach of reducing'new capacity by 50 percent, discussed in the methodology section
above, .was used to arrive at these estimates. The facility is. authorized to burn F037 and
FQ3S wastes. K117 and K118 are acceptable in" trace amounts. This facility does not
intend to make,changes to its hazardous waste burning practices before 1994, but has
proposed to add liquid and pumpable sludge combustion capacity. In response to the
proposed rule, EPA received comments stating that EPA overestimated available
capacity at this facility. In response to these comments, EPA contacted Heartland
Cement, confirmed that they are authorized to accept petroleum refining wastes, and
found no reason to revise its capacity estimate. The-'facility was planning to include this
trial bum with trial burns for BIF Compliance in the spring. As a result of these
confirmations, EPA did not revise its-previous estimates of available capacity at this
facility. , .
Keystone Portland Cement Company, Bath, Pennsylvania
Y Keystone Cement. Company burns liquid hazardous waste in two wet process
rotary cement kilns. The hazardous waste fuel is injected into the clinker discharge end
of the kiln. Based on reported maximum practical feed rates, and 1991 utilized capacity,
EPA estimates that the facility has 32,136 tons per year available capacity. This estimate,
reflects the adjustment for existing capacity, discussed in the methodology section above.
This facility did not report bromine limits or its ability to burn Kl 17 and Kl 18.
Lafarge Corp., AJpena, Michigan (Systech)
x' This facility operates five rotary cement kilns, but only two are jnrrently burning
hazardous waste. These kilns burn liquids only. Based on reported volumes utilized in -
1991, and maximum permitted feed rates, EPA estimates that together the kilns have
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9,460 tons of capacity available per year. Thij estimate reflects the 10 percent reduction
'for existing capacity-discussed in the methodology section above. This facility'has
submitted an application to allow them to burn F037 and FOJS under RCRA Interim '
Status./Lafarge intends to burn hazardous waste in the three kilns that are not .currently
burning hazardous^ waste, but must first satisfy numerous construction and regulatory
requirements, Lafarge estimates they will be on line burning liquid waste in 1992 or
1993. The facility also plans to install a sludge handling system at some unspecified point
in the future: This facility is not,authorized to burn K117 arid Kl 18-wastes.
Lafarge Corp./'Demopolis, Alabama (Systech)
«' . *
The Demopoiis, Alabama Lafarge facility operates one cement kiln, burning liquid
hazardous waste fuel." Based on reported volumes utilized in 1991, and maximum
permitted feed rates, EPA estimates it has 252 tons of capacity available per year. 'The
facility's capacity is so highly utilized it was not adjusted at all. In 1992 or 1993, the
facility intends to add a 150,000-gaUon burn tank,-to increase its capacity and"blending
capabilities. This facility.is not authorized to burn K117 and K118 wastes.
, Lafarge Corp., Fredonia, Kansas (Systech)
This facility operates two rotaryvcement kilns. One bums liquid and dry solid , .
hazardous waste, th'e other only liquid. Based on reported maximum practical burning
capacity, and 1991 capacity utilization, EPA estimates this facility has 8,209 tons per year
liquid combustion capacity available, and 850 tons per year dry solids capacity available. "
The capacity of the kiln burning only liquid hazardous waste fuel was not adjusted, the.
dry solid and liquid available capacity of the other kiln was reduced by the standard 10
percent used for existing capacity. The facility is modifying its permit to accept newly
listed F037 and F038 wastes. This facility is not authorized to burn KI17 and K118
wastes. " . .''.
Lafarge Corp., Paulding, Ohio (Systech)
This facility burns liquid hazardous waste fuel in two rotary cement kilns. Based
on reported maximum .practical burning capacity, and 1991 capacity utilization, EPA'
estimates this facility has 5,236 tons of available capacity per year. All available capacity
was reduced by the standard 10 percent used for existing capacity. It is modifying its
permit to be able to burn F037 and F038 wastes, estimating 2,000 tons per year of each.
The facility plans to add dry solids capability in 1992 or 1993.- This facility is not
authorized to burn Kl 17 and K118 wastes.
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Lone Star Industries, Green Castle, Indiana ,
This facility burns liquid and containerized solid hazardous waste fuel in one long,
wet process rotary cement, kiln. The liquid waste fuel is injected into the clinker
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discharge end of the kiln, and solids are fed in with an air cannon. The kiln burns waste
fuel during 80 percent of its operating time. Based on reported maximum practical
burning capacity, and 1991 capacity utilization, EPA estimates that Lone Star has 15,780
tons per year, liquid combustion capacity available, and 930 tons per year capacity
available for containerized solids. All available capacity .was reduced by the standard 10
percent used for existing capacity; This facility plans to, add dry solids capacity in the
third 'quarter of 1993. Bromine content of hazardous waste fuel burned is.limited to 2.5 ,
percent by product quality' considerations, but the facility did not report whether they are
authorized to burn Kl 17 and Kl 18 wastes. .. _'' ".'.'
' Medusa Cement, Wampum, Pennsylvania {Cemtech) '
This facility burns liquid and sludge hazardous waste in three long dry process
cement kilns: Solids are ground and.mixed into the liquid stream, before being injected
' into the kilns. Based on reported maximum practical burning capacity, and 1991 capacity .
utilization, EPA estimates that the facility has 27,375 tons per year liquid capacity
available, 3,312 tons per year pumpable sludge capacity available, and 564 tons per year
nbnpumpable sludge.capacity available. Its liquid capacity estimate was reduced 10,
percent, as existing capacity, and its sludge capacity estimate .was reduced 50'percent as
new capacity. F037 a.nd F038 wastes are included in its current permit, and Kl 17 and
K118 are acceptable in trace quantities.. This facility did not report plans to change its '
hazardous waste burning practices before 1994. In response to the proposed rule, EPA
received comments stating that EPA overestimated available capacity at this facility. In
response to these comments, EPA contacted Medusa Cement, confirmed that'they are
authorized to accept petroleum refining wastes, and found no reason to revise its capacity
estimate;. As a result of these confirmations, EPA did not revise its previous estimates of
available capacity at.this facility. '; . .
National Cement Company, Lebec, California . "" .
This facility burns liquid hazardous waste in one long, diy. process cement kiln. .
Waste fuel is injected into the clinker discharge end of the kiln. Based on reported
maximum practical burning capacity, and 1991 capacity utilization, EPA estimates that
the facility has 742 tons of capacity available per year. The liquid combustion capacity
was reduced by the standard 10 percent used for existing capacity. This facility does not '
plan to burn F037 and F038. It is authorized to burn Kl 17 and K118, and its total
permitted bromine limit is 3.8 percent. This facility did not report plans to change its
hazardous waste combustion practices before 1994i' . .' .
River Cement, Festus, Missouri (Cemtech) ' " ' "
.../.". ' "
River Cement burns liquid and sludge hazardous waste fuel in two' dry process
cement kilns. The facility filters liquid hazardous waste and grinds sludges, before'
blending the two and pumping the hazardous waste fuel into the clinker discharge end of
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'the kilni Based on reported maximum practical feed rates and 1991 waste volumes,.EPA
estimates that the two kilns have 24,550 tons per year liquid hazardous waste capacity
available, 8,862 tons per year pumpable sludge capacity available, and 1,256 tons per year
noripumpable. sludge capacity available. The standard approach of reducing existing
capacity estimates was used to-adjust this facility's reported capacity estimates. This
facility is authorized to burn newly listed F037 and F038 wastes. It is authorized to burn
K117 and K118 in trace amounts. This facility is considering adding dry solids capacity
and a sludge pump. . . . -.
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San Juan Cement, San Juan, Puerto Rico (ESSROC)
. . This facility burns liquid hazardous waste in .one wet process kiln and one dry .
process with preheater .Hazardous waste feed is pumped into the clinker discharge end
' of the kiln. Based on the reported'maximum practical feed rates and 1991 waste
volumes, EPA estimates.that the two kilns have 30,969 tons per year of available
capacity. The estimate for one kiln was not adjusted due to the high utilization rate, and .
the available capacity for the other kiln reflects the standard 10 percent reduction for
existing capacity, discussed in the methodology section above. This facility did not report
bromine limits or-its ability to burn K117 and Kl 18.
;' ' ' " \
Southdown, Inc., Fairborn, Ohio ...
Southdown's Fairborn, Ohio facility burns liquid hazardous wastes in one dry
process cement kiln with preheater. The waste fuel is injected into the.clinker discharge
end of the kiln. Based on reported maximum practical feed rates and 1991 waste ,
volumes, EPA estimates that the facility has 13,022 tons per year of liquid combustion
capacity available.. These estimates reflect the standard 10 percent reduction for existing
capacity discussed,in the methodology section above. At present it is only permitted to
burn characteristic metal wastes, D001, and F001, F002, F003, and F005. It is modifying
its RCRA permit to receive additional wastes, including F037 and.F038. This facility did
not report plans to bum K117 and Kl 18.wastes.
- Southdown,.Inc., Knoxville, Tennessee (Southdown) . . .
This facility burns liquid and containerized solid hazardous waste fuel in one four-
stage cement kiln with preheater and precalciner. Based on reported maximum practical
feed rates and 1991 waste volumes, EPA estimates that .the facility has ;13,64I .tons per
year solids capacity available, and 7,842 tons per year liquids capacity available. Liquid
capacity was adjusted with the existing capacity adjustment factor of 10 percent. The
estimate for containerized solid capacity reflects adjustments for both new and existing'
capacity, discussed in the methodology section above* This.facility is hot authorized to
receive K117 and K118. The bromine content of waste fuels is limited by the total
permitted halogen limit'of 5 percent. This facility is currently not permitted to burn
F037 and F038.wastes, but has submitted a permit modification .to add these wastes.
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State and regional EPA offices confirmed that approval is likely before May I
facility reported plans to construct a liquid hazardous waste storage facility in
2314 Sludge and Solid Cement Kiln Capacity Beyond May 1992
Several firms reported plans to add: new sludge and solid capacity between May
4992 and May 1994.. EPA did riot include these.planned capacity increases in j(s estimate
for May. 1992 available capacity. The following three facilities are currently bijfnine
.hazardous waste, and planning to. increase or expand their solids combustion "
Ash Grove, Foreman,. Arkansas, currently burns liquids and containerized
solids, and is planning, to increase solids capacity at an unspecified future
. time; . . . . ' ' . . ..' ' '"''.
Lafarge, Paulding, Ohicyis currently burning liquids but planning to add dry.
.' ' -solids capacity in 1992 or 1993; and - *
Lone Star, Green Cattle, Indiana currently' burns liquids and coniqjncrized
solids, and is planning to add dry solids capacity in 1993.
Ten facilities that are not expected to burn hazardous waste in May 1933 have
plans to add sludge or solid hazardous waste capacity before 1994. Together tj[CSe
facilities have thirteen cement kilns. The activities of these facilities, as each prepares to
burn hazardous waste fuel, are summarized below. EPA did not include the ca.fiacitv
from these facilities in its estimate for May 1992 available capacity. . '
Ash Grove West, Montana City, Montana
, ..The Ash Grove West Montana City plant operates 'one wet process c'em&ht kiln
It does not currently burn hazardous waste, but'this facility intends to begin in l99">
pending a public hearing. Because of the possibility of delays in coming on lin&. jls"r
capacity is not included in the projected May 1992 total. Ash Grove West p!an§ to burn
containerized solids only, with an annual capacity of 5,000 tons in 1992, increasing ,o
12,000 tons by 1994. ,. . ' , . . . - 8 '
Ash Grove West, Leamington, Utah
The Ash Grove Leamington plant operates one dry process kiln with a ^ stace
preheater and precalciner. It does not currently burn hazardous waste, but inte-ty,, to
begin in 1992, pending the lifting of the- Utah moratorium on the use of cemen.V kilns to
burn hazardous waste. Because of the possibility of delays in coming on line, US canacitv
is not included in the projected May 1992 total. This facility plans to burn 250fi ,0ns of
containerized solids in 1992, increasing to 12,000 tons per year by 1994 '
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' Blue Circle Cement, Atlanta, Georgia (Ccmtech)
Blue Circle Cement is operating two dry process cement kilns. They. do not
currently burn hazardous waste, but intend to begin in 1992. This schedule will depend,/
on construction of. a .receiving storage facility in I9'JI and early 1992, and receiving
Interim Status in 1991. The "facility has proposed to feed liquids and dry solids to the . ,
clinker discharge end of the kiln, and containerized solids to the calcining zone. FQ37
' and F038 are among the waste codes on its permit .-ipplication. The facility did not
indicate plans.to bum K117 and Kl 18. , \ .- - -
Blue Circle Cement, Tulsa, Oklahoma (Cemtech) ,
This facility is operating two dry process cement kilns, and is intending to begin
burning hazardous waste in 1992. This facility plans to burn liquids,' pumpable sludges,
and dry solids. It is. in the process of constructing a receiving and storage facility. The
facility intended to qualify for Interim Status under the BIF rule during the third quarter
of 1991. The facility intends to accept newly listed F037 and F038. wastes, but did not
indicate plans-to accept Kl 17 and Kl 18. ' . .
. ESSROC, Speed, Indiana (Cadence) . ( ' .
* >
This, facility is planning to burn containerized solid hazardous waste fuel. The facility
indicated that they are currently awaiting EPA permit processing, and could begin
burning hazardous waste in 1993. The facility did nol indicate whether they intend to
burn F037 and F038 or K117 and K118, and did not indicate a bromine or halogen limit."
Kosmos Cement Company, Louisville, Kentucky (Southdown) .. '
This Kosmos Cement facility operates one dry process cerrien't kiln with preheater.
It has completed all the necessary construction for liquids burning, and intends to begin
burning hazardous wastes in January, 1992. It is still awaiting its RCRA Part B permit
and its Jefferson County air permit. Equipment for feeding solid fuels to the kiln 'will be
added after obtaining the necessary air permit for solids and tires burning. F037 and
F038 are included on its permit application. EPA did not include this capacity in its . '
estimate of May 1992 available capacity. .-
Kosmos Cement Company, Pittsburgh, Pennsylvania (Southdown) .
' ' " ' .
This facility is operating one wet process rotary, cement kiln. The facility is
awaiting a permit from the Allegheny County Bureau of Air Pollution Control, which
must be approved 'before they can begin installing the containerized solid injection port
in the kiln. Then they will pursue RCRA Interim Stsitus, and a RCRA Part B permit.
F037 and F038 are included in the wastes on its permit application. EPA did not include
this capacity in its estimate of May 1992 available capacity. . .
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Medusa Cement, Clinchfield, Georgia (Cemlech) .'..''. .;
. This facility is operating one preheater cement kiin, but is not currently burning
hazardous, waste. It is planning to begin accepting hazardous'waste in 1992. They have
proposed to inject liquids and sludges into the clinker discharge end of the kiln, During
the fourth-quarter of 1991. and the first quarter of 1992, they will be constructing a
receiving and storage facility, and they will pursue Interim Status during the-third quarter
of 1991. F037 and F038 are included on its permit application. EPA did-not include'this
capacity in its estimate of May 1992. available capacity since, they are not yet operating. '
Southdown, Inc.,. Brooksville, Florida . : -
The Southdown Brooksville facility currently operates two dry process cement
kilns' with -preheaters. It is-not burning hazardous waste at this time, but is in the.process
of installing a baghouse exhaust filter on one kiln. Following the Florida Department of
Environmental Regulation's (DER) approval of a testpurn they will begin installing tire
and container injection mechanisms into both kilns. It will then seek its RCRA Part B-
permit and adjust its nitrogen dioxide and sulfur dioxide emissions level for Prevention of
Significant Deterioration (PSD). F037, F038, K117 and KJ18 are included .in its permit
application. EPA did not include this capacity in its' estimate of May 1992 available
capacity since they are not yet operating. ' . ."''. ..
Southdown, Inc., Odessa, Texas . . ' "
- Two dry process rotary cement kilr.-, one with a preheater, are producing clinker
at this facility. The facility is in the earliest stages; of planning to burn hazardous waste
and estimates it will begin burning in 1994. F037 and F038 are included in its permit
application. EPA did not include this capacity in'its estimate of May 1992 available
capacity since they are not currently burning hazardous waste. '
' In summary, thirteen facilities reported plans to increase their hazardous waste
burning capacity before May 1994. This increase in cement kiln capacity.will add an
estimated 98,500 tons to the national estimate of sludge and solid combustion capacity,.
Five' facilities, with 8 units together, reported plans to add or increase - .
containerized solids capacity. Assuming an average available capacity of
. 9,000 tons per year,'based on utilization rates of facilities currently burning
" containerized solids hazardous waste fuel, this will add. 72,000 tons of
. available cement kiln capacity per year by May 1994. . . .
Four facilities, operating seven units together, reported plans to add or
. increase dry solids capacity.. Assuming an average available capacity of
2,500 tons per year, based on utilization rates of facilities currently burning
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dry solid hazardous waste fuel, this will add 17,500 tons of available cement.
kiln capacity per year by 1994. . . .
- ' - " . '
. . Two facilities, together operating three units; reported' plans to add sludge
:burning capacity. Assuming an average available capacity of 3,000 tons per
year, based on utilization rates of facilities currently burning hazardous
waste- fuel, this will add 9,000 tons of available cement kiln capacity per
yearbxl994. "...
23.5 Facilities not-Included in this Capacity Analysis '
According to a February 25, 1991 memorandum from CKRC to EPA, several
Holnam and Continental Cement facilities have sludge and solid combustion capacity. It
is uncertain whether Texas Industries has solids capacity. Due to the uncertainty
regarding. the form in which they will accept wastes; and their capacity, these facilities are
hot included in this capacity analysis.
. Exhibit 2-7 summarizes facilities not included in this capacity update due to a lack
of detailed information.'regarding capacity. .''..' '
23.6 Packaging Capacity for the Cadence Solids Fuel Technology at Cement
" ' Kilns ' . .' / -_'/' . i ".',.- .
'',.' .-.... ' . .
Most of the solids combustion capacity at cement kilns comes from kilns equipped
with a technology developed by Cadence Chemical Resources Incorporated and Ash
Grove Cement Company. This technology-allows intact containers,' generally six-gallon .
pails or ten-gallon bags, to be fed to the cement kiln's calcining zone. To be fed to kilns
via this technology, .wastes must be packaged into appropriate containers. The
availability of this packaging capacity is integral to the utilization of cement kiln capacity .
for burning containerized wastes. During the public comment period, EPA received ' ,
several comments questioning the availability of packaging capacity.- In response to these
concerns, EPA contacted several fuels blenders and other waste processing firms to
assess the availability of packaging capacity. Phone logs documenting these calls can be .
found in Appendix C. The remainder of this section summarizes EPA's findings
. regarding the availability of packaging capacity.
(i S .»
- -EPA identified waste fuel processing firms from" the CKRC survey results. V
this approach, EPA hoped to target the largest providers of fuels processing and
packaging capacity. As a result of these calls, EPA identified approximately '66,000 tons
of packaging capacity in place at processing facilities (the current utilization rate of this
capacity is unknown), and 60,000 tons, of .currently unutilized mobile packaging capacity
which is not presently in 'place at a processing or waste generating facility (because it is in
'storage). EPA has identified the following sources of. packaging capacity:
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.'.-' Exhibit 2-7 ,
Facilities not Included in Capacity Analysis
because Detailed Capacity Data Was Unavailable . .
Facility Nome and Location I>pes of Wastes Burned .
Carolina Solite, Albemarle, NC
Continental Cement, Hannibal, .MO
Florida Solite,: Green Cove Springs, FL
Gifford Hill, Midlothian, TX , - '
Hplnam; Clarksviile, MO , , '
Holnani, Santee, SC
Kentucky Solite, Brooks, KY
Independent Cement, Hagerstowri; MD
Lehigh Portland Cement, Cementon, NY
Lehigh 'Portland Cement, Union Bridge,
MD
Missouri Portland Cement .'
Independence, MO
Monarch Cement, Humboldt, KS
. Ndrlite, Cohoes, NY
Phoenix Cement, Scottsdale, AZ . .
Solite, Arvonia, VA .
Solite, Cascade, VA ' '
St. Mary's Peerless, Detroit, MI
Texas .Industries, Midlothian, TX '
liquids . -.'..
liquids, solids . '
liquids . ;
liquids .
liquids, solids .
liquids " ' . ,
liquids, solids . >
uncertain .
' . * ' ~
uncertain '
uncertain " ' ''.'
uncertain , '
.uncertain ' . "
uncertain . ; '
uncertain . '
liquids '
liquids
liquids
liquids, solids . ' ' :
Cadence Chemical Resources currently operates,ah automated pailing
device in Chanute, Kansas. It's maximum practical capacity is :
approximately 14,000 tons per year (2 tons per hour operating 80 percent.
. .of the time) about 8,000 tons of which is available based on 1991 utilization
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Cadence Chemical Resources also operates a bagging system at the
Chanute, Kansas facility. It has a maximum practical capacity of roughly
, . 30,000 tons per year (processing 3 bags per minute, at 50 pounds per-bag
for 75 percent of the ..time). The utilization rate of this capacity is
unknown. ' ' . ''-..
Cadence also Has 60,000 tons of maximum practical bagging capacity in the
form of two idle rriobile units that it expects to lease to petroleum . .
refineries or fuels processors. . .
-1 '
' . OHM receives roll-off bins and transfers the wastes, to 55-gallon drums and
subsequently to six-gallon pails for cement kilns. OHM did not provide
estimates of available capacity for the system that filjs 6-gallon pails.
. . ,' PetroChem Processors currently processes about 7,000 tons of six-gallon
pails per year from its automated packaging system'(792 pails per day'
roughly 310 days per year) in Detroit, Michigan. The utilization rate of this
capacity is unknown. .. ' , . ,-
GSX processes wastes from roll-off bins and 55-gallon drums into six-gallon
' . pails at its facility in Crawley, Louisiana. 'About 5,000 tons per year of this
,. facility's 15,000 ton per year maximum practical capacity is available.5 -.
Alhvorth Inc. in Mount Pleasant, Tennessee; Spring Grove Resource
Recovery in Cincinnati, Ohio; Rhineco Chemical in Arkansas; and
Chemical Processors .Incorporated in Washington, also package wastes for
the Cadence system, according to the CKRC survey, but available capacity
\ -' estimates for these facilities were unavailable. - . ; ,
EPA has insufficient data to accurately estimate how much packaging capacity is
.currently available nationwide. .However, based on the limited information noted above,
the Agency estimates that at least 13,000 tons are available at existing fixed site facilities
and another 60,000 is available through unutilized mobile units. EPA also is aware that
some fixed-site fuel processors are not able to accept roll-off bins; EPA expects :
packaging'capacity to expand considerably; over the next six months to a year as.
additional packaging units are constructed and commissioned.. , '
- 5 Based on 70 percent utilization, overall waste receipts of 6,000 drums per month and 40 roll-off bins
per month, and roughly 40 percent of all wastes going through the packaging system ((6,000 drums/month
x 55 gallons/drum / 240 gallons per ion'+ 40 bins/month x 20 tons/bin)) x 12 months/year x 40 percent lo
packaging = 10,000 tons currently packaged at 70 percent utilization therefore approximately 5,000 tons per
year available). - ' .. . ' ' .
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' ' ' ' - '
2.4 OTHER TREATMENT SYSTEM CAPACITIES
This section discusses commercial treatment capacity other'than combustion for
the newly identified and listed .wastes. Specifically, it presents EPA's capacity analysis for
stabilization, biological treatment, and chemical.precipitation. Section 2.4.1 discusses the
general approach and assumptions EPA used for estimating available capacity for these .
technologies, and section.2.4,2 summarizes available capacity far newly listed and newly.
identified wastes. ; ' . ' -
2.4.1 General Approach and Assumptions
In analyzing alternative treatment capacity for stabilization, biological treatment, .
and chemical precipitation for newly identified and listed wastes, the Agency built on the
capacity analyses conducted for the Third Third LDR rule. This 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 and 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. ': ' . ..'.
In prior LDR ruleniakings, EPA updated the TSDR Capacity Data Set for critical
technologies based on confirmation of planned capacity changes, and other information
received since the survey (e.g:, comments on proposed rules). Updated information was
obtained'by contacting facilities 'arid verifying critical projected capacities reported in the
TSDR Survey. Based on the information provided by facility contacts, EPA determined
whether planned facility capacity had come on line 'as projected. For a more detailed
explanation of the TSDR Survey and of the Third Third Rule.refer to U.S. EPA,
Background Document for Tliird TJiird Wastes to Support'40 CFR Part 268 Land Disposal '
Restrictions, May 1990. .
2.4.2 Summary of Available Capacity for Biological Treatment, Chemical
Precipitation, and Stabilization
Exhibit 2-8 lists the maximum, utilized, and available capacities of commercial
.treatment systems appropriate for newly 'identified and listed wastes. The 1991 baseline
available capacity is the updated maximum (updated as described above) net of the 1986
baseline utilized-capacity. To estimate the capacity available for newly identified wastes,
the required capacity, for previous LDR rules.was subtracted from, the 1991 available
baseline capacity. For individual facility data refer to U.S. EPA, Commercial ,
Treatment/Recovery DataSet, May 1990. -. " ' - .- .
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Exhibit 2-8, .
DETERMINATION' OF AVAILABLE COMMERCIAL CAPACITY
FOR NEWLY IDENTIFIED AND LISTED WASTES
: Technology '
Biological' Treatment ;
Chemical Precipitation
Stabilization
, 1991 Baseline
Available
Capacity
(1000 tons/year)
196
1,413 .' '
3,125
Required Capacity,'
for Previous
LDR Rules
(1000 tons/year)
8.' '' ' ;
600 ,; .
,1,921 - ;
Capacity for
Newly Listed and
Identified Wastes
(1000 tons/year)
1S8
813 '
1,204 . .
Note: Totals may be inexact due to,rounding. . ..
Source: Background Document for. Third Third Wastes to Support 40 CFR Part
.. 268 Land Disposal Restrictions, May 1990 . ' ;.
.baseline capacity. For individual facility data refer to U.S. EPA, Commercial'.
Treatment/Recovery Data Set, May 1990. - .
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, CHAPTERS
CAPACITY ANALYSIS FOR F037 AND F03S PETROLEUM REFINING WASTES
3.1 INTRODUCTION . _ ,
This chapter describes the capacity analysis for newly listed F037 and F03S
petroleum refining wastes (hereafter referred to as F037/8). The overall purpose of this
analysis is to estimate the demand for commercial treatment/ recovery capacity as a
result of land disposal restrictions for F037/8. EPA compared this estimate of demand to
the estimate of available commercial treatment and recovery-capacity. This capacity
analysis incorporates data on F037/8 generation and management collected after the
proposed rule and was used to support variance determinations for F037/8 wastes. The
remainder of this introduction provides.background information on F037/8 and an
overview of the capacity analysis for these waste's. , '
. ; 3.1.1 Background. ' . ' . '
..." ;- - ' - - .' ' .'
The following sections provide background information oh the regulatory history <
of the F037/8 wastes, the industry and wastewater treatment processes that generate the
wastes, and the regulatory definitions of F037/8 wastes. .. - .
3.1.1.1 Regulatory History . ,
As a part of an October 21; 1980 amendment to RCRA, Section 3001 (b)(l)
requires that EPA identify and list all wastes determined to be hazardous. As a result,
two sludges from petroleum refining process operations (K050 and K052) and three'
petroleum refining wastewater treatment sludges (K048, K049, and K051), were .listed as
RCRA hazardous wastes in November 1980. In 1984, the Hazardous and Solid Waste
Amendments (HSWA) amended RCRA by instituting explicit new hazardous waste , . .
'management requirements, including land disposal restriction (LDR) schedules (Solvents
and Dioxins, California List, First Third, Second Third, and Third Third)1 for all listed.
hazardous wastes. K048-K052 were initially subject to LDRs as First Third Wastes, and
were subsequently re-evaluated as part of the Third Third final rule. The K048-K052
LDR prohibition did not become effective until November 8; 1990, due to a six-month ,
national capacity variance. The treatment standards for these wastes are based on
incineration (including reuse as fuel) and solvent extraction. . . '
1 The Federal Register notices containing the final land disposal restrictions schedules for these wastes'
are: Solvents and Dioxins - 51 Federal Register 40572, November 7,1986 (Surface Disposed) and 53
Federal Register 28118, July 28, 1988 (Underground Injected); California List - 52 Federal Register ,
25760, July 8, 1987 (Surface Disposed) and 53 Federal Register 3090S, August 16, 1988 (Underground
Injected); First Third - 53 Federal Register 31138, August 17, 1988 (Surface Disposed) and 53 Federal
Register 30908, August 16, 1988 (Underground Injected); Second Third - 54 > eleral Register 26594, June
23, 19S9 (AI! Land Disposed); Third Third - 55 Federal Register 22520, June 1, 1990.(A1I Land Disposed).
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After the K048-KQ52 listing was proposed, EPA received a rulemaking petition ,
that argued'that primary wastewater treatment sludges generated by petroleum refineries
(not just K048, K049, and K051) should be included in the listing because all such sludges
would be similar in composition. In response to this petition, the Agency proposed in. .
'November. 1980 that the K048-K052 listing be amended to include additional wastesvater
treatment sludges, from refineries. Since that time, EPA collected additional data .on
' these other.sludges and evaluated alternate listing descriptions working toward a final
listing rule. '.._. . _ '
F037/8 petroleum refining wastewater treatment sludges were listed as hazardous
on:November 2, 1990 (55 Federal Register 46354). The listing became.'effective in April
1991 arid LDR standards for these wastes were proposed on January 9, 1992 (57 Federal.
Register 957). These sludges are chemically and physically similar to K048-K052;
therefore, when the LDR becomes effective, the F037/8 wastes will likely compete for
, treatment/recovery technologies used to treat K048-K052. , .
, * . ~ '
. A related rule to the F037/8 listing rule is the Toxicity Characteristic. (TC) rule
that was promulgated on March 29, 1990, and became effective on September 25,-1990
for large quantity generators and treatment, storage, and disposal facilities. The TC-ruIe
', became effective for small quantity generators on March 29, 1991. Previous F037/8
studies, such as the. background document for the. listing of F037/8 wastes,^ indicated
that a large portion of F037/8 wastes exhibit the TC. As a result of the TC rule, some
refineries may have reconfigured their wastewater treatment system so that sludges
exhibiting the TC are not generated. For the capacity analysis, EPA considered the -.,.'
effect' of the" reconfiguration of wastewater treatment systems on the amount of F037/8 '
generated. , ..' . , , ' . ' . ;
3.1.1.2-' Industry and Waslewater Treatment Process Overview
At the beginning of 1991, there-were 194 known operable petroleum refineries in
the United States.3 These refineries were spread across'the country in 35 states, but 41
. percent (80 refineries) were concentrated in just three states: Texas, Louisiana, and ;
. California. Virtually all refineries generate a variety of oily wastewaters, including '
process wastewaters, wastewaters associated with the storage and shipment of crude oil' '. -
and products, wash waters, and cooling system wastewaters. These oily wastewaters are
commingled, sometimes with oil-free stormwater mnbff, and are either treated in an.on-.".'
site wastewater treatment facility and discharged to surface waters- or are pretreated on '
2 Midwest Research Institute, Estimates of Wasie Generation by Ihe Peiroleum Refining Industry.
Draft Report, prepared for ihc Office of Solid Waste, EPA, October 29; 1987; and Midwest Research
Institute, Summary of Data and Engineering Analysis for Pciroleum Refining Wastewater Treatment
Standards. Final Report,' prepared for the Office of Solid Waste," EPA, April 8, 1988. .
3 Thrash, L.A, "Annual Refining Survey,* Oil and Gas Journal. March 18, 1991.
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site arid discharged-to an off-site wastewater treatment facility. Discharges to surface,
waters are controlled under the National Pollutant Discharge Elimination System
(NPDES), while releases to publicly, owned treatment works (POTWs) arc subject to
state arid national pretreatment standards.
'. ' Although wastewater treatment systems vary from one refinery to another, these .
treatment systems follow a general pattern. Exhibit 3-1 presents a simplified block flow '
diagram of the common treatment steps, which are described below.
/. . .. ......' '
' . . Wastewater "influent" from refinery operations enters a series of.
QilAvater/soh'ds separation steps, collectively referred to as primary
' ' treatment. Process wastewaters may be commingled with stormwater.
' runoff in.a non-segregated system. The primary treatment system may be .
broken down into primary and secondary separation. '.«;
Primary separation is generally characterized by gravitational separation,
during which solids settle to'the bottom and oil floats to'the top and is .
skimmed off. The API separator is the most widely used gravity separator.
Primary separation sludge can also be generated^by corrugated plate
interceptor (CPI) separators, settling ponds, stormwater ponds that receive/
oily wastewaters, and drainage and collection systems. . ..'"
.- , ' , "' .''*' -' '
' Secondary separation is a primary treatment that is intended to remove
suspended solids and emulsified oils that are not readily separated by
gravity. Air floatation units, such as dissolved air floatation (DAF) and
. .' induced air flotation (IAF) units, generally are used for secondary
separation. In addition, secondary .separation may be performed by
oxidation ponds and flow equalization tanks. '. ' . .
. Following secondary separation, wastewater enters secondary or biological
treatment, and is then discharged after treatment. ;
3.1.1 J Waste Stream Definitions ' ' ' :
Based on the listing descriptions for K048, K049, and K051, these wastes .
encompass only certain sludges generated in specific units in the primary wastewater
treatment process. In particular, K048 is DAF float, K049 is slop oil emulsion solids, and
K051 is API separator sludge. .The newly listed wastes, F037 and F038, effectively
include all other primary and secondary oilAvater/solids separation sludges that are not
already generated as either K048 and K051. The listing descriptions for these F wastes
are as follows: . ' ' . ,
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EXHIBIT 3-1
SIMPLIFIED BLOCK FLOW DIAGRAM OF
COMMON WASTE\VAT;ER TREATMENT STEPS
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" F037: Petroleum refinery primary oil/water/solids separation sludge - Any
. " sludge generated fronj the gravitational separation of oilAvater/solids during
" the storage or treatmenfbf process wastewaiers'and oily cooling
. wastewaters from petroleum refineries. Such sludges include, .but are not
limited to,-those generated-in dil/water/solids separators; tanks and
impoundments; ditches and.other conveyances; sumps; and stormwater
; ' units receiving dry weather flow. Sludges generated in stormwater units
; -that do not receive dry weather flow, sludges generated from non-contact .
once-through cooling towers segregated for treatment from other process
. . cooling waters, sludges generated in aggressive biological treatment units as
. defined in 40 CFR 261.3 l(b)(2) (including sludges generated in one or
more additional units after wastewaters have been treated in aggressive
biological treatment units) and K051 wastes are not included in this listing. .
* FQ38: Petroleum refinery secondary.(emulsified) oil/water/solids separation
sludge - Any sludge and/or float generated from the physical and/or " -.
chemical separation of oil/water/solids in process wastewaters and oily
cooling wastewaters from petroleum refineries. Such wastes-.include, but
are not limited.to, all sludges and floats generated in induced-air'floatation .
(IAF) units, tanks, and impoundments, and all sludges generated in DAF
, . units. Sludges generated in stormwater units that do not receive dry
weather flow, sludges generated from non-contact once-through cooling.
towers segregated for treatment from other process or oily cooling waters,
sludges generated in aggressive biological treatment units as defined in, 40
> CFR 261.31(b)(2) (including sludges generated in one or more additional
units after wastewaters have been treated in aggressive biological treatment
units) and F037, K048, and-K05l wastes are not included in this listing.
3.1.2 Overview or (Capacity Analysis . .' ,.,.
-.' - ' ' ', ' '-.'''' " '' ? -. -
This capacity analysis consisted of three genera! tasks: . . .. -
' ' 'Collect information on waste generation, chemical/physical characteristics...
type and concentration of constituents, waste treatability, and current and
' -. potential management practices (treatment, storage, disposal, and recycling)
of F037/8 petroleum refining hazardous wastes that will be restricted from
land disposal. -For example, EPA collected F. waste information from
voluntary data submissions by refineries and from visits to individual
. . 'facilities and companies that own and operate refineries. , .
Develop algorithms for quantifying the F037/8 generation rates at facilities
for which EPA had limited data. EPA used previously reported K waste r
generation and other information to develop a "material-balance" estimate
of F037/8 waste from each wastewater treatment unit, tank, and surface
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impoundment. If K'waste generation and the facility's, waitewater
treatment configuration were, not available, information on crude processing
capacity and engineering judgement were used to'estimate F037/8
. generation rates. ' '
. Quantify alternative commercial treatment or recycling demand (i.e.,
national demand, for on-site and commercial capacity) that will be created
-. '" by the shift of F037/8 petroleum refining wastes away from land disposal at
* the expected effective date of the LDR (June 1992); and for the two-year .
. '.- ' .."variance window" following the final rule; (until June 1994).
' : '.'' '
The remainder of this chapter consists of three sections. Section 3.2 describes'the
data'sources-used in the analysis. Section 3.3 provides details of the methodology used
for the capacity analysis, discusses the factors affecting the analysis for F037/8 wastes, and
provides estimates' of the quantities requiring off-site treatment. Section 3.4 presents the
results of the comparison,of alternative and required capacity.
'Appendices of the Background Document accompany this chapter. Appendix D "
contains the interview guide and information obtained from contacts with petroleum
refineries. Appendices E and F present the.calculations that EPA used for estimating
F037/8. waste generation. . . '
3.2 DATA SOURCES .
...' For this capacity analysis;" EPA identified a variety of potentially useful data
sources, and then collected and examined them for use in estimating F037/8 waste.
generation. As a result of.this data identification, collection, and evaluation effort, EPA
used the following data sources:. , .
.' Petroleum refinery visits; ."'.' ' . '
' f '"',.' . -
Information submissions from'refineries; ' ' . ' '
Comments in response to "Advanced Notice of Proposed Rulemaking for
"'. Newly Identified and Listed Wastes" (ANPRIvH (56 Federal Register 24444. '
' May 30, 1991);
.. . .«' F037/8 Regulatory Impact Analysis (F037/8 RIA) for Final Listing;
' National Survey of Hazardous Waste. Treatment, Storage, Disposal, and
; Recycling Facilities (TSDR Survey);
.. TSDR Capacity Data Set;
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National Survey of Hazardous Waste Generators (Generator Survey);
- Petroleum Refinery Data Base (PRDB);
Reports on the F037/8 listing rule; '. , '
No-migration petitions; . ' ' '. ....
Comments received in response to the proposed.nile (57 Federal Register
- - 957, January 9,. 1992); . . , .., .
Data from the American Petroleum Institute (API) Survey; and . -..
' ' Data from the Toxicity Characteristic (TC) Questionnaire.
All but the last two sources were used for the capacity analysis conducted for.the
proposed rule. Comments received on. the proposed rule and data from the TG'.
questionnaire'were available only for the final rule analysis. Exhibit 3-2 summarizes how
this information was used in the capacity analysis.
EPX reviewed several additional data sources bin did not use them for the
analysis.. .;..- . ' ' ' -
,» .. Corrective Action Regulatory Impact Analysis. Data Base; . '.
Biennial-Report/State Reporting Requirements; and ..
California Hazardous Waste Data Base. ..-'
. Each data source, as well as the reason it was or was not used'in the F037/8
capacity analysis, is briefly described in the remainder of this section. Section 3.3 then .
describes in more detail the data sources that were, used, and how they were used,
3.2.1 Data Sources Used For F037/8 Capacity Analysis
: Petroleum Refineiy Visits, EPA visited .four refineries to collect information on '
F037/8 generation and management. For these visits, EPA prepared an interview guide
.(see Appendix D) to obtain information on waste generation and management,
wastewater system modifications planned for the upcoming F037/8 and TC LDRs, and
. chemical and physical characteristics that affect treatability. From these visits, EPA
obtained reliable estimates of the quantities of F037/8 wastes that will require alternative
commercial treatment as a result of the LDRs. Appendix D presents the interview guide
that was used, as well as the information obtained during these visits.
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' - ' . 3 - 8 . ;
EXHIBIT 3-2
SUMMARY OF DATA SOURCES USED,IN F037/8 CAPACITY ANALYSIS
Data Sources
Petroleum 'refinery
. . - ' . visits'
Recent information
submissions '
Comments on. the
ANPRM
F037/8 Regulatory
Impact Analysis
TSDR Survey
TSDR Capacity Data
Set
National Survey of
Hazardous Waste
Generators
Petroleum Refinery
DataBase'
Reports on the F037/8
Listing Rule
No-migration Petitions
Comments ori trie
. Proposed Rule
Data from
the API Survey
Data from the TC
Questionnaire
"V
How Used in F037/8 Capacity Analysis ,
Provided, reliable estimates of quantities of F037/8 wastes ,
for four 'refineries, '
Provided reliable. estimates of quantities of F03.7/8 wastes .
for 25 refineries. . . ,. ' . .
Provided information on F037/8 waste generation,
management, and treatment.' ' . ,
Provided an industry overview and profile of affected
. facilities, an analysis of baseline waste management
practices, and regulatory compliance scenarios.
Provided information on the generation and management of
the related KQ48-K052 wastes, and on wastewater treatment
system configurations. ' ' '';
Provided information oh required capacity for K048-K052
waste streams,. and on available capacity of hazardous waste>
management technologies. .
Provided information on the generation and management of
the related K048-K052 wastes, and on wastewater.treatment
system configurations. /'.'
Provided information on the characteristics, quantities, and "
management practices of primary wastewater sludges.
Provided information oh F037/8 waste generation rates, '.
physical and chemical waste characteristics, and wastewater
treatment block diagrams for 16 refineries. .
Provided information on wastewater' treatment, . .-. ,
configuration, and petroleum refining waste generation and
management.' ' . . . /
Provided information on F03 7/8 waste generation, ' .-.
management, and treatment. ' '
Provided(estimates'of waste generation and management at
petroleum refineries in 1987 and 1988. ".'
Provided information on" generation of wastes from the
retrofitting or closure of surface impoundments, and from
cleanout of tanks that will replace impoundments.
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Recent Information Submissions. EPA reviewed information voluntarily
submitted by 25 refineries for'the proposed F.037/8. waste LDR rule. EPA provided a
recent information submission guideline (similar to the guide used for facility visits) to .'
refineries that requested it so that they could provide informalion useful for the ,
capaciryanalysis. This information, which is presented in Appendix D, was evaluated in
detail for the F037/8 capacity analysis. -
Comments on the "Advanced. Notice of Proposed Rulcmaking for Newly Identified
and Listed Wastes." Ten comments were received in response to the ANPRM.4' These
comments, which were submitted by refineries, trade organizations, and suppliers of
hazardous waste treatment technologies, 'contain information on F037/8 waste generation,
management, and treatment. Information from- the comments was used in this report .to
note limitations to the methodology as well as provide data supporting the analysis. .
These comments are briefly summarized in. the relevant sections of this report.
F037/8 Regulatory Impact Analysis. The,F037/8 Regulatory Impact Analysis
(RIA)5 was prepared in 1990 for the F037/8 listing rule.6 The RIA provides an
industry overview and profile of affected facilities, an analysis of baseline waste
management practices, regulatory compliance scenarios, economic costs and benefits of
the' listing, product price and international trade impacts, and a Regulatory Flexibility
Analysis. ' ' . : . . ,
For the RIA, EPA conducted sampling .visits at 16 petroleum refineries to
determine the characteristics of sludges generated in primary and secondary wastewater
treatment units, and to supplement the information gathered from other sources. During
the visits, EPA collected information on wastewater treatment system configurations,
effectiveness of. oil/water/separation practices, and sludges samples generated from these
units.7- ,-'' ' . . '',-.'
EPA developed a data base for the RIA, referred to as the EPA/RIA data base,
using data from the Petroleum Refining Data Base (PRDB) (see below), sampling visits,
and wastewater treatment flow 'diagrams submitted with RCRA Section 3007
* EPA, "Advance Notice of Proposed Rulemaking for Newly Identified and Listed Wastes," 56 Federal
Register 24444. May 30. 1991. . . . ,-r '' .
5 DPRA Inc. and 1CF Incorporated, Regulatory Impact Analysis for ihe Listing of Primary and :
Secondary Oil/Water Solids Separation Sludges from the Treatment of Petroleum Refinery Wasiewaters.
prepared for fbe Office of Solid Waste, EPA,' October 1990.- ',',''
* EPA, "Hazardous Waste Management Systems: Identification and Listing of Hazardous Waste; Final
Rule." 55 Federal Register-46354. November 2. 1990. . .
7 Data from the sampling visits were presented in: EPA,'Notice of Data Availability," 53 Federal .
Register 12162, April 13, 1988. ] - '.'..'. ' ' .'.'
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questionnaires sent by EPA to petroleum refineries-in 1984 (to gather information on
1983 operating characteristics). 'The data'base listed facilities-by groups based on
wastewater treatment system configurations and impoundment categories. The data base
contains data on approximately 190 facilities. EPA also incorporated sampling and
characterization data from a series of reports8 that were used in the development of the
1990 Toxicity Characteristic rule and the F037/8 listing riile. Some facility-specific
information from the RIA was used in'the F037/8 capacity analysis.- Furthermore, some
of the aggregate quantities (e.g., total F037/8 generation) were compared with the results
of the capacity analysis. ' L - ' . ' . .
' i " ;
; National Survey of Hazardous Waste Treatment, Storage, Disposal, and Recycling
Facilities (TSDR Survey). The National Survey of Hazardous Waste Treatment, Storage,
Disposal, and Recycling Facilities (TSDR Survey) was mailed in the fall of 1987. The .
TSDR Survey requested information on waste quantities and waste management
practices for the entire year of, 1986, as well as on any projected changes in waste '.
management capacity prior to 1992. The TSDR Survey, included approximately 2,500 '
facilities that manage hazardous wastes on site. These facilities include all/of the 2,400
RCRA-permitted or interim status treatment, disposal or recycling facilities; plus about
100 of the 700 facilities that only store wastes. All petroleum refineries 'that are classified
as TSDRs were included in this survey. > . -
..'.' ,i
EPA asked for several types of information in this' survey, including:. '. . . ."
. facility EPA identification, location, and regulatory and operating status; '
. > waste types, characteristics, quantities, and residuals; -.
' waste management practices (both for exempt and non-exempt systems);
'.' description of on-site processes, operations, and equipment; and .
, capacity information (both current and future).
V . ' EPA could .not use this survey to determine the exact quantities of F037/8 .wastes .
requiring treatment, since these wastes were not identified or'listed as hazardous until
after 1986 and, therefore, were not included in the survey. However, this survey
provided information on the generation and management of the related K048-K052
wastes, and on facility schematics. EPA used this information and a material-balance
calculation approach to estimate F037/8 generation rates/ ,' . .' .-.
EPA identified petroleum refineries in the TSDR Survey by searching the TSDR.
Capacity Data Set (see below) for any facility in the TSDR Survey .with a 29XX SIC code
(i.e., petroleum refining and' related industries). Eighty-nine refineries were identified.
' ,8 Midwest Research Institute. Estimates of Wasie Generation bv ihc Petroleum Refining Industry.
Draft Report, preparoi for the Office of Solid Waste, EPA. Ociobcr 29. 1987;.and Midwest Research
Institute, Summary of Data and Engineering Analyses for Petroleum Refining Wasiewaier Treatment
Standards. Final Repon. April 8..1988. . ' ' , ' .
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,.~ , EPA reviewed the.TSDR facility'schematics to determine the configuration of the
wastewater. treatment questionnaires to extract appropriate information for the F037/8
capacity analysis. ' . ' v ,
. . . -TSDR Capacity Data Set. Some of the information from the TSDR Survey had
been used to derive the TSDR Capacity Data Set. The TSDR Capacity Data Set was
7) created based on selected responses from the TSDR Survey. This data set contains
,v; information on required capacity for waste streams managed in land disposal units, and
on available capacity of hazardous waste management technologies. Some of the
- capacity data from the TSDR Survey have been updated through 1988.
Vf , ' - . > ''.:.
The limitations.of this data set are the sam'e as'the limitations of the TSDR .
;AJ ' Survey. EPA used the.TSDR Capacity Data Set to identify the petroleum refineries who
i: . responded to the TSDR Survey. ' . . .
~ . , National Survey .of Hazardous Waste Generators (Generator Survey).-The . '/,
' " ., National Survey of Hazardous Waste Generators-(Generator Survey) was mailed in the
fl ( .-. fall of 1987 and requested information'on waste quantities arid waste management
. . practices for the entire year of 1986, as well as on any projected changes in treatment
capacity prior, to 1992. EPA. included approximately 6,200 facilities in the Generator
Survey.. All treatment, storage, and disposal facilities (TSDFs) surveyed in the TSDR
Survey were included in the Generator Survey." EPA.also included the 1,000 largest U.S..
"~ hazardous.waste generators and a statistical sample of large quantity hazardous waste
generators for each state. About 5,600 facilities' responded to the survey. ' ;
"*."-. This survey was designed to obtain information on the quantities and
-'."". characteristics of hazardous waste generated in the United States. .In addition, the survey
' ' provided capacity information for facilities not included in the TSDR-Survey {e.g.,
facilities that manage wastes in RCRA-exempt units). EPA asked for several types of
information in this survey, including: ...''
.. facility EPA identification, location, and regulatory and operating status;
waste identification,-characterization, and quantities;
.. : waste generation, shipment, and management practices;
' description of on-site processes; ''...: . :
capacity .information; and .-'.-. ..
,.^« . ' waste minimization information. . , -. .
., EPA could not use this survey to determine the exact quantities of F037/8 wastes
. > requiring treatment, since these wastes were not identified or listed as hazardous until
after 1986 and, therefore, were not included in the survey. However, this survey
provided information on the generation and management of the related K048-K052
." wastes, and on facility schematics. EPA used this information and.armaterial-balance
calculation approach to estimate F037/8 waste generation. . ,
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Petroleum Refinery Data Base. The Petroleum Refinery Data Base (PRDBj9 is
a major data source on primary wastewater sludges from petroleum-refineries and is
based on a mail survey conducted by EPA during 1983, and includes revised 1985
information for some of the major facilities.- The -survey .questionnaire asked for several
types of information.including:. ' " .-..''
', refinery capacity; . . . , .' '
' crude oi! types; ' ' ' . . . .
.. . product types, and quantities; ' . >
V process descriptions; - '
. ' . wastewater flow rates; -.'_'.-
. process, slop. oil.systems,-and wastewaters treatment flow diagrams; and
! generated residue characteristics, quantities, arid management practices.
The data base contains information from 1983 for 182 of the 220 petroleum refineries7
listed as operating in 1984. However, only 166 refineries of the sample in the data base
- were still operating in the.beginning of 1991, the others having .been closed since 1983.
During the same period the total number of operating refineries decreased from 220 to
194.",. . ' / I"..'' '';''.'..
The refineries represented in the PRDB were distributed across the country in 35
states, but 43 percent (88 refineries) were concentrated in just three States - Texas,
Louisiana, and California.10 The refineries that were not included in the PRDB are
generally small topping_and asphalt plants and account for less than five percent of the
industry, -based on daily crude throughput: 5 > . . . '
. The.PRDB classifies refinery wastewater treatment systems into several broad
configurations. EPA used these classifications for the F037/8 capacity analysis to
estimate the quantity oif F037/8 generated at operating refineries! . , ' .
Reports on the F037/8 Listing Rule. EPA developed two reports,11 one in 1987
and the other in 1988, in support of the F037/8 listing and the Toxicity Characteristic
rule. These reports summarize sampling and analysis data collected by EPA's Office .of..
Solid Waste for 16 petroleum refining facilities. These reports contain several types of
information including: ' . '..'... ' ' ,
S. rr.
; * The PRDB coniains confideniial business information (CBI). Access to the PRDB was obtained
through the RCRA CBI document. '. ... . '
'.° Thrash, L.A., "Annual Refining Survey,' Oil and Gas Journal. March 18,1991.
11 Midwest Research Institute, Estimates of Wasie Generation h'y the Petroleum Refining Industry..
Draft Report, prepared for the Office of Solid Waste, EPA, October 29, 1987; and Midwest Research
Institute, Summary of Data and Engineering Analyses for Petroleum Refining Wasicwalcr Treatment
Standards. Final Report, prepared for the .Office of Solid Waste, EPA, April 8, 1988. "...
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__ .... generation rates; ' .
physical and chemical waste characteristics; ,
' ' . « waste management practices; and : . . : .
__ wastewater treatment block diagrams for all the facilities. ' -
"" " F037/8 wastes were not specifically identified in these reports because this analysis was .
-- done, prior to the F037/8 listing; however.-wastes fitting the F037/8 definition were
\ reported. These two reports provide only, partial information for the F037 and F038 .
capacity analysis because only 16 facilities were sampled.- ;
r, -i ,''. ' '
£j For the capacity analysis, EPA used'the wastewater treatment block diagrams to
determine possible configuration modifications that'refineries.may undertake to comply
, - with the F037/8 and TC LDRs. . ' / ,
v ! -..'. - .
No-migration Petitions. Over" the past three years, approximately 30 petroleum
~ refineries submitted no-migration petitions for, land treatment units. These petitions
attempt to demonstrate that wastes do not migrate from the unit for as long as the waste
remains hazardous. If a no-migration petition is approved, the facility can continue to
use the unit without meeting the LDR treatment standards. The-data in'the petition
includes: , /.... " . . ' .
generation rates; ' . .'
. . physical and chemical characteristics; and . ....
* ., management practices of petroleum wastes that fit the description, of
'. -....' ' F037/8wastes. . . - '; 'v ' . _ "'.'..
.."' ' j
Some facilities have included wastewater process schematics showing flows of waste
streams. Since these schematics provide important waste generation and waste '''..
' management information, EPA requested that ajl facilities submit wastewater-process
. - 'schematics to supplement the petition. ' . ''.'' ' "'. '
EPA reviewed the no-migration petitions to identify refineries that generate
'. , F037/8 wastes. For several facilities, these petitions provided information on wastewater
, . treatment configurations, and petroleum refining waste generation arid management.
; Comments on the Proposed Rule. There were 20 submissions on the generation
. and management of F037 and F038 wastes in response to the proposed rule. Most
of the comments were from refineries and their tirade associations. The major issues
.addressed by the commenters were the physical/chemical and waste generation
characteristics of F037/8 wastesj quantities generated from surface impoundment
cleanouts, the variance decisions, in the proposed rule, andiwaste removal'frpm surface
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impoundments and closure requirements. These comments are briefly summarized in the
relevant sections of this report. The full texts of relevant comments are presented in the
Response to Comments Document for the .final rule:
American Petroleum Institute (API) .Survey. In 1989 API conducted a survey of
domestic refineries. The goal of the survey was to document the management of waste '
and secondary materials in 1987 and 1988. -Out of a total U.S. population of 176 .. ,
refineries in 1989, 115 responded to the survey. The results of the survey provided
estimates of waste quantities generated and .managed by .refineries!
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The results of the survey were not used as a. source of data for the capacity
analysis because data on individual refineries were not available. Results of the survey,
.however, were used as a means of confirming and validating the estimates of F037/8
waste quantities requiring off-site commercial treatment. . .
Data from the TC Questionnaire. -In the spring of 1992 EPA conducted a survey
of facilities that manage newly identified TC organic wastes (DQ1S-DQ43) in land-based
' units or dispose of these wastes using underground injection wells. The questionnaire
was sent to .approximately 140 facilities, of which. 59 are refineries. A total of 54 ,
refineries responded to the TC questionnaire. They reported information on the
refineries' wastewater treatment systems, the timing of.when their surface impoundments
would be retrofitted or closed (and be replaced by tanks), the quantity of F037/8 wastes
that would be generated when these surface impoundments are retrofitted or closed, and
the estimated quantity of F037/8 wastes that would be generated from cleanout of tanks
that replace surface impoundments. EPA used this information, as'well as-follow-up
telephone calls made to verify the data reported in the questionnaire, to update the
quantity of F037/8 wastes from surface impoundments. r
3.2.2 Data Sources Examined But N'ot Used For F037/8 Capacity Analysis
Corrective Action Regulatory Impact Analysis Data Base. EPA's.Office of Solid
Waste arid' Emergency Response;deyel6ped a data base on a sample of 79 RCRA ; -
facilities in order to estimate costs and benefits of RCRA corrective action requirements.
Nine petroleum refining facilities are included in this sample. The majority-of \
information contained in the data base is from RCRA Facility Assessments (RFAs)
conducted in the last five years (i.e., from 1985 to 1990) and from Part A RCRA permit
applications, which may date back as far as ten years. .'
Since most of the corrective action data were collected prior to the F037/8 listing,
.the data.base does not specifically identify F037/8 wastes. -Furthermore, only a limited
number of'these facilities are petroleum refineries; Therefore', EPA did not use this data
source for the FQ37/S capacity analysis.. ' '
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Biennial Report. EPA requires large quantity generator, treatment, storage, and
disposal facilities to report, to EPA on their Hazardous waste activities every two years.-
Although these Biennial Reports do request data on'the generation and management of
.hazardous wastes, the 1989 biennial Reports do hot contain F037/8 wastes because these
wastes were not considered, hazardous when the surveys were'conducted. Also, although
the Biennial Reporting System is currently being revised and improved and F037/8 wastes
will be included in the 1991 report, data was not available in time for incorporation'into
the capacity analysis for F037/8 wastes. - .'
California Hazardous Waste Data Base.- California.enacted the Hazardous Waste
Management Act in 1986.in accordance with the procedures for establishing treatment
standards under Section 25179.6 of the State's Health arid Safety Code. The California
Department of Health Services is proposing treatment standards for non-RCRA organic-
containing hazardous wastes generated from the petroleum refining industry, in California.
Petroleum wastes fitting the F037/8 waste definition have been identified by California
prior to the F037/8 waste listing. ' \ , .
To assign treatment standards to the non-RCRA petroleum wastes,, the
Department of Health Services used manifest data from 1986 to develop a data base .
containing information on the generation, chemical/physical characteristics, and treatment
of these wastes. These data were of limited use for the capacity analysis because these
data did not specifically identify F037/8 wastes. '' ' .
33 METHODOLOGY, ASSUMPTIONS, AND PRELIMINARY RESULTS
In conducting the capacity analysis for F037/8 'petroleum refining wastes, EPA
derived and quantified the amounts and characteristics of the wastes that will require
commercial treatment/recovery as a result of the LDRs. These estimates were revised
between the proposed and final rules as EPA evaluated additional data. This section .
presents only the estimates obtained for the final rule. The basic methodology did not
change significantly between the two nilemakings and any changes in.the'underlying
assumptions are noted in this section. The method that EPA' developed for the F037/8.
petroleum refining wastes capacity'analysis is comprised of four steps:, '. . " !
(1), identify research needs and; existing data; " :, "
.(2) apply engineering judgment to. existing data; . ''. .
. '(3) collect and evaluate new data; and . ' . , ;" ' .
(4) apply engineering judgment to fill data gaps. : ,
Each of these steps is discussed below. '.,''<
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33,1 Step 1: Identify Research Needs and Existing Data .
For' this step, EPA identified key factors that needed to be addressed in order to
conduct the capacity analysis,' and then considered these factors. while reviewing the ,
available information sources on petroleum refining wastewater treatment sludges (see
Section 3.2). The key factors included the quantities of newly regulated' F037/8 sludges,
management of K048-K052 wastes in response to existing LDRs for these wastes,
potential management of F037/8 wastes in response to the LDRs for these wastes, and
potential management of accumulated F037/8 wastes removed as a result of the
retrofitting or closure of surface impoundments. These factors are discussed in more
detail in the next sections. . ''.
. As indicated in. Section 3.2, the most relevant data were extracted from the
following sources: - ' . . , .
Comments in. response to "Advance .Notice of Proposed Rulemaking for
". Newly Identified and Listed Wastes" (56 Federal Register 24444, May 30,
; 1991); . . . : ' ;. :. . _ ' '
V F037/8 Regulatory Impact Analysis for Listing Rule (F037/8 RIA);
' . National Survey of Hazardous Waste Treatment, Storage, Disposal, and
v . ' Recycling Facilities (TSDR^Survey); . .
TSDR Capacity Data Set; . '
' ' -National Survey of Hazardous Waste Generators (Generator Survey);
, ; Petroleum Refinery Data Base (PRDB); . '
Reports on the F037/8 listing rule;
No migration petitions; ' '.-.''
Comments received in response to the proposed rule (57 Federal Register
.' ' 957, January.9, 1992);. . . . . ' >
. Data from the American Petroleum Institute (API) Survey;, and ' .
Data received from the Toxicity Characteristic (TC) survey. ' . .
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33.2 Step 2: Apply Engineering Judgement lo Existing Data
EPA conducted an in-depth review of the most appropriate available data as
identified in Slep 1, and developed assumptions where possible to resolve issues and. fill
data.gaps. This review focused on_five areas: .'..;.
(1) . Evaluating previous estimates of total. F037/S waste quantities; .
(2)' Evaluating F037/8 management practices and'available on-site .
treatment/recovery capacity; ,-."'' . ."
....'. .t V ' . ' "'..'
(3) Evaluating the fate of accumulated sludge; \ ' '. ..
(4) Examining the extent to .which F037/8 sludges can be dewatered; and
. (5)' Identifying existing data gaps. .
These areas are discussed .below. Additional detail, where relevant, is provided in .
Section 3.3.4 (Apply Engineering Judgment to Fill Data Gaps). ' '. %. .
(1) Evaluating previous estimates of total F037/8 waste quantities. EPA
evaluated previous estimates of the. quantities of F037/8 wastes by reviewing available
literature to identify what quantities are likely to be generated once these wastes become-
subject to the LDRs.. For example, based primarily on the PRDB, EPA had derived for
the F037/8 listing RIA a preliminary estimate of 450,000 tons/year of non-dewatered.
routine F037/8 waste generation. The PRDB,'however, as well as a number of the other
data sources examined in Step 1, were developed before 1988, and do not reflect current
trends. For example, much of the data did not account for the impact on wastewater
treatment system configurations duetto the TC listing rule. In addition, not all data
elements necessary for the capacity analysis are contained in these'data bases. For
example, explicit data'pn:the generation rate of primary wastewater treatment sludges
(i.e., F037/8 wastes) are not provided in the PRDB.
(2) Evaluating F037/8 management practices and available on-site
treatment/recovery capacity. EPA evaluated how the newly regulated sludge is likely to
be managed once it is subject to the LDRs. EPA reviewed the wastewater treatment
system configuration at individual refineries and collected available data on how. the
industry responded to the LDRs for K048 and K051 to determine possible management
scenarios for F037/8.. Based on the information developed from this review, EPA applied
engineering judgment and developed assumptions concerning how refineries might '
manage F037/8 to comply with the LDRs. . -l
One basic assumption developed at this point was that once the F037/8 waste
LDRs become effective, refineries will manage their F037/S wastes in the same way as
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they are currently managing their K048-K052 wastes. That is, refineries, when possible,
will recycle the F037/8 wastes through on-site cokers or will reduce the quantity of F
wastes requiring treatment by-dewatering, thermal drying', and/or other means, and then
generally send the F wastes off site to commercial treatment/recovery facilities. The
Agency expects, that only nonwastewaters will be generated. -' ;
(3) Evaluating the fate of accumulated sludge. EPA analyzed existing data (e.g., .
' data from the PRDB) on 'management. practices prior to the effective date of the F waste
listing. These data address regulatory constraints, potential liabilities, and technical issues
that may affect refineries' decisions on management of newly regulated sludges that have
accumulated in on-site surface impoundments that do not meet MTR requirements:..
For the F037/8 Listing RLA, EPA estimated that the quantity of one-time .
generation of non-dewatered 'accumulated wastes -(5. 3 million tons) is much greater than
the annual amount of routine FQ37/8, waste generation (450,000 tons). If these
accumulated sludges are removed from impoundments before the expected effective date
.of the LDR (i.e.,' June 1992), they would not require treatment before being land
disposed, and .therefore they would not impact the available treatment/recovery capacity
being examined by this analysis.. . ; . - . ''
If accumulated sludges are removed. from impoundments after the effective date
of the" LDR, they will, increase the demand for treatment. EPA, however," has authority
to grant only a two-year national capacity variance for F037/8 wastes. Therefore, if '
refineries remove accumulated sludges after June 1994 (i.e., two years past the. expected
time of the final LDR), the impact of those sludges oh available treatment capacity '
would be out of the scope of this capacity analysis.13 . - .
A few of the commenters on the ANPRM and the proposed rule noted the
difficulties involved in closing surface impoundments. In. response to the ANPRM, ITEX
Enterprises Inc. (Conimenter CDP-0002Q)14 noted that often the only viable option -' '.
open to refineries was to make process changes in wastewater flow systems prior to the
effective date of the LDRs such that the surface impoundments would no longer be
receiving hazardous wastes (e.g., by closing). Those: companies that did decide to close
units, pften chose to treat this waste in situ, rather than remove it from the impoundment.
ITEX felt that a number of companies were "locked in" to this option even though it may
only be a sensible option where the waste is sufficiently shallow to respond to treatment,
and the land area is not. needed for future use. Sun Refining and Marketing ' - ',
.13 For this capacity analysis, the Agency is concerned with the generation of F037/8 wastes during the
two years following the effective date of the LDR; therefore, the Agency did not examine the F037/S waste
generation that would occur every three or more years (e.g., from the cleaning out of large or numerous
tanks). . -... '
14 ANPRM RCRA docket No. F-91-CDP-FFFFF. . .
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(Commenter GDP-00030) noted that .there is not capacity to handle either the sludge
removed from the bottom of surface impoundments or th'e wastewaters that flow",through
them. Furthermore, this commenter stated that it will be impossible to build "
replacement units in Jess than fpur.years. API s comments (Commenter CDP-00023) . i
stated that replacing impoundments with tanks'can take from six months for a small unit
to more than four years for a large impoundment. '
- In'response to the proposed rule, BP Oil (CD2P-00064) and Unocal (CD2P-
00044) indicated that the full four years allowed under RCRA section 3005(j)(6) is
needed to close (or retrofit) nbn:MTR surface impoundments and construct tanks to
replace surface impoundments. According to these commehters, tank construction
1 programs have been co'mplex' engineering projects; time is needed to design, permit, and
construct wastewater tanks; . ' .
. In the proposed rule's capacity analysis, EPA assumed that most' surface
impoundments would either be cleaned out or replaced by tanks prior to the effective
'date of -the LDR. 'As a result, EPA assumed the quantities of wastes removed from large
surface impoundments in the two -years following the effective date to be negligible.
In response to the proposed rule, seven commenters, API (CD2PT00087), BP Oil
(CD2P-00064), Conoco (CD2P-00092), Exxon (CD2P-OOl'l8), National Petroleum '
Refiners Association (CD2P-00022), Phillips (CD2P-00042), and Unocal (CD2P-00044),
indicated that EPA underestimated the amount of F037/8 wastes that will be generated.
from surface impoundment cleanouts.* For the final rule, EPA reassessed the proposed
rule assumptions regarding the closure of surface impoundments. EPA evaluated
additional data forthe final rule from the TC questionnaire,.contacts with refineries .who
responded to the questionnaire, and comments on the proposed rule. Based on .these
data, EPA identified refineries that will still operate-with surface impoundments after
June 1992 and the quantities generated from closure of these impoundments between
1992 and 1994. .. .
;' In identifying surface impoundments that have closed, .EPA assumed that
refineries that did'not take part in the TC questionnaire have already closed their.surface
.'impoundments that contain F037/8 wastes. EPA based this assumption on the' fact that
the TC questionnaire population is composed of facilities that have submitted
notifications to EPA identifying surface impoundments that accept, newly identified '
organic TC wastes. Because most of the F037/8 wastes also exhibit the TG (for
benzene), the Agency believes that the-TC questionnaire population included refineries '
that still manage F037/8 wastes in surface impoundments.
'EPA believes that tanks replacing closed ^surface impoundments'will require
routine cleaning to remove accumulated F037/8 wastes., EPA used the information .'
reported in the TC questionnaire as the basis for estimating the quantity of F037/8 wastes
from tank cleanouts. ...
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. (4) Examining the extent to which F037/8 sludges can be dewatered. EPA
examined dewatering data provided in no-migration petitions, from refineries, and ,
reviewed technical descriptions of the processes and efficiencies of primary dewatering
technologies (i.e., centrifuges, Belt presses, plate and frame filtering, and thermal drying).
' EPA combined this information on dewatering processes with information, on the physical
form of the sludge,15 and EPA reports that examined dewatering of petroleum refining
wastes,'6 in order to develop an understanding ^of quantity reductions from dewatering.
This information indicates that dewatering of these wastes are widely practiced, and the , '
type -of treatment available to the refinery determines the dewatering equipment used' .
and the extent to which the wastes are dewatered. For example,, facilities. that
aggressively dewater their wastes (e.g., with a filter press) usually send the filter cake to
treatment that can handle bulk solids. Facilities that dewater less or do not dewater at
all, generally send wastes to treatment systems that require pumpable sludges".'
(5) Identifying existing data gaps. As the above analyses were completed, EPA
evaluated gaps in the data, 'in-general, the data were often obtained prior to 1988
(before the K048-52 LDRs, and the F037/8 and TC listings). Also, not all of the specific
'data elements required for the analysis were available (e.g., on future management ,
practices). In Step 3, EPA collected additional data to address the data gaps. .
333. Step 3: Collect and Evaluate New Data ,
' .v- ' To evaluate the assumptions and address the data gaps identified in Step 2, EPA .
collected and evaluated additional data on F037/8 wastes". .The data collection efforts
focused on refineries that are the dominant F037/8 waste generators. Throughout this
data collection effort, EPA coordinated with refineries and local and state regulatory. .
'agencies to assemble arid review petroleum refining waste data. The bulk of the.
information was collected directly through data submissions by refineries, visits to
individual facilities and/or companies that own and operate refineries, and phone calls to '
; refineries responding to; the TC questionnaire. Some information was verified through
local and state agencies. This effort focused on the key petroleum refining states that .
account for the largest quantity of refining capacity (i.e., Texas, California, and
Louisiana). '''_.- . '".''." '
1S. U.S. EPA, Proposed Besl Demonsirated Available TectinoloEv (BOAT) Background Document for
Newly Listed Refinery Wastes FD37 and F038. November 1991. '' '.
14 U.S. EPA. Assessment of Hazardous Wa5te Practices in )he Pcirolcn'm Refining Industry. NTIS
Report PB-259097, 1976; and U.S. EPA, Assessment Data Base for Pcrrnleum Refining Wasiewaier and
Residuals. EPA/«W2-83-OlO. 1983. . . ,
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. 33,4 Step 4: Apply Engineering Judgement to Fill Data Gaps
EPA evaluated each of the 194 refineries in operation as of;January, 1991. The :
types of .engineering judgement EPA'used to derive estimates of F03 7/8 waste generation
depended on the availability of information for the refinery. This section describes in r
general the approach EPA used for refineries with different levels of information. This
section also presents the preliminary results, as well as additional data gathering and.
analyses necessary for subsequent refinements.- -The following subsections, are provided;
(1) Refinery categories. . ' ^
.(2) Refinery groups. - ; \ t ".
(3) Material-balance.calculations..
(4) Non-dewatered F037/8 generation. . ' '
(5)v Reductions as a result of dewatering. . " ,'
1 -"(6) Reductions as a result of using on-site cokers.- .
(7) Reductions as a result of using other treatment. ;.
3.3.4.1 Refinery Categories. . .',-.- ".-'..
EPA first placed the refineries into three categories based on the availability of,
information: . ' . . . ... .\- -
. " Category 1: Refineries discussed in Step 3 that submitted information for
'-. the'F037/8 waste capacity analysis. Category 1 contains 29 refineries and
represents 28 percent of the total crude oil capacity. EPA determined the
,FQ37/8 waste generation for these 29 refineries by using the. quantities
' provided by the refineries. This information is recent and therefore , .
supersedes' the information that refineries may have reported previously (in
- sources identified in Step 2). - . ' ' . ..
In cases where more recent information was submitted by these Category 1 .
',. refineries in response to the proposed rule or in the TC Questionnaire,
EPA incorporated the new information into the analysis.
' Category 2: Refineries that provided detailed information in the TSDR
Survey. Generator Survey, and PRDB. These sources of information : -
. provided the Agency with facility schematics or descriptions, estimates of. K
waste generation, and other information useful for "material-balance"
calculations of facility-specific F waste quantities. Category 2'contains 136
refineries and. represents more than 67 percent of the total crude , " *
processing capacity. For these refineries, EPA used the K waste generation
data together with'reported primary and secondary separation
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, -. . efficiencies,'7 typical waste compositions (i.e., oil/grease, suspended solids,'
and water content),18 and solids settling characteristics, to develop a .
"material-balance" estimate of each wastewater treatment unit, tarik, and
surface impoundment. .This approach provided EPA with an accurate
-engineering-based estimation of routine F.waste generaiion. These
facilities .were labeled as either Category 2a and 2b., Category 2a '
represents refineries who responded to the TSDR and Generator Surveys,'
and Category 2b represents refineries for which EPA had information in
the PRDB. Category 2a information is more recent than Category 2b
information. -. ' .' ;. ' -. ' .
In cases where 'more recent information was submitted by these Category 2
refineries in response to the proposed rule .or in the TC Questionnaire, .
.., . EPA incorporated.the new information into the analysis. .
Cateeorv 3: Remaining refineries with limited data. For these refineries.
. . EPA only.had data on crude processing capacity from the Oil & Gas .
Journal's 1991 refinery survey.19 Category 3 contains 30 refineries and .
- / represents less than five percent of the total crude processing capacity. For
these refineries, EPA estimated F037/8 waste generation based on waste
, generation rates associated with the most common type of wastewater
. . -treatment configuration. :--'
./ ' ' ' . . - - '
- Category 1 refineries are described in Appendix D.' Appendices E and F describe
the use; of the data .for refineries in Categories 2 and-3. . ,
33.4.2 Refinery Groups '',." -'
' To facilitate the estimation of F037/8 waste generation' for Categories 2 and 3,
refineries were'grouped according to their reported or assumed primary wastewater /
treatment configuration. This grouping, which is based o'n a grouping scheme used in the
F037/8 Listing RIA,r° allowed for a convenient representation of treatment schemes .
' and petroleum-waste generation potential. EPA- assigned each refinery to Category 2 or
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17 U.S. EPA Environmental Assessment Data Base for Petroleum Refining Wasiewaier and Residuals.
EPA 600/2-83-010, 1933. ... . ../-.'
18 U.S. EPA, 'Assessment of Hazardous Waste Practices in the Petroleum Refining Industry. NT1S
Report PB-259097, 1976: . . . , ...
19 Thrash. L.A. 'Annual Refining Survey." Oil & Gas Journal. March is 1991. ' '
20 DPRA Incorporated and ICF Incorporated, Regulators1 Impact Analysis for the Listings of Primary
and Secondary OilAVatcr/Solids Separation Sludges From ihe Treatment of Pelrolcum Refinery
Wastewaters. prepared for U.S. EPA, Office of Solid Waste; October 1990.
-------
I"
»
' . 3-23. v , .... . .
3 based oh two factors: (1) the type and position of wastewater treatment units (e.g.,.CPI
separators, IAF units) in the treatment train that routinely generate (ranging from
continuous to annually) F037/8 wastes; and (2) the size and position of surface
impoundments, that accumulate F037/8 wastes. . ' ' . .
The different waste treatment groups are illustrated in.Exhibit 3-3 and are
described below.^1; . . .
Groups 1: Facilities with one or more impoundments upstream of primary
' treatment (i.e., wastewater treatment upstream of biological treatment),. .
and in between primary separation and secondary.separation. The primary
.. treatment section also receives storrriwater runoff. (Primary separation,
includes gravity separation units such as API or CPI separators. Secondary
separation includes air flotation units (AFUs), such as DAF or IAF units.)
Groups 2: Facilities with one or more stormwater impoundments that .
discharge to primary treatment consisting of primary separation, followed by
secondary separation.' '' ,
.' : Group 3:' Facilities that do not have a well-defined process for secondary .
separation; The ^primary separation section discharges to surface ..
. impoundment's) upstream of biological treatment.
* Group 4: Facilities with primary-and secondary separation processes, but
, , without any surface impoundments that would generate F wastes.
Generation' of sludges may occur, however, from treatment tanks, storage
tanks, and sewers. '
Group 5: Facilities that have at least one surface impoundment
. downstream of primary and secondary separation.'.'
Group 6: Facilities that are similar to Group 1 facilities, but that carry put
secondary separation in impoundments. - .-
" . - - ' '''..
Group 7: Facilities that are similar to Group 3 facilities, but that have
stormwater impoundments that enter the treatment train-in primary . . "
' separation. ".".'.-. . ,'
For Category 2 facilities, EPA used available facility schematics to determine the
grouping that .best represents the facility. These schematics, obtained from the TSDR
and Generator Surveys and from the PRDB, may not reflect recent changes to refineries'
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Wastewater ~~ Separatton
GROUP 2: . : -
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oundment '] . ' ' -...''.' . ' "',''
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v EXHIBIT 3-3 (continued) , . . .*
WASTEWATER PRIMARY TREATMENT GROUPINGS . , - . ' , j
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GROUP 4: '.._"' . . ' .: . ' . '
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Wastewawr .Separation . .
GROUPS: .
oily' ^ Primary - tf S
Wastewaiar Separation. S
... ! ' *
GROUPS: ' .
.Siormwater. . I"1 impoundment.
Oily . -.^ (Wet and dry
Wastewater weather inflow)
V_|J _ ^
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GROUP?: . '.
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Stormwater '' & Impoundment
Wastewatar T" weather inflow)
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, * -Separation- p; ^Treatment . ..
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.wastewater. treatment system. In cases where more recent information on a refinery's
wastewater treatment system is available (from the TC questionnaire), EPA used the.new
information in the analysis. EPA assigned ail Category,3 refineries to Group 4, the most
prevalent wastewater treatment configuration among^Category 2 refineries.
33.4.3 Material-balance Calculation for Category 1 Refineries
- EPA used material-balance calculations, to estimate non-dewatered F037/8 wastes
for Category.2 refineries. That is; information concerning a refinery's wastewater flow; <
treatment system, K. waste generation, and other characteristics were.used to'determine a
refinery-specific amount of F037/8 waste. These calculations are presented in detail iri
Appendix E, In general, the following information or assumptions about1 the facilities
were incorporated into the calculations. :: ' '
.. ' I '. - '''"-. V .
Facilities within a group may differ, in the type of primary and secondary
separators they employ. CPI separators and LAP.units generate F037/8
wastes, respectively; API separators arid.DAF units generate KQ5Land
K048 wastes, respectively. Therefore, EPA considered whether a-facility'
uses an API or CPI separator, a DAF unit, an IAF unit, or a combination
of units. ' . '' "
' - ' Location of impoundments determines the solids loading in the'influent
.wastewater." Impoundments upstream of primary treatment receive
wastewaters with higher concentrations of solids than impoundments that
are between primary and secondary separation, or downstream of primary
treatment, and therefore accumulate more F037/8 wastes.. . '
.. Segregated flow systems (i.e., wet weather flow only) were distinguished
. from non-segregated flow systems (i.e., dry and wet weather flow) because
the wet weather component of segregated flow systems does not generate
'.>:'. F037/8 wastes; . . ' . .
-'.- Refineries'that close surface impoundments prior to the effective date of .
-.'".' the LDR and replace impoundments with tanks will generate F037/8 wastes
. when these tanks are cleaned out. Based on.information submitted by - .
.refineries, EPA:beIieves that these tanks will be cleaned out once during
the two years following the LDR. Furthermore; based on estimated tank
- : sludge generation reported in the TC Questionnaire, EPA estimates that
the annualized quantity of routinely generated F037/8 tank sludges is, on
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the average, one-third the quantity of F037/8.wastes that were cleaned out',
' .. . , from the' surface impoundments that have closed.22
3-3.4.4 Non-dewatered F037/8 Waste Generation .' . '
. .For the fina| rule, EPA'conducted separate capacity analyses for F037/8 wastes
removed from surface impoundments and for all other F037/8 wastes (otherwise known
as routinely generated wastes). In the proposed rule, wastes,removed from small surface.'
impoundments were included in the estimates of rouline generation. For the final rule
analysis, routinely generated F037/8 wastes are those wastes generated from tanks,
including equalization tanks and oil/water/solids separators (such.as CPE separators and
IAF units) that are not API.separators or DAF units. Surface impoundment wastes' .
include wastes generated from both small and large surface impoundments.'
Routinely Generated Waste . '-.'' '
As described previously (and in greater.detail in the appendices), the routine
generation of F037/8 wastes was estimated according to a different procedure depending
on the data category to which the refinery was assigned. These analyses of F037/8 waste
'generation show that, as of June 1992, non-dewatered routine F037/8 waste generation is
estimated at 571,000 tons/year.' Of this amount,.California refineries generate'.
approximately 173,000 tans/year (30 percent).23 Category 1 facilities account for .
301,000 tons/year (53 percent of the total), Category 2 facilities account, for 265,000
tons/year (46 percent), and Category 3 facilities account,for 5,000 tons/year (1 percent).
Exhibit 3-4 presents'a summary of the contributions of Category 1, 2, and 3
refineries to the npn-dewatered routine F037/8 waste generation, as well as to the total
U.S. crude oil capacity. As seen in this exhibit, Category 1 refineries account for a ;
relatively small proportion of the total number of refineries-(i.e., ,15 percent), yet they .
account for 28 percent of the total crude'capacity and 53 percent-of the non-dewatered
routine F037/8 waste generation: The Agency believes that these differences may reflect
a larger refinery size and a higher utilization of individual crude capacities for Category 1
refineries as compared to Category 2.and 3.refineries. The cost for treating and
recovering these wastes provides incentives for refineries to reduce the amount of F
wastes they generate. Therefore, EPA expects,F waste generation to decrease following
the effective date of the LDRs for F037/8. These reductions" would be achieved by
^Fpr facilities with surface impoundments' lhat will close due lo management/of newly identified ' '
wastes, the TC questionnaire requested that ihe facilities estimate the annualized quantity of tank sludges
from tanks lhat will replace surface impoundments. EPA found I hat, on avrage, the atinualized quantity
of tank sludge-is one-third the quantity of wastes that mil be cleaned out from surface impoundments.
23 .The economic impact screening analysis differentiates between California and non-California wastes.'
Consequently, these quantities are presented here also. ' ' .
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' ' ' EXHIBIT 3-4 ' '
CONTRIBUTIONS OF CATEGORY 1, 2, AND 3
REFINERIES TO TOTAL CRUDE CAPACITY ANP NON-DEWATERED ROUTINE
F037/8 WASTE GENERATION ,
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... ALL REFINERIES. '
n = 194 ' . .
Crude Capacity = 1.7 x 107 brls/day
'" F037/8= 571,000 tons/year
CATEGORY 1
n = 29 (15 percent)
' Crude Capacity * 4.7 x. 10 brts/day
. (28 percent) .
F037/8 = 301,000 tons/year
(53 percent)
CATEGORY 2' .
nil 31 (68 percent)
Crude Capacity = 1,1 x io7 brls/day
(67 percent)
F037/8 - 265,000 tons/year '
(4 6 percent) ; .
. . CATEGORY3
: n = 34 (17 percent) .
Crude Capacity » 8.5 x 10s brls/day
(5 perc-T.t)
' F037/8 » 5,000 tons/year
(1 percent)
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3-29 . .
segregating stofmwater and process wastewater sewers so that solids from siormwater
. runoff does not contribute to F037/S sludge generation, by improving refinery . '
housekeeping so that less contaminants enter stormwater and process water, by
dewatering or drying to reduce waste quantities. ' . , . ...
. Surface Impoundment Wastes ' ' . ,
The quantity of accumulated F037/8 in surface impoundments was available for
Category 1 .facilities in (see Appendix D). For facilities in Categories 2 and 3, EPA used
calculations shown in Appendices E and F to estimate the quantity of accumulated
F037/8 wastes. Estimates of the quantity that would be removed after June 1992 was .
.obtained from the TC questionnaire, contacts with refineries, and comments on the.
proposed rule. Refineries that did not take part in the TC questionnaire and did not
.submit information on surface impoundments in response to the proposed rule were
assumed to have already closed their surface impoundments that contain F037/8-wastes.
This assumption was based on the fact that the TC Questionnaire population is .-
composed of facilities that have submitted notifications to.EPA for land-based units
accepting newly identified organic TC wastes. Impoundments managing F037/8 wastes
are likely to be covered by the TC Questionnaire because most of the F037/8 wastes
exhibit the TC for benzene. (Contacts with four refineries that did not respond to the
survey confirmed that they no longer have surface impoundments in operation.) .'
EPA estimates that approximately 423,000 tons of nori-dewatered F037/8 sludges
will be removed from impoundments between June 1992 and June-1993, and 225,000
tons will be removed between June 1993 and June 1994. Of this amount, Category 1 -
facilities account for 224,000 tons between June 1992 and June 1993 and 118,000 tons
between June 1993 and June 1994 (53 percent and 52 percent of the totals, respectively).;
Category 2 facilities account for 199,000 tons between June 1992 and June 1993 and
107,000 tons between June 1993 and June 1994 (47 percent arid 48 percent of the totals,
respectively).^* . ' . ' .
3 J.4.5 Reductions as a Result of Dewatering
' ' ' . ' ' - ' ' _ ' ' .' >
: After examining the information discussed in Section 3.3.2 on dewatering, as well
as information from Category 1 refineries, EPA concluded that F037/8 wastes are !
generally dewatered prior to treatment and disposal. This information also showed, that
, standard filter presses can reduce the quantity of oily wastes by an average of 50 percent
(to a water content of 20 to 40 percent) with higher quantity reductions for. sludges'
with higher water content while dewatering using a centrifuge ,or a belt press can '.
- 24 Since wastewater treatment configurations were not known for Category 3 facilities, they were
assigned to Group 4 (the most prevalent wastewater treatment configuration). Since Group 4 facilities do
not have impoundments that would generate F wastes, the 31 Category 3 facilities are assumed to -
contribute no accumulated FD37/8 wastes. . . .
*
153
" *
-------
achieve quantity reductions ranging from 30 to 40 percent (to 'a water content of '40 to 60
percent). Category 1 refineries that provided information on their dewatering practices
indicated much higher quantity reductions. These reductions ranged from 50 to 98
percent, with an average of 80 percent. Six of the Category 1 refineries (or 21 percent)
indicated 'that they have operated of are currently operating, planning to operate, or 'are
investigating thermal .dryers. , ,
Routinely Generated Wastes . .
.. \Based on the above mentione^d information, EPA reduced the' quantity of
routinely generated F037/8 wastes by the amount reported (i.e., for Category 1 refineries
that reported dewatered amounts)! or by 50 percent for refineries that did not submit '
information on dewatering (i.e.; Category 2 and 3 refineries, and several Category 1 . '
refineries).25 .This dewatering reduces the 571,000 tons/year of routine F037/8 waste '
generation to approximately 185,000 tons/Veer. Of this amount, California refineries , .
generate approximately 67,000 tons/year (36 percent).26
Surface Impoundment Wastes ' . .' ,
For F037/8 wastes removed from surface impoundments, EPA used dewatering ,'
percentages reported by refineries. .However, EPA applied a dewatering percentage of
50 percent for refineries for which refinery-specific dewatering percentages- were not, . .
available for these wastes. This dewatering results in 200,000 tons of F037/8 removed
from surface impoundments between' 1992 and 1993 and 112,000 tons removed between '
1993 and 1994. ' . .
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3.3.4.6 Reductions as a Result of Using On-Site Cokers .
.EPA recognizes that 'recycling of. petroleum refining wastes using cokers 5s
.attractive to refineries, and wastes recycled by this process to produce coke are exempt
from hazardous waste regulations.27.; For example, of the 29 refineries in Category 1, '
seven indicated -that they are or will be recycling petroleum refining wastes using.on-site -
cokers. (Two of the 29 refineries have cokers but stated that they will not use them for
recycling F wastes, and 'six refineries have 'cokers but' did not indicate whether they will
use the cokers to recycle F wastes.) ' ;
25 One exception to this assumption is a large Category 1 refinery that EPA assumes will dewater to
an extent that is similar to several .other large Category 1 refineries (i.e., 80 percent). .
26 The average water content of this dewatered 'waste would be approximately 30 percent. EPA
recognizes that thts'is lower than the water contents discussed above for centrifuging and belt pressing
(although not for filler pressing), but believes that -- based on greater incentives to dewater ihe waste -
' ihis 30 percent value is close to the average water content being attained today.
27 RCRA section 3004(q)(2)(A), ' . . . .
j
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I!
3-31 ,
' To obtain an estimate of the quantities of F037/8 that will not require commercial
treatment due to the LDRs, EPA evaluated the use of on-site cokers to manage F037/8
'wastes. EPA used.reported estimates of coker use by Category i refineries, as well as an
assumption developed far refineries that are known to have cokersiS but that did not
indicate whether they.would use their cokers for F037/8 wastes. This latter assumption.is
that 90 percent of these refineries will use their cokers to recycle F037/8 wastes. -This
assumption was based on'Category 1 refineries that indicated operational constraints that
prevent them from using cokers, as well as on the contrasting incentive that exists for
increased coker use due to the coking exemption: EPA, therefore, estimated that 55
' percent of the 185,000 tons/year of dewatered routine. F037/8 waste generation will be
managed using on-site cokers-(thus reducing the potential quantity of F037/8 wastes
requiring commercial treatment to 82,000 tons/year, where 13,000 tons/year is due to
California refineries). ' . . .
EPA assumed that those refineries recycling routinely generated F037/3 wastes
through cokers will also use the cokers to recycle F037/8 wastes from surface
impoundments, unless more recent information (e.g., from TC Questionnaires and
. comments in response to the proposed rule) indicates that the refinery will not use
cbfcers to recycle these wastes.30 A substantially smaller reduction of the-F037/8 waste
removed from surface impoundments will occur as a result of on-site coker use; The
quantity F037/8 removed from impoundments potentially requiring commercial treatment
will be reduced, by roughly 3 percent due to coking, resulting in 193,000 tons requiring
treatment between 1992 and 1993, and 109,000 tons requiring treatment between 1993
and 1994. The smaller reduction-of F037/8 waste from surface impoundments resulted
_ because several facilities that will generate large quantities of surface impoundment waste
either do not have pn-site cokers or do not plan to use .cokers for these wastes:
33.4.7 Reductions as a Result of Other Treatment . ' .
On-site treatment such as incineration, thermal distillation, and solvent extraction .
can be used to treat F037/8 wastes to meet LDR treatment standards. Of the 194'
. refineries, five refineries have on-site sludge/solids incinerators. Of these refineries, two
stated that they will not use their incinerators to treat F037/8 wastes, one stated that it
will use its incinerator for F037/8 wastes, "and the remaining two did not indicate what
' they will do. The two refineries that will not use their incinerators for F037/8 wastes ! .
23 From information obtained directly from Category 1 refineries and from Oil and Gas Journal's
"Annual Refining Survey" (March 18, 1991) for Category 2 and 3 refineries.
** For example, some refineries have cokers for which (he technology for recycling petroleum refining
wastes has not been developed. Other refineries may be producing anode-grade coke, which-may not meet
product specificauons if petroleum refining wastes arc recycled in the cokers. . ' .'
?° Several refineries have commented thafthey wiH not use their cokers to recycle F037/8 wastes from
surface impoundments because they are lower in Btu value than routinely generated wastes.
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stated operational constraints as their reasons (e.g., there would be excessive wear and
tear on incinerator feed systems'.'the burning of petroleum wastes would exceed the
incinerator emission limits). - ' .
. Of the 29 Category 1 refineries, only one reported using a thermal distillation unit,
and one other reported investigating.the use of solvent extraction.
Many-refineries are using or investigating thermal drying, a process that reduces
F037/S wastes by approximately 5Q percent by removing water and volatile organic
compounds and that results in a dried-cake with a high ash content.
,-To obtain an estimate of the reduction to routinely generated F037/8 wastes
requiring commercial treatment due to these other treatments, EPA used information on
Category 1 refineries for June 1992, and developed an assumption for refineries that did
not submit information on other treatment. That is, .for the two Category 1 refineries
that did not submit information on their incinerators, the Agency assumed that all of
' their F037/8 wastes would be treated using on-site incineration. For all six Category 1
refineries that indicated they may use thermal drying, EPA assumed a 50 percent
reduction in their F037/8 wastes.' For the Category 2 and 3 refineries, EPA assumed that
approximately 20 percent will use thermal drying.and thus reduce their waste'requiring
commercial treatment by 50 percent. .. ,
EPA, therefore, .estimates that incineration, solvent extraction, thermal distillation,
and thermal drying-will reduce routinely generated dewatered'F037/8 wastes requiring
commercial treatment by an additional 13,000 tons per year. This reduction results in a
total quantity requiring off-site commercial capacity of approximately 69,000 tons/year.
To estimate quantities of waste from surface impoundments, treated in other on-
. site processes, the Agency used information submitted by refineries for the proposed rule
analysis, comments in response to the proposed rule, and information from the TC
' Questionnaire on other on-site technologies. In case's where information was not
- available, EPA assumed that 20 percent of these refineries would use other on-site
. treatment methods to reduce surface impoundment wastes requiring commercial '
.treatment by 50 percent. The Agency estimates that 20,000 tons of the.dewatered F037/8
removed from impoundments between 1992 and 1993 will be sent to other treatment
after coking (10 percent), and 10,000 tons will be sent to other treatment between 1993
and 1994 (9 percent). The resulting quantities requiring off-site commercial treatment
are 173,000 tons between 1992 and 1993, and 99,000 tons between 1993 and 1994. '
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',
3.4 SUMMARY OF REQUIRED CAPACITY'AND COMPARISON TO AVAILABLE
CAPACITY
This section presents a summary of ihe results of the F037/S capacity analysis.
These results are presented on an aggregate basis (i.e., results of individual facility
analyses are combined). Appendices D through F present refinery-specific calculations
and values. . :
This section describes F037/8 waste generation and management as it occurs at'
the time of the expected effective date of the LDR (June 1992). This section also ;
summarizes the results of the analysis of available capacity presented in Chapter 2, and
compares these results to the estimate of required capacity.
Routinely generated wastes and wastes removed'from surface impoundments are
presented separately.' Only dewatered F037/8 (as defined previously) is addressed in .this
section. Also, F037/S waste generated in California is presented separately, for purposes
of the economic analysis for the proposed rule. ' - '
3.4.1 F037/8 Waste Generation and .Management Expected on the Effective Date
of the LDR (June 1992) -
. " EPA estimates that approximately 185,000 tons/year of dewatered F037/8 wastes
are currently generated routinely (see Exhibit 3-5). Of.this amount, 116,000 tons/year (62
percent of the total) is expected to be managed in on-site systems. The majority of the
management is coker use, with limited reductions to waste requiring off-site commercial
treatment as a result of thermal-drying, thermal distillation, solvent extraction, and
incineration.'.. .'.'.
Subtracting 116,000 tons/year from the overall generation amount of 185,000
tons/year.results in approximately 69,000 tons/year of routinely generated dewatered
F037/38 waste requiring alternative commercial treatment/recovery capacity. Wastes that
are removed from surface impoundments are addressed in the next section.
> ' ' '
3.4.2. F037/8 Waste Generation During Two Years Following the LDR (June 1992
to June 1994) . -. . . '
1
EPA expects that during the two years that follow the expected effective date of
the LDR for F037/8 waste (i.e., June 1994), the total annual quantity of routinely
generated F037/8 waste.will decrease as the cost of treating and.recovering these wastes
increases, while the quantity being treated on site will increase (see section 3.3.4.4). The
31 ICF Incorporated, COM and Economic Impact Analysis of Land Disposal Restrictions for Phase I
Ncwlv Listed and tdeniified-Waste Proposed Rule, prepared for the Office of Solid Waste, EPA.
November 1991. '
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. . . '. EXHIBIT 3-5 '
DEWATERED ROUTINE F037/8 WASTE GENERVTION (TONS/YEAR)
AND MANAGEMENT PRACTICES FOLLOWING
EFFECTIVE DATE OF LDR (JUNE 1992)
Type
Generation
Reductions from
On-site Coker Use
Reductions from
Other Cm-site
Treatment
Quantity Requiring
Alternative
Treatment
California
67,000
54,000
3,000 '
10;000 .
j
Non-California
U 8^000
49,000
10,000
59,000
Total -
185,000
103,000
. . 13,000
- 69,000
result of this is expected to be a decrease in the quantity of routinely generated F037/8
waste requiring commercial treatment or recovery capacity". Because EPA does riot have
data indicating the extent to which these changes would occur, however, the quantity of
required capacity for routinely, generated waste that was estimated for June 1992 (i.e., ,
69,000 tons per year) is being assumed, for the purpose of this analysis, for the two years
following that date (i.e.', until June 1994). . .
Quantities of dewatered F037/8 waste removed from surface impoundments are
estimated to equal 200,000 tons between 1992 and 1993, and 112,000 tons between 1993
and 1994 (see Exhibit 3-6). EPA estimates that approximately 27,000 tons will be treated
on site by cokers and other-forms of treatment between 1992 and 1993 and 13,000 tons
between 1993 and 1994. The resulting quantities requiring off site treatment are 173,000
tons between 1992 and 1993 and 99^000 tons between 1993 and 1994.
Combining the quantities of wastes from routine generation with wastes removed
from surface impoundments results in a total of 242,000 tons of F037/8 wastes requiring
alternative treatment between-1992 and 1993, and 168,000 tons between 1993 and 1994.
3.4.3 Available Commercial Capacity and Comparison to Required Capacity
The quantities of F037/8 wastes requiring off-site treatment are assumed to be
treated either by incinerators or cement kilns. EPA believes that F037/8 wastes are not
amenable to all types of incineration and cement kiln capacity. EPA believes that some
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EXHIBIT 3-6. . '
' . /V -
F037/8 WASTES REMOVED-FROM SURFACE IMPOUNDMENTS,
MANAGEMENT PRACTICES, .AND TOTAL F037/3 QUANTITIES
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Type
Generation .
Reductions from On-site
Coker Use
Reductions from Other
On-site Treatment
Quantity Requiring
Commercial Treatment
Routinely Generated,
Total Quantity Including
Routinely Generated
1992-1993
' ; 200,000
7,000 - "
20,000 '
1.73,000
- 69,000
242,000
1993-1994 '
112,000
3,000
10,000
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99,000'
' 69,000
168,000 ' '
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dewatered F037/8 wastes are tacky or not pumpable. Because of these characteristics,
EPA believes that dewatered F037/8 wastes are not amenable to pumpable sludge feed
systems at incinerators and sludge or dry solids feed systems at cement kilns.
. ' ' -' . ' "' ' '
EPA believes that some F037/8 wastes as generated are suitable for cement kilns.
The Agency notes that F037/8 sludges removed from surface impoundments downstream
of oil/water/solids separation units may contain prohibitively low amounts of organic'
contaminants. Even after using aggressive dewatering (e.g., filtration, drying), the BTU
content of some of these surface impoundment sludges may not rise to acceptable levels
for cement kilns. ...-_
The Sham Recycling Policy Guideline limit for waste fuels of 5,000 BTU/Ib will be
superseded as cement kilns certify compliance with .the Boiler and Industrial Furnaces
(BIF) Rule interim status requirements by August 1992. Once a kiln certifies ' ,
compliance, its minimum waste fuel heating value will depend on product quality
considerations. EPA recognizes that operational limits are likely to prohibit cement kilns
from accepting wastes with heating values below about 4,000 BTTJ/Ib. The BIF Rule also
will allow broader use of fuels processing to erihance-the heating value of wastes destined
for cement kilns.. On the other hand, product quality constraints of cement kilns (i.e., '
wastes must have sufficiently high BTU to achieve adequate conditions in the kiln to
produce a quality product) and technical and regulatory limitations of fuels blending for
solids limit the use of low-BTU waste at cement,ki!ns. In addition, EPA believes that
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some fuels blenders have the 5.000 BTU/lb limit written into their permit and would, at n
minimum, require a permit modification to accept low-BTU wastes. Thus EPA does not
'. expect blending to significantly increase the amount of low-BTU wastes used as fuels .by
cement kilns. ' EPA believes that containerized solids capacity at cement kilns will be
. used to burn high-Bill-F037/S wastes. - '
EPA believes that low-BTU F037/S wastes sent off-site will likely require
incineration and that these wastes are generally collected in bulk (e.g..- in roll-off bins).
EPA believes that systems for packaging petroleum refining wastes into drums for -
incinerators are hot widely available. Therefore, EPA bejieves that containerized solids
systems at incinerators will not receive'a large portion of the nation's F037/8 wastes.'
Although packaging capacity could be added at generators, incinerators or intermediate
processors, EPA believes that obtaining storage and operating'perrnits. as well as
construction and startup of packaging units will take six "months to one year. EPA
believes that most low-BTU F037/8 sent off-site will require bulk solids incineration and
nonpumpable sludge capacity.' EPA notes,, however, that this rule does-not preclude the
use of other feed systems. - .'
' Since routinely generated FQ37/8 wastes are generated in wastewater treatment .
units (e.g., .CPI separators, IAF units) similar to those that generate K048 and K051
wastes (from DAF units and API separators, respectively), the proportion of low-BTU to
high-BTU F037/S waste should be similar to the proportion of low-BTU to high-BTU
K048 and K051 wastes. Cadence Chemical Resources Inc..provided information to EPA
'for the K04S-K052 LDR rulemaking that indicated the heating value of K wastes. .
According to this information which is presented in Appendix C, approximately 30
percent of the K wastes as dewatered will meet levels acceptable to cement kilns and
approximately another 30 percent will meet levels acceptable to cement kilns with the
use, of modified dewatering techniques such as changing to organics-based filter aids or
eliminating .inorganic-filter aids (EPA also has collected information indicating that the
use of sludge dryers can also increase the BTU-content of petroleum waste). The
remaining 40 percent of the K wastes will not have a heating value acceptable to cement
kilns even after dewatering. Applying these proportions to routinely generated F037/8
wastes, EPA estimates that of the 69,000 tohs/yr requiring alternative treatment, 28,000 .
tons/yr (40 percent) will be low-BTU content wastes that will be treated.by bulk solids
incineration, and 41,000 tons per year (60 percent) will be high-BTU content wastes that
will be managed using containerized solids capacity at cement kilns. . ,
EPA believes that there is insufficient bulk solids incineration capacity available
for the 28,000 tons of low-BTU waste would need to be managed in the form of bulk
solids at incinerators. Therefore, EPA is granting a one-year national capacity variance
to all routinely generated F037/8 wastes to allow time for cement kilns to comply with
the requirements of the BIF rule and for additional capacity, for bulk solids incineration
and other treatment and recycling technologies to come on line to meet the demand for
low-BTU routinely, generated.wastes. ''..' ' ;
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Some refineries submitted data on BTU values of F037/S-wastes from surface
impoundments in their comments on the proposed rule. EPA used these data to
estimate :he proportion of lovv-BTU to high-BTU F037/S wastes from surface . .
impoundments. .Of the 173,000 tons of dewatered F037/S wastes that will be generated
from surface impoundments between June 1992 and June i993, EPA estimates that
112,000 tons will be low-BTU wastes and will require bulk solids incineration, and 61,000
tons will be high-BTU wastes and will be managed using containerized solids capacity.at
cement kilns. Of the 99,000 tons of dewatered F037/3 wastes that will be generated
between June 1993 and June 1994, approximately 64,000 tons will be low-BTU wastes,
and 35,000 tons wiH.be high-BTU wastes. '' . . '
.EPA has identified 23,000 tons per year of bulk solids incineration capacity; 1,000
tons per year of nonpumpable sludge incineration capaciry, and 83.000 tons per year of
containerized solids capacity at cement.kilns. EPA is granting a.two-year national
capacity variance to these surface impoundment wastes. This variance allows refineries '
time to find suitable storage, handling, treatment, and disposal capacity and also-allows
time for other types of commercial capacity to increase to meet the demand from these
surface impoundment wastes. -
Because low-BTU F037/8 wastes are not amenable to cement kilns, and
incinerators generally have less capacity for high-BTU wastes than for low-BTU wastes
(i.e., when they are constrained by heat release limits), EPA considered the possibility of
limiting the capaciry variance to low-BTU wastes. However, EPA abandoned this idea .
for several reasons. First, the precise point at which F037/8 wastes are not suitable to.
cement kiln processing is difficult to demarcate, varying to'some extent on individual kiln .
preferences and shifting state regulation. Thus, there is no readily available means of
accurately subcategorizing among,amenable and non-amenable routinely generated -
wastes. More importantly, EPA believes that the heating value of F037/8 can vary >
considerably over time at the-same refinery. A regulatory regime whereby the status of
sludge could vary on a daily basis (or a tank-by-tank basis)'would create a regulatory
nightmare. There would be day-to-day uncertainty for waste generators regarding the
regulatory status of the day's waste, increased testing to confirm compliance, vastly
increased record keeping._and construction of two sets of waste processing units (with
their use depending upon BTU levels) whose use could not be reliably predicted. In
addition to this miasma of uncertainty for generators, enforcement would be extremely ..
difficult, with such issues as status of blending, drying, filtering and other processing
operations in doubt (e.g., whether or not they add or remove BTU values), and
documentation uncertain and difficult.
For the reasons discussed above, EPA concluded that it would .be unduly
burdensome and not a sound exercise of discretion, for the regulated community to . ...
comply with or for regulators to enforce different standards for high-BTU and low-BTU
"F037/8 wastes. Finally, by granting a variance to low-BTU wastes and not to high-BTU
wastes, EPA would unfairly reward refineries who could process their wastes to enhance
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their BTU value but have nut acted to do so. In.addition, as discussed in the preamble
and this document, it is not clear that there exists ;idi:<]u;ite capacity for high-BTU
routinely generated F037/S in any case. EPA believes (here is uncertainty in the
available containerized solids capacity because some cement kilns may not meet the
August deadline for complying with interim status requirements of the BIF Rule (i.e.,
.problems' in complying with the hydrocarbon emission requirements, see Chapter 2).
Treatment of F037/8 wastes using incineration, solvent^extraction, and-thermai
distillation will result in the generation of treatment residuals''" (e.g., ash from '
incineration) that may require stabilization to meet the metal standards. The solids
content of/FQ37/8 wastes ranges from 40 to 70 percent (with an average of 55 percent).
Assuming these solids result in the generation of residuals, EPA estimates that 77,000
tons of residuals will be generated from the treatment of routinely generated-and surface
impoundment.wastes between June 1992 and June l'J93, and 51,000 tons of residuals will
be generated between June 1993 and June 1994.' EPA also estimates that 1,204,000-ton's ,
per year of stabilization capacity is available (see Chapicr 2). Therefore, the Agency
believes that sufficient stabilization capacity is available to manage the F037/8 residuals.
Also in.this final rule, EPA is resolving the conflict in RCRA concerning the
deadline by which surface impoundments receiving wastes that are newly listed must
comply with the minimum technology requirements specified in sections 3004(o). 'As'
mentioned in Section'3.3, many of the F037/S wastes managedjn surface impoundments
'are managed in unretrdfitted units (i.e., impoundments not meeting the MTRs). EPA is'
promulgating that in the case of wastes subject to.a national capacity variance,
impoundments managing such wastes (and no other^ wastes subject to an earlier
prohibition) have four years from the date of the identification or listing (i.e:, the date
the identification or listing is promulgated, not the effective date of the rule, see section
3005(j)(6))' to retrofit or close.
32 F037/S wastes used ai cctncm kilns and on-siiC'COkers to produce a product (i.e., cement from
cement kilns and petroleum coke from cokcrs) do not result in Ihc generation of residuals lhai would be
subject to the LDRs. -
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' . CHAPTER 4
CAPACITY ANALYSIS FOR-OTHER NEWLY LISTED WASTES
This chapter presents EPA's analysis of required alternative treatment or recovery
capacity forother newly listed wastes that are currently being land-disposed. Other
"newly listed wastes include specific source wastes (K wastes; 40 CFR 261.."52) as well as
commercial chemical products (U wastes; 40 CFR 261.33). Specifically, this chapter
addresses organic U wastes (2-eihexyethanol (U359), o-toluidene (U328), and p-toluidene
(U353)), UDMH production wastes, toluene diisocyanate 'wastes,' EDB wastes; EBDC
wastes, and methyl'bromide wastes. The six waste groups received final listings between
1984 and 1990. Nearly all of these wastes result from organic chemicals production, and
most contain either halogenated organic compounds or aromatic hazardous constituents.
The purpose of the capacity analysis is to estimate the quantity of these wastes requiring,
alternative treatment or recovery (ATR) capacity as a result of today's final rule.
The remainder of this chapter is divided, in to' two sections. Section 4.1 discusses
the data sources and general methodology used to estimate the required capacity for
other newly listed wastes. Section 4.2 presents the results of,tlie capacity analysis and
discusses current generation and management of other newly listed wastes by waste
group, waste, code, facility, treatability group (Le., wastewater or nonwastewater) and
individual waste stream. . .
4.1 DATA SOURCES AND METHODOLOGY.
EPA used several data sources for conducting the capacity analysis for other newly
listed wastes. Generation and management information concerning these wastes was
collected by EPA during 1990 and early 1991 under the authority of "section-3007 of '
RCRA (data collected by this effort can be found in Docket # F-91-CD2P-5F, and are -
hereafter referred.to as the 3007 Data). Waste generation and management information
for these wastes was requested of companies identified in relevant- chemical industries.
These companies were identified through commercial trade literature as potential
generators based on the manufacture of the products that result in these wastes. EPA
requested information from 25 facilities identified as potential generators of these wastes.
The Agency contacted several of these" facilities to clarify the information they submitted.
Phone logs'of these follow-up calls are presented in Appendix A: Organic Wastes
Generation Phone Logs. Additional information used in this capacity analysis.was
obtained from comments submitted in response to the ANPRM for newly listed and
newly identified wastes (56 Federal Register 24444,'May 30, 1991) and submitted in .
' response to the proposed rule for newly listed and newly identified wastes (57 Eederal
Register 958, January 9, 1992): ...
To assess required alternative capacity for. these wastes, EPA analyzed the current
generation and management of these wastes to determine how each individual waste
stream will'be affected by the final rule. EPA first considered whether a waste steam'.is
currently iand-disposed. If a waste is not currently land-disposed, or is currently !and-
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affected by the final rule. If a generated waste is currently land-disposed, EPA '
considered the current management of the waste to determine whether current treatment
' or recovery processing would meet the LDR treatment being promulgated today. If a
land-disposed waste stream was managed using the BOAT or-an equivalent, the waste
stream was considered not to be affected by today's final rule. Any land-disposed waste
streams that are not currently managed using a BOAT or equivalent were considered to
require alternative treatment or recovery capacity as a result of today's final rule. These
waste quantities were assigned to the BOAT technology to assess whether a national
capacity variance was-warranted. EPA compared the total or'aggregate required capacity.
for a particular treatment or recovery capacity to the aggregate, available commercial
capacity to determine whether adequate capacity exists for each' waste code'.
"t i
4.2 CAPACITY ANALYSIS RESULTS . .
Exhibit 4-1 summarizes the results of EPA's analysis of the quantities of other .
'newly listed wastes requiring alternative treatment or recovery capacity as'a result of
today's final rule. Exhibit 4-1'identifies:
» The generating.facility and a waste stream identifier for each identified
other newty iisted waste stream;
The waste quantity currently generated; .
. The waste quantity being land-disposed (surface-disposed, deepwell-
disposed with a no-migration variance, or deepwell disposed without a no-
migration, variance);
The waste quantity currently treated (or recovered);'
The method by which the waste is currently treated or recovered and the
type of discharge from treatment as applicable; and
* The quantity of each waste'stream identified as requiring alternative
treatment or recovery capacity as a result of today's final rule.
The remainder of this section discusses EPA's capacity analysis for each waste
stream presented in'Exhibit ,4-1. ' ' .
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4.2.1 Unsymmctrical Dimethylhydrazine (UDMH) Production Wastes (K107,
KIOS, K109, and KJ10) ' .
K107.-- Column bottoms from product separation from the production of 1,1-
dimethylhydfazine (UDMH) from carboxylic acid hydrazines.
KlOS -- Condensed column overheads from product'separation and condensed
reactor vent gases from the production of 1,1-dimethylnydrazine
(UDMH) from carboxylic acid hydrazides. .'
K109 -- Spent filter cartridges from, product purification from the production of
1,1-dimethylhydrazine (UDMH) from carboxylic acid hydrazides.
K110-- Condensed column overheads from intermediate separation from the
, .production of 1,1-dimethylhydrazine (UDMH) from carboxylic acid
- hydrazides. ' ' . '
UDMH wastes listings were proposed in December 1984 and finalized in May
199O. For UDMH wastes, EPA is promulgating incineration as the method of treatment
for no n waste waters, and incineration or chemical oxidation or biodegradation followed by
carbon adsorption as methods of treatment for the wastewaters.
. / _ .
Only one manufacturer, Uniroyal, submitted 3007 Data on UDMH wastes. This .
.company formerly used a proprietary process that generates UDMH'wastes, but has
ceased UDMH production. Therefore, the Agency has concluded that no UDMH-wastes
will require alternative treatment or recovery capacity as a- result of today's final rule.
Based on available data, EPA believes that sufficient capacity exists for treatment of the
UDMH wastes; therefore, EPA is not granting a national capacity variance for K107,
K108, K109, and K110 wastewaters and nonwastewaters.
-i
4.22 2-Ethoxyethanol (U359) > , .
U359- 2-Ethoxyethanol . ' ' . ' '
' The U359 waste listing was proposed in July 1985 and made final in February
1986. For U359, EPA is promulgating incineration or .fuel substitution as methods of
treatment forthe nonwastewaters;'and incineration, or chemical oxidation followed by
biological treatment or carbon adsorption,-or biodegradation followed by carbon .
adsorption for the wastewaters.
Three facilities submitted 3007 Data on current U359 waste generation. In
addition, one of these facilities provided information in response to the proposed rule.
Information "on U359 wastes from the three additional facilities is discussed below.
Oxv Petrochemical. Pasadena. TX. This facility reported generating less than one
ton of U359 nonwastewaters, which is sent off site for incineration. Because none of
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these wastes are currently land disposed, EPA concluded that these wastes will not
require alternative treatment as a result of today's final rule. . . "''>'
'- Texas JEastman,_Lgngvkw. TX. This facility currently generates and incinerates on
site approximately 128 tons per year of U359 nonwaste waters. In addition, Texas
Eastman occasionally generates unspecified and variable quantities of U359 wastewater
(none was generated in 1989), which ihey send to on-site biological treatment. Because
none of these wastes are currently land-disposed, EPA concluded that none of these
wastes' will require alternative treatment or recovery as a result of today's final rule.
Union Carbide. Seadrift. TX. This facility reported generating less than one tori
of U359 nbnwastewaters, which is sent off site for incineration.- -Because none of these
wastes are currently land.disposed, EPA concluded that these wastes will not require
alternative treatment as a result of today's final rule.- In addition, Union Carbide
reported generating roughly 500 tons of U359 wastewater from a remedial actioni that
potentially will not meet de minimis requirements. - .
EPA assigned 500 tons to its estimate of required alternative treatment capacity
for incineration of U359 wastewaters. EPA has determined that there is sufficient excess
incineration capacity to handle additionarquantities of LJ359 if the need arises. Based on
the available data, EPA believes that sufficient capacity exists for. treatment of the.U359
wastes; therefore,. EPA is not granting a national capacity variance for U359 wastewaters ,
or nonwastewaters. . . - ' ^.
4.23 Dinitrotoluene and Toluenediamine Production Wastes (K111-K112,
U328 and U353)
Kill - Product washwaters from the production of dinitro toluene .via nitration of
toluene. ... ' ' "
K112- Reaction by-product water from the drying column in the production of
toluenediamine via hydrogenation of diriitrotoluene.
U328- Ortho-toluidine. '
U353 - Para-toluidine. ' , .
. . . . . ' . -r-
Dinitrotoluene and toluenediamine production waste listings were proposed in
May. 1985 and finalized in October 1985. U328 and U353 waste listings were proposed
in May 1984 and finalized in October 1985. For Kill wastewaters and nonwastewaters,
EPA is promulgating concentration standards base.d on a transfer of the F039 standards <
for 2,4-dinitrotoIuene and 2,6-dinitrbtoluene. EPA is promulgating incineration as the
method -of treatment for Kl 12, U328, and U353. nonwastewaters; and incineration,
chemical oxidation followed by carbon adsorption, or biodegradation followed by carbon
adsorption as methods of treatment for K112, U328, and U353 wastewaters.
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' Four facilities reported.generating Kill or K112 wastes in response to the 3007
Data request, and one facility submitted 3007 Daia on current LJ32S waste generation.
In addition, the Agency contacted other facilities that were potential generators of these
wastes in order to obtain further information concerning waste generation, management
practices, and residuals. Finally, information was provided in response to the ANPRM
(56 FR 24444) and the proposed P'le (57 FR 958). ': .
Three facilities reported that they ceased generating K111-KI12 wastes: Oiin
Corporation's Moundsville, WV facility (closed since 19S3); E.I. du Pont in Deepwater,
NJ; and Dow Chemical in Freeport, TX. Six facilities reported that.they currently
generate Kill and/or K112 wastes, and one facility (E.I. Du Pont in Deepwater, NJ)
provided data on current generation of U328.* Below is a summary of current generation
and management practices at these six facilities.
Air Products and Chemicals. Inc.. Pasadena, TX. This facility generates 195,833
tons per year of Kill wastewaters and 87,500 tons per year of K112 wastewaters. A
fraction of the Kill wastewater is chemically oxidized with hydrogen peroxide prior to
mixing with other wastewaters. All facility wastewaters (including K112,-wh!'ch does not
receive on-site treatment) are combined and sent off site for treatment at a POTVV
facility. Since all of the^Kill and K112 wastewaters generated at this facility are .
discharged to a POTW, EPA has concluded that none of.these wastes will require
alterna,.ive treatment or recovery capacity as a result of today's final rule.
. In response to the proposed rule, Air Products and Chemicals (Comment number
CD2P-QOOS4), reported generating 3,500 tons of Kl 11 nonwastewater, which will require
alternative treatment capacity (i.e., incineration). EPA believes that incinerators are
equipped to handle Kill nonwastewaters, but believes that in general facilities manage
'spent activated carbon by returning it to the supplier for regeneration.
BASF Urethanes. Geismar. LA. This facility generates a K112 wastewater. stream
and'no Kill wastes. The rate of Kl 12 wastewater generation was estimated as the
permitted discharge'limit of 60,833 tons per year (40,000 gallons/day). The K112
wastewater is currently treated in a distillation tower followed by granular activated .
carbon beds. Spent carbon is sent off site for regeneration. This company did not report
where effluent is discharged, but EPA assumes treated effluent is discharged to a POTW
or under a NPDES permit. EPA has concluded that none of these wastes are land-
disposed and therefore none will require alternative treatment or recovery capacity as a :
result of today's final rule. ' ( ' l
Baver fMobav). Bavtown. TX. This facility generates Kill wastewaters at a rate
of 54.750 tons per year and K11T: wastewaters at a rate of 35,040 tons per year. These
wastes are commingled with other wastes (they comprise about 3 percent of the
aggregated waste streams) and sent to an on-site biological treatment'plant. Biosludge
from treatment of aggregated wastewater streams amounts to approximately 700 tons per
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year. During management of the'KUl . wastewaser stream, dinitrotoluene is recovered
from the waste-stream using toluene'as an extractant. The water containing residual
dinitrotqluene goes to above-ground biological'treatment, primary clarification, and' " -
carbon absorption prior to discnarce under Organic Chemical, Plastic and Synthetic
Fibers (OCPSF) guidelines (40 CFR 414.SO-9rSub'parts H and I [52 FR 42522]), The
,K 112'wastewater stream is first pH adjusted, and then follows the same treatment train
as the Kill wastewater stream (excluding the extraction step); Biosludge is treated on
site'in a filter press and then incinerated off site, as part of a mixed stream. Ash from
this incineration is land disposed. Carbon is thermally regenerated on site. Because
none of these wastes are land disposed'without treatment using '3 BDAT (incineration),
EPA-lias concluded that none of these wastes'will require alternative treatment or
recovery capacity as a result of today's final rule.
s ' . ' - .
. ' The Bayer f Moba'vl. New Martinsville. WV. This facility generates 45,833 tons
per year of Kill wastewaters and'158,333 tons per year of K112 wastewaters. Kill-and
K112 wastewaters are'mixed with other production wastes, resulting in a combined
wastewater stream of 5,327,000 tons per year that is treated on site. Kill wastewaters
comprise 0.5 to 2 percent of the hydraulic loading,'and K112 wastewaters amount to 2 to
6 percent of the hydraulic loading to the wastewater treatment system, Wastewater
treatment includes neutralization, biological treatment, and carbon adsorption in an
NPDES permitted facility. Approximately 20,000 torts of biological sludge is incinerated
along svjth other wastes in an on-site, RCRA-permitted fluidized bed incinerator. As
much as 9,600 pounds of incinerator ash are-generated per day and shipped off site to a
hazardous waste landfill. Because ail of the Kill and K112 wastewaters generated at
this facility are discharged under a NPDES permit, and all treatment residuals are .
currently treated using the BDAT (incineration), EPA has'concluded that none of these
wastes will require alternative treatment or recovery capacity as a result of today's final
rule. ' .
Olin Chemical. Lake Charles. LA. This facility generates two Kl'12 wastewater
streams and four K112 nonwaste'water streams:.one primary K112 wastewater stream;
one primary K112 nonwastewater stream; two spent carbon nonwastewater streams from
treatment of KIJ2; and one wastewater stream resulting from treatment of K112. It
generates no Kill wastes. .
K112 wastewater, generated at a rate of 76,666 tons per year, is treated in
standard carbon beds and discharged under NPDES. As a result, of this'treatment, 150
..tons per year of spent carbon are-generated. This spent carbon is returned to its
manufacturer for regeneration. Side-draw from the methanol still, column, a K112
.nonwastewater, is generated at a rate of 2,682 tons per year and incinerated on site. (A
small fraction is incinerated off site.) Incinerator scrubber water blowdown, a K112
wastewater, is generated from the on-site incineration of the side-draw (a K112
nonwastewater) at the rale of roughly 525,400 tons per year. This Kl 12 wastewater is .
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treated in standard carbon beds, before discharge under NPDES guidelines. This second.
spent carbon stream, generated at the rate of 20 tons per year, is incinerated off site.
Because all of the K112.wastewaters generated at this facility are discharged under
NPDES guidelines, and K112 nonwastewaters are currently recovered or incinerated,
'EPA has concluded that none of these wastes will require alternative treatment or
recovery capacity as a result of today's final rule.
Rubicon Chemical Baton Rouge. LA. This facility generates 44 tons per year of
Kill wastewaters and 46 tons per year of K112 wastewaters.^ Kill and KI12
wastewaters undergo on-site pretreatment, which includes neutralization and filtration.
Residuals from the treatment-of these wastewaters carrying the Kill and K112 codes (86
pounds per year of each waste) are incinerated off site. The pretreated Kill and Kl 12
svastewater (with a combined wastewater stream of unknown quantity) is deep-well
injected on site; the facility currently has a no-migration variance for this operation.
Because the wastewaters are treated on site and the facility has a no-migration variance,
EPA has concluded that none of these wastes will require alternative treatment or
recovery capacity as a result of today's final rule. . '. i
EJ. Du 'Pont.- Deepwat'er.' NJ. This facility reported generating U328
nonwastewater streams totalling 2 tons, but did not specify how the waste was managed.
Therefore EPA assumed, as a worst case scenario, that the entire quantity is land
disposed and will require incineration as a result of today's final rule.
Based on the facility-specific analysis/described above, the Agency has identified
less than 3,500 tons of Kill nonwastewaters, less than 100 tons of K112 nonwastewaters,
and no Kill or K112 wastewaters requiring alternative treatment-or recovery capacity as
a result of today's final rule. Most of the Kill,and Kl 12 wastes generated are currently
treated and discharged under NPDES. Residuals from treatment of Kill and K112 .
were further treated or recovered before being land disposed. EPA has concluded that
sufficient incineration capacity exists to treat 3,500 tons per year of Kill wastes;
therefore, EPA is not granting a national capacity variance for Kl 11 and Kl 12
wastewaters or nonwastewaters.
, Although available data indicate that considerably less than 100 tons of U328 and
U353 nonwastewaters are currently being land disposed, as a worst case scenario, EPA
assigned 100 tons of U328 and U353 wastes to incineration for this analysis. Based on .
. the available data, EPA believes that sufficient capacity exists for treatment of the U328
and U353 wastes; therefore, EPA is not granting a national capacity variance for U328
and'U353 wastewaters or nonwastewaters. - , ' ' " '
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4.2.4 Ethylenc Dibromide (EDB) Production Wastes (K117-K118,' and K136)
and Methyl Bromide Production Wastes (K131 and K132).
K117 -- Wastewater from the reactor vent gas scrubber in the production of
ethylene dibromide via bromination of ethene.
K118 -- Spent adsorbent solids from the purification of ethylene dibromide via
bromination of ethene.
i
KI36 -- Still bottoms from the purification of ethylene dibromide in'the
production of ethylene dibromide via bromination of ethene.
KI31 -- Wastewater from the reactor and spent sulfuric acid from the acid dryer
from the production of methyl bromide.
K132 -- Spent absorbent and wastewater separator solids from,the production of
methyl bromide. .
Ethylene dibromide (EDB) wastes listings were proposed in October 1984 and
finalized in February 1986. Methyl bromide wastes listings were proposed in April 1985
and finalized in October 1989. For K1I7, K1IS, K136, K13I, and K132 wastewaters and
nonwastewaters, EPA is promulgating concentration standards 'based on a transfer of
data used to calculate the standards for the brominated U wastes (U029
(bromomethane), U030 (4-bromophenyl phenyl ether), U066 (1,2-dibromoo-
chloropropahe), U067 (ethylene dibromide, EDB), U068 (dibromomethane) and U225
(bromofohn)), which were promulgated as part of the Third Third Rule; and multi- ,
source leachate (F039) performance for wastewaters. These standards were based on
incineration for nonwastewaters; and a variety of industrial .wastewater technologies for
wastewaters, including steam stripping, activated sludge, and air stripping. Any other
forms of waste treatment other than impermissible dilution may be used to achieve
numerical treatment standards regardless of which technology served as the basis of the
standards.. . ' '
i . :
Two facilities submitted data on generation of these wastes in response to the
ANPRM (56 FR 24444) and in response to the proposed rule (57 FR 958): Ethyl '
Corporation iiuMagnolia, AR and Great Lakes Chemical Corporation in El Dorado, AR.
Ethyl Corporation also submitted 3007 Data oh methyl bromide waste generation. Each
of these facilities are -discussed -below. , ,
Ethyl Corporation. Magnolia. AR. In response to the proposed rule, Ethyl
Corporation reported generating 30 tons of K118 nonwastewaters; which are currently
land disposed off site.. EPA determined that this quantity of K118 nonwastewater will
require-alternative treatment or recovery capacity as a result of today's iinal rule.
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-, In comments to the ANPRM. Ethyl indicated-that the Magnolia, AR facility'does
not generate any K117. They stated that the aqueous bottoms from the reactor vent
scrubber are not a Kll? wastewater because they are recycled to the bromine production
process on site for acid value and recovery of bromine. In addition, they stated that the
stream generatedrfrom the recovery process (about 13,000 tons per year), also is recycled
and will not require alternative capacity as a result of today's final rule. Because the
stream is not currently, land-disposed, EPA has concluded that it will not require
alternative treatment or recovery capacity as a result of today's final rule.
Ethyl Corporation also generates K131 and K132 nonwastewaters. K131
nonwastewater (spent sulfuric'acict) is generated at the rate of 3,000 tons per year. This
1 waste stream is stripped in an enclosed process until methyl bromide concentration is less
than 200 ppm, and returned to the acid supplier for reclamation. Because this waste
stream is not currently land-disposed, it will not require alternative treatment or recovery
capacity as a result of today's final rule. ', . .
Ethyl Corporation also generates approximately 67,000 tons per'year of an
aqueous stream, which potentially carries the K13I code, from its'TBBP A/methyl
bromide reactor. Ethyl contends that its process is fundamentally different from those
covered by the K13I listing, and that therefore it does not generate K131 "wastewater
from the reactor". They stated that the aqueous portion of a TBBPA product slurry
from Ethyl's TBBPA/methyl bromide co-production process is close-looped recycled to
the bromine production process. Because it is not land-disposed, this -stream will not
require alternative treatment or recovery capacity as a result of today's final rule. : ,
1 ' " ' '
Ethyl Corporation also reported generating K132 nonwastewater (spent alumina
adsorbent) at a rate of 7.5 tons per year. Currently, Ethyl uses a closed-loop stripping
operation to recover the methyj bromide from this stream, before it is removed from the
column to be discarded off site." Ethyl stated that its process can meet BOAT standards
for K132.. Therefore, EPA has concluded that this stream will not require alternative
treatment as a result of today's final rule.
Great Lakes Chemical Corporation. El Dorado. AR. Great Lakes Chemical
Corporation'generates 2,100 tons per year of K131 nonwastewaters which are sent off
site for acid reclamation and.1.5 tons per year of K132 nonwastewaters which are sent
off'site for incineration.. Because these streams are-currently being managed to meet the
promulgated treatment.standard, EPA has concluded that these.streams will not require
alternative treatment or recovery capacity as a result of today's final rule.
Beginning in 1992, the Great Lakes Chemical facility'expects to generate
approximately one million tons per year (260 million gallons) of Kll7 wastewaters froni
ground-water cleanup activities. This stream also will carry the KJ31, U067, and possibly
TC waste codes. As a'result of buried K118 nonwastewaters at two closed landfills on
the El Dorado plant site, Great Lakes Chemical currently collects about 13.1 million
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gailons per yenr of leacfiate and ground water, which'is aggregated with process
wastewater. resulting in disposal of approximately 115 million gallons per year. In
addition to K11S, this wastewater mixture also carries K131 and K132 waste codes. The
stream is currently treated in an on-site wastewater treatment plant (where it-undergoes
neutralization, equalization, and filtration) before being tkep-weil injected. The total
quantity of the two deep-well'disposed wastewater streams to be generated at the Great
Lakes Chemical Corporation facility is expected to be'greater than 300 million gailons
per year. EPA has concluded that there is not adequate treatment capacity for this
deep-well disposed quantity of wastewaters carrying the Kl 17, K118, K131, and K132
waste codes. Therefore, the Xgency is'grantirig a national capacity variance for deepwell
injected-quantities of Kl 17, Klls,. K131, and K132 wastewaters that are deep-well
disposed. EPA has identified no quantities of K117, Kl IS, KI31, or K132 wastewaters
that, are currently being surface disposed. / Therefore, EPA is not granting a national
.capacity variance for K117, K11S,' K131/or*K132 wastewaters that are surface disposed.
Great Lakes Chemical-Corporation.reported that the mixed K117, K11S, K131,
and K132 nonwastewater quantity they reported in response'to the ANPRM will not
require alternative treatment capacity as a result of today's rule. In its comment to the
: ANPRM, Great Lakes Chemical Corporation expressed concern over difficulty in
locating treatment capacity for a waste filter cake potentially carrying the K118, K131,
and K1J2 waste-codes. Great Lakes Chemical Corporation generates 1,'650 tons per year
of filter cake currently identified as K118, K131, and K132 nonwastewater. Analyses of
the fllter cake, indicated that the concentrations of the regulated constituents are below
the treatment standards being promulgated today, and therefore the waste will not '
require treatment as a result of today's final rule. In addition,"Great Lakes Chemicaf -.
Corporation has located a suifuric acid'producer that can reconstitute its K131
nonwastewater stream, .which is generated at the rate of 2,100 tons per year, to
commercial-grade material. Because this waste stream is not currently surface-disposed,
it will not require alternative treatment or recovery capacity as a result of today's final'
rule.. . '
Based on the individual facility analyses discussed-above, EPA'has identified .
several EDB and methyl bromide waste streams requiring alternative treatment or
recovery as a result of today's final rule. Based on new information-received in response
to the proposed rule, EPA estimates that less than 100 tons of currently disposed Kl 18
nonwastewaters will require alternative treatment. .
As a worst case scenario for the capacity analysis, EPA assigned 100 tons of K118
nonwastewater to incineration. The Agency has identified no K117, K136, KI31, or K132
nonwastewaters that will require alterrative treatment as a result of today's rule.
Therefore, the Agency is not granting a national capacity variance for Kl 17, Kl 18, K136, '
j K131 or K132 nonwastewaters. The Agency has identified no,surface-disposed K117,
K118, K136, K131,'.or K132 wastewaters that will require alternative treatment as a result
of today's rule. Therefore, the Agency is not granting a national-capacity variance for
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surface-disposed KH7,-K11S, K136, K13I or K132 wastewaters. A total of greater than
300 million gallons of deep-well disposed Kil7. KilS, K131, and K132 wastewaters will
require alternative treatment or recovery capacity as a result of today's rule. EPA has
determined that there.is not adequate treatment capacity for this deep-well disposed .
quantity. Therefore, the Agency is granting a 2-year national capacity variance for
quantities of K117. K118. K131, and K132 wasiewaters that.are deep-well disposed.
4.2.5 Ethylenebisdithiocarbamic (EBDC) Acid Production Wastes (K123,
K124,,K12S, and K126) . .'.
K123 '-. Process wastevvater-(including supernates, filtrates, and washwaters) from
the production of ethylenebisdithiocarbamic acid and-its salt.
K124 Reactor vent scrubber water from the production of
ethylenebisdithiocarbamic acid and its salts.
K125-- Filtration, evaporation, and centrifugation solids from the production of
ethyleriebisdithio'carbamic acid and its salts.
K126 -- Baghouse .dust and floor sweepings in milling.and packaging operations
from,the production or formulation of ethylenebisdithiocarbamic acid
, and its salts. f .
Ethylenebisdithiocarbamic (EBDC) waste listings were proposed in December
1984 and finalized in October 19S6. For EBDC wastes, EPA is promulgating incineration
as the method of treatment for nonwastewaters, and incineration or chemical oxidation
followed by biotreatment or carbon adsorption as methods of treatment for wastewaters.
- Five companies submitted 3007 Data on EBDC wastes. Two companies reported
current generation of wastes from EBDC production: Alco Chemical in Chattanooga.
TN and Vinings Industries in Marietta, GA. The other three companies, who formerly
produced EBDC, currently do riot generate the EBDC wastes: Rohm and'Haas in '
Philadelphia, PN, Drexel Chemical in Tunica, MS, and FMC Corporation with facilities in
Middletown, NY and Jacksonville, FL. The two facilities, that reported current
generation of EBDC wastes .are discussed below. ' ' ' '
Alco Chemical in Chattanooga. TN discharges several'wastewater streams that
poter.tially cany the K123 code: 10,480 tons per year of scrubber water and 388 tons per
year of evaporator condensate. The streams are treated on site by pH neutralization
prior to discharge to a POTW. These, discharges are not "supernates, filtrates, or
washwaters" and as such the facility does not believe they meet the definition of K123.
Because these wastes are discharged to a' POTW, EPA has concluded that they will not
require alternative treatment or, recovery capacity as a result of today's final rule.
Vinings Industries in Marietta. GA discharges 36 tons per year of wastewater that
potentially .carries the.K123 code. The stream undergoes alkaline chlorination on site.
EPA assumes that'this discharge is either to .a POTW or under a NPDES permit, and
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therefore.will not require alternative treatment as a result of today's final rule. In
addition. Vinirtgs generates 1.75 tons of a K125 nonwasiewater. which is landfilled off
site. EPA has concluded that this K125 nonwastewater will require alternative treatment
or recovery as a result of today's final rule. ' . ' , '
The Agency has identified less than !00 tons of K125 nomvastewaters which are
currently land disposed and-'will require alternative treatment or recovery as a result of
today's final rule. As'a wqrst'case scenario for this capacity.analysis, EPA has^assigned
100 tons of K125 nonwastewaters to incineration capacity. Based on the facility-specific
analysis discussed above, EPA has concluded that no quantities of K123 wastes are .
currently being land disposed, and no K125 wastewaters, K124 wastes/or K126 wastes
are currently being generated. Therefore,1 EPA is not granting a national capacity
variance to K.323, K124, K125, or K126 wastewaters or nonwastewaters. '.
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CHAPTER 5 .
CAPACITY ANALYSIS FOR SURFACE-DISPOSED MIXED RADIOACTIVE WASTES
Mixed RCR_A/radioactive wastes are radioactive wastes that are contaminated with
RCRA hazardous wastes. The treatment standards promulgated as part of the Land
Disposr.! Restrictions apply to these RCRA wastes mixed with radioactive, \yastes.
The Background Document for the Third Third Land Disposal Restrictions'
.provides a-detaileii analysis of the generation of and available alternative treatment
capacity for mixed RCRA/radj'oactive wastes.. Based on this analysis. EPA granted a
two-year national capacity variance to all Third Third surface-disposed mixed
RCRA/radioactive wastes (from May-8, 1990 to May 8, 1992). Included in the.Third
Third wastes were both organic and inorganic-containing wastes. In both cases, there was'
' an overall shortage of treatment capacity: . , ,
/' ^ '.
Since granting that variance, EPA is not aware of any new alternative treatment
capacity that has become available. EPA's data show that there continues to be a '
treatment capacity shortfall for all types.of mixed RCRA/radioactive wastes, and
consequently, EPA is today granting a two-year national capacity variance to ail surface-
disposed mixed RCRA/radioactive wastes contaminated with F037. F038, K107, K108.
K109, K1IO, Kill, KI12, K117, K118, K123, K124, K125, K126. K131, K132, K136,
U328, U353, and U359. . '
5.1 BACKGROUND \
EPA has defined a mixed RCRA/radioactive waste as any matrix containing a
RCRA hazardous waste and a radioactive waste subject to the Atomic Energy Act (53
FR 37045, 37046, September 23, 1988). Regardless of the type of radioactive
constituents trjat mixed RCRA/radioactive wastes contain (i.e., high-level, low-level, or
transuranic), these wastes are currently subject to RCRA hazardous waste regulations. In
general, the treatment standards for mixed RCRA/radioactive wastes are the same '
treatment standards in effect for non-radioactive hazardous wastes.
Radioactive wastes that arc mixed with spent solvents, dioxins, or California list
wastes, or First Third, Second Third, or Third Third scheduled wastes are subject, to the
land disposal restrictions already promulgated for those hazardous wastes. -In,the Third
Thirds rulemaking, EPA granted a two-year national capacity variance for mixed
RCRA/radioactive wastes contaminated with First Third, Second.Third, and Third Third
wastes because of a lack of available treatment capacity. Although this variance expired
-
EPA. Background Document For Third Third Wastes To Support 40 CFR Part 268 Land Disposal
Rest fictions.'Final Rule. Third Third Waste Volumes, Characteristics, and Required and Available Treatment
Capacity. Volume III. Appendix B. May 1990. ' ' '
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on May S, 1992, the Department of Energy (DOE) has submitted a case-by-case .
extension application for certain Third Third mixed RCRA/'radioactive wastes generated
and stored at 31 of its facilities. DOE requested a one-year extension of the Third Third
capacity variance for the mixed RCRA'radioactive wastes addressed in the application.
EPA is reviewing DOE's application and has issued a proposed finding that DOE
has made all but one of the demonstrations required by 40 CFR 268.5 for-a case-by-case
extension (57 FR 22024, May 26, 1992). The.remaining demonstration requires DOE to
enter into a binding contractual commitment to construct or otherwise provide alternative
treatment, recovery, or disposal capacity for the wastes.included,in the application. EPA
will consider granting the case-by-case extension based on its-evaluation of the remaining'-
demonstration. In addition, EPA has taken regulatory action to grant a generic, one-year
extension of the LDR effective date applicable to all facilities managing hazardous debris
(with several exceptions)'(57 FR 20766, May 15, .1992), including mixed
RCRA/radioactive waste classified as debris. This extension is effective from May S,
1992 to May 8, 1993. . ' . . .
The proposed rule (57 FR 958;'January 9, 1992} presented the results of-EPA's
preliminary capacity analysis. Based on this analysis, .EPA proposed a two-year national
capacity.variance for mixed RCRA/radioactive wastes contaminated with the newly listed ,
wastes. In response to the proposed rule, seven commenters discussed issues relating to
capacity available for the treatment of mixed RCRA/'radioactive wastes. Only one
commenter, DOE, provided quantitative information on mixed RCRA/radioactive wastes.
The commenters addressed the. following major issues: > '
" The two-year national capacity variance for mixed RCRA/radioactive
. wastes is justified; . . ' ' ,
- The two-year national capacity variance for mixed RCRA/radioactive
wastes is.not justified; _ _ '
DOE should not be relied on to develop new capacity;
. Non-DOE mixed RCRA/radioactive wastes should be stored under an
. emergency permit program; . . ,
Treatment capacity for some, mixed RCRA-'radioactive .wastes is increasing;
' Several obstacles exist to the.development of new treatment capacity for
mixed RCRA/radioactive wastes; and '. ' r ' .
'' . ' *
EPA should encourage separation of the hazardous and radioactive
components of mixed RCRA/radioactive waste.
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Information that EPA received in'support oi the proposed national capacity
variance for newly listed mixed RCRA'radioactive wastes is included in ihe analysis that
follows. This analysis presents the rationale for EI'A's decision to grant such n variance
, in today's ruiemaking. For a more detailed discusMmi of the capacity related comments
for mixed RCRA'radioactive wastes and the Agency's response to these comments.
please refer to the Response-to-.Comments document.
5.2 ANALYSIS OF ALTERNATIVE TREATMENT CAPACITY
As part of this capacity analysis conducted to support.the final rule on the land
disposal restrictions for newly listed mixed RCRA/radioactive wastes, and in response to
comments received on the. proposed rule, EPA examined the-l99i Report on Hanford.
Site Land Disposal Restrictions for Radioactive Mixed Wastes. DOE/RL-43, October
1991 (hereinafter cited as 1991 Hanford Site Report). EPA not only used the 199j
Hanford Site Report to refine its initial analysis conducted for the proposed rule, but also
' to determine if large quantities of previously restricted mixed RCRA/radioactive' wastes
still exist that require treatment. Th'ese mixed wastes would have priority over newly
:listed mixed RCRA/radioactive wastes for the "purpose of assigning treatment capacity.
* EPA's capacity analysis methodology assigns any new commercial capacity for mixed
RCRA/radioactive wastes that becomes available to mixed wastes that were regulated in
.previous land disposal restriction rulemakings (i.e., radioactive wastes mixed with
solvents, diprinsj California list wastes, or First Third, Second Third; or Third Third
wastes). ' '
. Based on comments received in response to the Advance Notice of Proposed
Ruiemaking (ANPRM) (56 FR 24444, May 30, 1991), and during previous rulemakings,
EPA believes that DOE facilities generate the vast majority of mixed RCRA/radioactive
wastes. According to the Background Document for the Third Third Land Disposal
Restrictions, non-DOE mixed RCRA/radioacfive/waste is believed to account for less
than one percent of all mixed RCRA/radioactiye wastes generated nationwide. Based on
DOE comments submitted in response to the ANPRM, DOE generates relatively small
quantities of mixed RCRA/radioactive wastes contaminated with newly listed organic .
wastes and petroleum refining wastes. EPA also believes.that there are few, if any,.other
generators of these wastes.. ' ' .
In addition, based on comments received on the proposed rule, information from- .
the ANPRM, and information received during previous rulemakings, DOE faces major
treatment capacity shortfalls for previously regulated mixed RCRA/radioactive wastes
that it generates. Consequently, EPA believes that there isi currently no available '
capacity for even relatively small quantities of newly listed'mixed RCRA/radioactive
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wastes, and therefore adequate capacity is not available for newly listed mixed
RCRA/radioactive wastes^. _, ,- .
The i99LHanford Site Report was submitted by DOE as part of its comments on
the proposed rule, and it illustrates the lack of treatment capacity for newly listed mixed
RCRA/radioactive wastes.- The Report 'contains "a detailed description of the generation
and management of land disposal restricted waste (mixed waste) generated, treated, and
stored at the Hanford Site." The Report also identifies 16 land disposal restricted mixed.
waste streams and classifies these wastes based on eventual -waste treatment methods.
.Overall, the 1991 Hanford .Site Report provides information on the following:
' schedules and methods 'for characterizing each land disposal restricted
waste stream; ...
"/ ' the quantities and types of waste in storage; ' "
« storage capacity; .
. waste treatment processes;
* schedules for developing appropriate treatment technologies and capacity; '
and , ' .
methods to minimize
stream. .
the generation,' volume, and toxicity of each-waste '
Using data characterizing the 16 restricted mixed RCRA/radioactive waste streams
identified by the 1991 Hanford Site Report. EPA developed Exhibits 5:1 and 5-2. For
each waste stream, Exhibit 5-1 summarizes the quantities of waste in storage, available
storage capacity, dates when storage capacities are expected to be full, and future waste
generation projections. Exhibit 5-2 summarizes planned waste treatments for each waste
stream, the capacity of each treatment type, and the expected dates on which each.
treatment capacity will be available. The 1991 Hanford Site Report does not identify any
mixed RCRA/radioactive wastes affected by the LDRs being promulgated today.
Availsbte" capacity refers to the amount of treaimem capacity that a unit offers beyond any treatment
that is currently taking place. ' .- -
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' ' Exhibit 5-2
Planned Mixed RCR.VRadioacti»e Waste Treatment ai ihe Hanford Site
Trsittnent Ficitit>A
t
242-A Evaporator
Effluent Treatment
Facility (ETF)1
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Hanford Waste
' Vitrification Plant .
(HWVP)
Incinerator (off-site)'
Incinerator (on -site)
Waste Receiving and
Processing Facility
(WRAP)
TBD
Streams L'lililiRg
Treatment Facility
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9. 13. 14. 16
5.9.10.11. 12
Planned Treatment
evapc ration
destruction of orginics.
removal of inorganics
grout
Minftcaiion'
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incineration
TBD
TBD
TBD. deactrvation for
waste stream no. 5
Planned dpaciiy
(m; >ear)
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6.000 ,
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TBD
TBD '
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October 1994
. 19"Jle
December. 1999
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September 19W
TBD
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i Wiste'stream no. 15 will noi be treated at the Haitian) Site, but will IK shipped to itie Waste Isolation Pilot Plant for
permanent storage. ' .
b OOE plan* to incinerate waste stream no. S off-tile at aa undetermined facility.
c , The planned capacities presented io this calurna weir calculated assuming that the treatment facilities operate 200 days a
year, at daily capacities of 870 m* for the 242-A Evaporator, 382 m' for the CTF, and 33 mj for the ETF.
d ' The condensaie from the evaporator vrill be treated at the ETF. >
e Some of nut stream no. 1 can be treated directly at the OTF- MOM wa>te> thai arc to be treated at the GTF wiil Tint
have to undergo prctrcatmcnt io separate them from otter wutes. Pretrtatment is expected to begin in 1994.
According to EPA's analysis, approximately 225,000 m3 of restricted mixed
RCRA/radioactive wastes are currently stored at the Hanford Site. The current total
storage capacity for these wastes is approximately 570,000 m3. The Hanford Site pians to
implement a waste reduction and minimization program'that is expected to reduce the
amount of mixed RCRA/radioactive wastes generated at the facility by approximately
100,000 m per year. The majority of the reduction is expected to come .through
treatment. ' ' .
*
Overall, however, EPA's analysis shows that treatment capacity for most of the
previously restricted mixed RCRA/radioactive wastes stored and expected to be
generated at the -Hanford Site will not be available until after October 1994. Although
the 1991 Hanford Site Report identifies no mixed RCRA/radioactive wastes affected by
the LDRs being promulgated today, the waste stream information presented above serves
as an example to confirm the Agency's belief that a lack of available treatment capacity
exists for previously regulated mixed^RCRA/radioactive wastes. As a result, EPA
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'considerable number of treatment units are either planned or under construction at DOE
facilities. At least 20 different treatment units are expected to come on line at DOE
facilities between 1992 and 2012. These units will include several' ir.cinerators.
solidification units, vitrification and glass/ceramic process units, grout operations, and
other treatment units such as evaporators and leaching systems. When operational, these
units will provide significant treatment capacity, for a number of treatability groups for
mixed RCRA/radioactive wastes generated at DOE facilities in the future.
Although DOE does have operational combustion facilities, their capacity is or- will
be utilized for previously generated mixed RCRA/radioactive wastes 'containing spent
solvents, dioxins; California list and First Third, Second Third, or Third Third scheduled
wastes, and is therefore not available for newly listed mixed RCRA/radioactive wastes.'
For the purposes of this capacity analysis for newly listed mixed 'RCRA/radioactive
wastes, then, available DOE combustion capacity for those wastes is zero. Similarly,
there is no other available capacity for newly listed mixed RCRA/radioactive wastes.
5.3 NATIONAL CAPACITY VARIANCE FOR MIXED RCRA/RADIOACnVE
. WASTES . . .
Based on the analysis discussed in section 5.2, EPA believes, that DOE generates a
large majority of mixed RCRA/radioactive wastes affected by this rulemaking and
previous LDR rulemakings, and that major treatment capacity shortfalls currently exist
for previously regulated mixed RCRA/radioactive wastes generated at both DOE and
non-DOE facilities. As a result, EPA has determined that there is currently no BOAT or '
equivalent available treatment capacity for any newly listed mixed RCRA/radioactive
wastes at DOE or non-DOE facilities. Because a treatment capacity shortfall was
, identified for every mixed RCRA/radioactive waste treatability group, EPA is today
granting a two-year national capacity variance for all mixed RCRA/radioactive wastes
contaminated with newly listed wastes for which treatment standards are included in this;
rulemakirig. '..'.
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' . CHAPTER 6
CAPACITY ANALYSIS FOR DEBRIS CONTAMINATED
WITH NEWLY LISTED WASTES
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6.1 INTRODUCTION AND KEY FINDINGS . '
i,, ', '
This document presents' the capacity analysis EPA conducted to support the final
rule on the Land Disposal Restrictions (LDRs) for debris contaminated with the Newly
Listed wastes. The purpose of the capacity analysis'is to establish the effective date of
the rule. (Please refer to Document 1 for a description of.the^Newly Listed wastes
covered in this rule.and for other background information on capacity analysis).
Specifically, this document presents the data and methodology used to derive estimates of
the quantities of hazardous debris that require alternative .treatment and recovery prior >
to land disposal as a result of the LDRs.
The capacity analysis presented in this document involves a two-step process: (1)
estimating all hazardous debris generated that is inherently hazardous or contaminated
with previously regulated wastes; and (2) estimating quantities of debris contaminated
with the Newly Listed wastes, covered under this rule. Estimating the quantities of all
hazardous debris, as defined in this rule, is necessary because this rule establishes new,
treatment standards for all debris, including debris contaminated with previously listed
wastes. Therefore, the commercially available treatment capacity for debris
contaminated with the Newly Listed wastes is affected by the total volume of hazardous
debris generated. , .
This capacity analysis is based on comments and data received in,response to the
Proposed Rule (57 FR 958), comments and data received in response to the Advanced
Notice of Proposed Rulemaking (ANPRM) for wastes covered in this rule (56 FR
.24444), industry roundtable meetings, and the National Survey of Hazardous Waste
Treatment, Storage, Disposal, and Recycling Facilities (TSDR Survey). EPA's central
estimate for the total of currently land-disposed debris contaminated with RCRA
hazardous wastes is approximately 1 million tons per year. This estimate is based oh
percentages of the total of allhazardous wastes land disposed that are'classified as
RCRA hazardous debris. EPA also estimated lower and upper bounds of 700,000 to 2.8 >
million tons' per year, respectively, based on adjustment factors to the TSDR survey data.
In this rule/EPA is requiring that hazardous debris be treated prior to land
disposal using one or more of the following families of debris treatment:
. Extraction; . . '.
Destruction; and ' . ' _
Immobilization. '
However, the Agency believes that there are constraints on the management of debris for
all three treatment categories.' The availability of many extraction; destruction, and
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immobilization 'technologies is limited due 10 a lack of available RCRA permitted
treatment capacity. In addition,-the use of some destruction and immobilization
treatment technologies is restricted by materials:hand!ing problems. These capacity
constra'inis are compounded-hy the iarge quantities of debris contaminated with
previously listed wastes that would require treatment concurrently with debris
contaminated with the Newly Listed wastes: Therefore, in order to minimize disruptions
in the management of hazardous debris, the Agency took regulatory action en May S,
1992 and granted a generic, one-year extension to the LDR effective date for all facilities
managing hazardous debris (with several exceptions) (57 FR 20766). In addition, EPA is
' granting a two-year national capacity variance to debris contaminated with the Newly
Listed wastes covered' in this rule.
This document is organized in four sections. Following this introduction, the
second section summarizes the available information sources on hazardous debris. These
sources include comments .to the Proposed Rule and ANPRM, roundtable meetings held '
with representatives of companies generating and managing hazardous debris, data
submitted voluntarily to EPA, the TSDR survey, and Superfund Records of Decision.
The third section describes the methodology used to derive debris quantity estimates
presented in the rule. The final section discusses the available capacity for managing
hazardous debris.
6.2 AVAILABLE INFORMATION SOURCES
EPA used a variety of information sources to estimate the quantities of hazardous
debris requiring treatment capacity. These sources include information received in
' response to the Proposed rule for the Newly Listed Wastes (57 FR 958); the ANPRM
for .the Newly Listed wastes (56 FR 24444); a series of Roundtable meetings held by the
Agency with representatives of companies involved in the generation, management and
disposal of hazardous .debris; and from the National Survey of Treatment, Storage,
Disposal and Recycling-Facilities (TSDR Survey), The Agency also examined data from
Superfund Record of Decisions (RODs), as well as information contained in trade
journals and other sources. Finally, the Agency interviewed experts in hazardous debris
generation, management, and treatment. ' - ' -
The Agency used these information sources to estimate the quantities and types of
hazardous debris that will require treatment at the time this rule becomes effective. . ,'
6.2.1 Comments to the Proposed Rule . ' '
The January 9,.'1992 Proposed Rule (57 FR 958) presented the methodology for
and the results of EPA's preliminary capacity analysis. Based on this analysis, EPA
proposed a two-year national capacity variance for debris contaminated with Newly
Listed wastes. The Agency solicited comments on its approach as well as estimates of '.
available treatment capacity. ' ' '
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" EPA received over 100 debris-relatec! comments in response to the Proposed
Rule. Of these. '45 comments discussed issues relntiny to capacity available for
contaminated debris.. The commemers raised the following major issues:-
, Underestimation of the quantity of contaminated debris generated;
' Total volume of debris generated; ,
-Capacity variances for hazardous debris contaminated with "- -
newly listed wastes; ' - .
* ». Capacity variances for hazardous debris contaminated with previously
regulated wastes; '
Materials handling problems with hazardous debris;
« Concerns about treatment capacity for. hazardous debris; and
, Concerns about storage capacity for contaminated ^debris. . . ,
Several commenters'referred specifically to'hazardous debris contaminated with
. F037 and F038 wastes. Generally, these commenters supported the proposed two-year
variance for debris contaminated with'F037 and F038. Seven commenters provided
quantitative debris information. Exhibit 1 presents-.the quantitative data received in
comments to the proposed rule. ', ' . * '
For a more detailed discussion of the capacity related comments for hazardous
debris and the Agency's response to these comments, please refer to the Response-to-
Comments document. '
6.2.2 Comments to the ANPRM
The May 30, 1991 ANPRM (56 FR.24444) identified EPA's data requirements for
performing a capacity, analysis on debris contaminated with the Newly Listed wastes. As
such, EPA requested comments and information on the volumes and characteristics of -.
hazardous debris generated and managed. EPA also requested information concerning
available or potential treatment technologies, their capacity, performance, and limitations
or constraints.' EPA also solicited comments and-information on other capacity-related
.issues including the potential treatment difficulties encountered in asbestos-containing
debris, PCB-hazardous debris, and debris with inherent contamination. x
/
. EPA,received-37 debris-reiated'comments in response to the ANPRM. Of these,
seven contained quantitative debris information. Some commenters provided.information
on types of debris (ranging from broad categories.of debris to specific quantities of debris
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EXHIBIT 1
HAZARDOUS'DEBRIS QUANTITIES REPORTED
IN PROPOSED RULE COMMENTS ~ '
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Commenter
Envirosafe-
. Beazer East
Soil Tech
uspci
Department of the Army
Waste Management
Model City Landfill
DuPont
Data
95% of all loads Contain debris
22,500 cubic yards of debris at one'
-. -site
, 77,000 tons of contaminated
material has been treated -
69% of remedial projects include
a significant amount of debris ,
17 million square feet of potentially
hazardous demolition debris , ,
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200,000 cubic yards/year of debris
10JOOO cubic yards .of debris from-
one cleanup
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EXHIBIT 2
HAZARDOUS DEBRIS QUANTITIES REPORTED
' '
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Commenter ' '
Chemical Waste Management
, . Olin Chemical -
ThermalKEM
Chempro
DuPom
Union Carbide
Canonic
IN AN PRM COMMENTS
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Several commenters addressed the issue of treatment of mercury-contaminated.
(D009) wastes. They noted that many items, particularly, debris items, were' not suitable
for'thermal treatment which is the BDAT for this group. Additional comments focused
on refractory bricks which may be contaminated during their use and'are often inherently
characteristically hazardous due to their high chromium content. Comrnenters also
expressed concern over debris contaminated with asbestos, and the risk arid danger to
workers and local air quality effects if asbestos materials were to be fragmented arid
particularized during treatment, . .
.' These issues and concerns are also covered in Appendix B, Contaminated Debris
Issues and Concerns. .
6.23 Roundtable Meetings .' . '
As part of the Agency's efforts to gain a more complete understanding of capacity
issues associated 'with the land disposal restrictions for hazardous debris, EPA held three
joundtabie meetings with representatives of companies that generate or manage these
wastes during the months of May and June, 1991. The roundtable meetings covered a
"broad range of topics, including generation and management of hazardous debris,
composition of hazardous debris, and capacity issues: ,
, ' The first roundtable meeting included representatives from seven waste
management companies who operate'commercial landfills, and a
representative from the National Solid Waste Management Association;
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* The^second roundtable meeting was attended by representatives from .
thirteen companies that generate and primarily manage, hazardous debris in
on-site landfills; and
* The third roundtable meeting included waste treaters and brokers from
seven firms, ' . ' . ,
6.2 J.I Quantities and Composition of Hazardous Debris '
'. ' In these roundtable discussions, industry participants provided information on the
quantity and composition of hazardous debris generated and/or managed by'lheir ' .
companies. This information was used to update data submitted in response to the 1987 -
TSDR Survey. . ...
Most participants provided quantity estimates of the proportion of the total waste
volumes they manage that could be classified as debris. Of. the eleven generators'that
estimated the'volume of waste managed on-site classified as debris, four estimated that
debris comprised 10 percent or less of the total waste volume they manage; three
estimated'that debris accounted for between 10 and 25 percent of. the total, three
reported that debris contributed to about 50 percent of the waste managed on-site, and
one generator estimated that debris comprised almost 80 percent of the total'waste
landfilled. '
/
One representative of a commercial landfill estimated that 75 to 80 percent of all
deliveries to landfills contain some type of debris. Practically >all deliveries of wastes from
remedial actions are believed to contain at.least some debris. A second landfill operator
estimated that approximately 30 percent of the wastestream volume received could be
classified as debris. v . .
Waste generators noted that debris comprises a large diversity of materials, often
generated on an irregular basis. Some of the most common types of debris include
construction debris, wood, rocks, bottles, and miscellaneous equipment ranging from
laboratory gloves to empty containers, filters, and pipes. Participants also noted that
filters corne in ail sizes and, shapes and that, although they are typically made of some
type of metal, they also can be made of such materials as polypropylene, dacron, and
nylon. In addition, there are also activated carbon filters, caustic filters, and clay filters.
Representatives from commercial landfill companies noted that some types of
debris such as personal protective equipment, spill cleanup materials, and contaminated
scrap metal and equipment are universally generated, whereas the generation of some"
other types of debris may vary among the different region of the United Slates.
Participants also remarked that some debris waste streams are recurrent, including
asphalt from oil change businesses, oil wax and wicks from train maintenance, and filters
from all types of industrial processes. '. -
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Overall, the rouhdtnble participants agreed that quantifying debris volumes is
difficult^ because debris is often generated wiih soil or mixed with'Other contaminants and
separation is not usually possible. Furthermore, TSD facilities have historically classified
wastes according to waste code rather than by waste type (i.e., debris). Accordingly, (He
quantity data on debris'wastes are less precise than data for most oth'er hazardous waste
streams. '_.' ' .
6,2-5.2 Sources of Hazardous Debris . ' _ .
For purposes of this capacity analysis, EPA has divided the universe of hazardous
debris into three primary sources: (1) routinely generated debris, (2)
demolition/construction debris, and (3) remediation debris. Each of these sources has '
characteristics that affect the type, quantity, variety, and timing of debris gene'ration.
Participants to the roundtable meetings shared their experience with .debris from these .
sources. . '
Routinely generated debris includes waste items that are generated regularly or .
.continuously from a given "source" or industrial activity. Examples of routinely generated
-debris include: ' " ' ,..-
', Filters; .. -.
Off-spec manufactured items; . '
* Spent batteries;' ., '" ' .
Lamps and electronic components; and
' Personal protective equipment (PPE).
Debris from demolition and construction activities are generated sporadically
because construction and demolition tend to be seasonal and non-continuous.
Furthermore, the quantities of debris generated vary from site, to site. Debris resulting
from private party remedial actions that are relatively small in scale are included in the
demolition/construction category. The types of materials generated in this category .
include:? '-.'.-, , .. ' ''"'," '
Concrete and metal-construction materials;
. Geologic materials; and
' Durable manufacturing and process equipment. . . '
Remediation 'debris are generated through Superfund, State CERCLA, and
RCRA corrective action activities. This source category is characterized by large
quantities'of hazardous debris being generated from single locations over a potentially
long period of time. . "' " . .
Exhibits 3 through 5 depict the various s'oufccs of hazardous debris and
subsequent management options. .
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The quantity of debris generated through' demolition/construction and; remediation
.related activities is .estimated to exceed the amount of routinely generated debris by up-
to a factor of ten. Debris from large remedial actions tend to be managed on-site and
therefore do not require off-site commercial treatment capacity. However, debris from .
demolition or construction and from routine operations y-? usually sent off-site for ;
manacement and constitute the most important sources of debris requiring commercial
off-site treatment. Exhibit 6 presents the relative volumes of hazardous debris currently
going to commercial landfills. N
The volumes of debris that are generated also vary depending on the region, the
time of year, and economic conditions. For examp.le, more debris is generated in the
summer than in the winter due to increased construction .activities. "In aging industrial
areas, a greater quantity of de'bris is generated from the .demolition of older plants,
whereas in other areas, a greater proportion of the generated debris may originate from
road construction or the cleanup of federal facilities. At many southern sites,
approximately 25 percent of the tonnage generated at remediation sites is reported to be
wood. Finally,-in a depressed economy/industrial waste streams are reduced and plant
retrofitting is delayed or cancelled, resulting in smaller quantities of debris generated.
6.23J Current.Management of Hazardous Debris
The management of hazardous debris is often made difficult-because of material
size and because debris wastestreams are often mixed with other contaminated wastes.
Management options currently employed include landfilling debris without treatment,
.incineration, stabilization, and decontamination through washing and steaming. (Exhibits
3 through 5 show the. variety of management options.) Approximately SO percent of the
hazardous debris land disposed off-site is landfilled without treatment. Data received by
EPA indicate that, of the land-disposed hazardous debris, approximately 90 percent is
contaminated with metals, while the remaining 10 percent contain organics, and are often
also contaminated with metals. '
Participants to the roundtabte meetings estimated that incineration is the
predominant treatment method employed for the hazardous debris that are now treated.
While stabilization of hazardous-debris is also practiced, one constraint to stabilization is '
the availability of sizing equipment required for pre-treatrnent. Also, debris,
contaminated with asbestos is not .usually stabilized because of'the potential health risks
. to workers. .
1 This estimate is skewed towards debris contaminated with inorganics because the national capacity
variance granted in the Third Third rule to inorganic solids debris was in eff' :t at the time these daia were
collected. Furthermore, the impact of the new Toricity Characteristic (TC) rule is jusl beginning' to he
reflected in the data available to EPA. ;
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Sources of Hazardous Debris
.Received By Commercial Landfills.
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Demolition Debris
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A large proportion'of hazardous debris could be managed using,decontamination-
processes. Nfany facilities and treaters are currently.performing what they consider to be '
decontamination of materials on-site, a process whereby the hazardous'waste is'separnted
.from the debris material, thereby decontaminating the debris material. Roundtable .
participants argued that EPA needs to recognize these procedures. Commenters also <
argued that if treatment permits were required for practices currently considered to be '
decontamination,'th.is would.cause severe disruptions in treatment. EPA has taken these
comments into consideration in updating its treatment standards. Nevertheless, EPA.
recognizes that the currently available RCRA permitted capacity for many extraction
technologies is very limited. ' ' " '
6.2.3.4 Other Issues of Concern ' '''.'''
Other issues of concern brought up by the roundtable. participants include
permitting and capacity constraints. * New treatment capacity is expected to take time to
come on-line due to the permit process. Participants said that permit approval for
simple technologies, such as shaking,or washing may lake up to two years. Obtaining a
-permit'for incineration could take even longer or may not be possible at all because of
widespread public opposition to this technology. Furthermore, debris treatment may
require very large pieces of equipment as part of the pre-ireatment process, such as a
new grizzly system which could be very expensive. Another issue raised is that because
of the time and expense of adding new hazardous waste landfill capacity, landfills may
begin to be selective about thfe wastes they accept, reserving their capacity for highly
priced hazardous wastes. - .
.These issues and concerns raised by the regulated community indicate that the
, available capacity to handle\the quantities of previously regulated hazardous debris may
be constrained by materials handling and permitting problems. EPA has taken these
concerns into consideration in its proposal to grant a national capacity variance, to debris
contaminated with the Newly Listed wastes. In addition, in order minimize disruptions in
the management of all hazardous debris, the Agency took regulatory action on May 8,
1992 and granted a generic one-year extension to .the LDR effective date for all facilities
managing hazardous debris (with several exceptions) (57 FR 20766 May 15, 1992).
6.2.4 National Survey of Treatment, Storage, Disposal and Recycling Facilities
(TSDR Survey) '
The TSDR Survey was conducted during 1987 to obtain comprehensive data on
the nation's capacity for managing hazardous waste.- Types .of information collected
included data on the quantities of hazardous waste being land disposed,.quantities of
waste generated; as well as information on waste characterization, and hazardous waste .
treatment capacity in units exempt from RCRA permitting. Th: TSDR Survey covers
facilities with permitted waste treatment, storage, disposal, arid recycling units. Although
.the TSDR Survey remains the most comprehensive available data source .on the total
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quantity of land-disposed-hazardous wastes, it is incomplete and poorly defined for
estimating hazardous debris .due to the following limitations:.
The TSDR Survey questionnaire did not recognize hazardous debris as a
separate waste category. Therefore, the regulated community did not
. .specifically classify their debris wastes.
. In the TSDR Survey, debris were.often mixed with other waste streams
(e.g., soils), which were frequently contaminated by more than one RCRA
waste code. ' . .
. The TSDR Survey, conducted in 1987,-does not include debris
"' coniaminated with the Newly Listed wastes,, because many of these wastes
were not listed as hazardous'at that lime.
Despite these limitations, data from the TSDR Survey" can" be used in combination
with more recent data to develop estimates of volumes likely to require commercial
treatment. For example, information on debris waste quantities can be extracted from
the TSDR Survey using waste descriptor codes. These codes describe in general terms,
the physical/chemical characteristics of each wastestream. The descriptor "code B43, for
example, is used for,a wastestream described as empty or crushed metal drums or
containers, all of which would fall into the debris category. Exhibit 7 lists waste
descriptor codes in the TSDR Survey that relate to hazardous debris. The wastestreams
identified as contaminated soil or cleanup residue are assumed to contain'10,percent ,
debris and 90 percent contaminated soil. ,
6.2,5 Other Information Sources '
In addition to the information sources described above, the Agency'also reviewed
Superfund Records of Decisions (RODs) for data on hazardous debris at Superfund sites.
Superfund RODs, in generaf, specify the recommended course of action for remediating
a Superfund site, describe types of contamination present, and estimate cleanup costs and
time required to complete remediation. RODs vary greatly in the level of detail provided
regarding volumes of hazardous waste, including hazardous debris. RODs signed prior to
1988 contain few data on waste volumes, whereas those signed during 1988 and 1989
contain- more complete and detailed information on contaminated volumes. However,
even among the more recent RODs that do'provide volume information, no distinction
was made between contaminated soil and debris in the reported volume figures.- Also,
many facilities combine their contaminated soil and debris volumes with other soil wastes,
which can result in an overestimate of the debris volume.
Of the 287 RODs (for the years 19S8 and 1989) examined by the Agency, only 62
provided information on contaminated soil and debris. The other RODs either contained
no quantitative information or indicated zero volumes of hazardous debris. The. Agency ;
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6-15.
. EXE1IBIT7 s
TSDR SURVEY HAZARDOUS DEBRIS \VASTE DESCRIPTOR CODES
Debris Descriptor
Code
A06
A08
AEA
B38 and B39
B42
' ; B43
' B44
B45 and BIM
B54 and BS7
. B56
. B85
BEM
BIQ and BFR
BIU
.BJC
BJD
', BJS
BJT
BJW
BXB
BXJ
Debris Description
Contaminated soil or cteanup residue
Concentrated off-spec or discarded product
Other untreated wastes
Other "dry" ash, sla'g, or thermal residue
Metal scale, fillings, or scrap
Empty or crushed metal drums or containers
' Batteries, battery parts, casing, cores
Spent solid filters or adsorbents
Lab pack or debris
Other inorganic solids
Empty fiber or. plastic containers . ,
Lead contaminated floor debris
' Acid or caustic spill cleanup waste
Used mercury lamps
. - Grit blasting residues, metal dust,
Arsenic contaminated, waste solids
Contaminated trash
Other debris
Paint pigment solids'
Lab cleanup material
. Paper paint filters with heavy metals
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6-16
estimates that approximately 300.000 metric tons of hazardous debris' will be generated at
these 62 Superfund sites. However, the RODs also indicate that the primary means of
'managing debris at Superfund sites is on-site treatment and disposal. Therefore, 'these
volumes' will have a limited impact on commercial treatment capacity.
As part of its data collection efforts, EPA reviewed various background documents,
and data bases prepared for earlier regulatory actions such as the Land Disposal
Restrictions. The Agency also reviewed trade journals that contained data on hazardous
wastes received by commercial landfill facilities. EPA .used these data to estimate
hazardous debris volumes for facilities- not included in the TSDR Survey.
EPA also solicited estimates of volumes of hazardous debris from experts. For
previously 'regulated hazardous debris, EPA relied on rwo contractors, 'one an expert in,
hazardous debris generation and the other an expert in hazardous debris treatment. For
newly regulated hazardous debris, EPA conducted its analysis based on the quantified
judgements of experienced and qualified environmental management personnel at
facilities affected by this rule. ' .
63 CURRENT GENERATION OF HAZARDOUS DEBRIS WHICH WLL ^
REQUIRE TREATMENT CAPACITY -
' Today's rule includes a new definition of hazardous debris and establishes
management options for its treatment and disposal. These management options are
applicable hot only to debris contaminated with the Newly Listed wastes,' but also to
debris contaminated with previously regulated wastes: (e.g., Third Third wastes). Under
the Third Third Rule, contaminated soil and debris were grouped into a single waste .',
category,-and treatment standards were set based on the contaminant waste codes rather
than on the intrinsic characteristics of the waste matrix (i.e.,.the physical characteristics of
. debris). In previous rulemakings, EPA granted national capacity variances to hazardous
. debris. These previously regulated debris waste streams will also have a significant.
: impact, on the available treatment capacity for debris contaminated with the Newly Listed
wastes since all debris is subject to the treatment standards established in this rule.
These factors compelled the Agency to reexamine previous capacity analyses for
hazardous debris. Hence, today's capacity analysis encompasses all debris requiring
treatment capacity, not just the debris contaminated with the Newly Listed wastes.
In this rule, EPA has revised the definition of debris. Debris is now defined as
solid-material exceeding 60 mm particle size that is (I) a manufactured object; (2) plant
or animal matter; or (3) natural geological material. Excluded from the definition of
debris is any material for which a specific treatment standard has been set (e.g., lead-acid
batteries) and process residuals and residues from the treatment of hazardous wastes
(e.g., smelter slag). Under the proposed rule, solid mnjerial above 9.'5 mm,that net one
of the above criteria was considered debris, as were some process residuals such as slag.
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6-n :
However, EPA does not believe that this.change in definition significantly alters its
estimates of the volume of hazardous debris.
6.3.1 Estimates of Total Hazardous Debris >
Because of the uncertainties.associated with the nvail:ihle data, the Agency* -
developed estimates of hazardous debris usjng two methods that validate each other. For
Method ^1. adjustment factors were derived by comparing TSDR Survey data on
hazardous debris for specific facilities with more recent data submitted in response to the
Proposed Rule and the ANPRM, or.in the roundtable discussions for the same facilities.
The adjustment factors were'applied to the total quantity of hazardous debris reported in
the TSDR Survey to estimate a range for the quantity of land-disposed hazardous debris.
In Method 2, the Agency used the hazardous debris quantity as a percentage'of the total
hazardous waste quantity land disposed to estimate the total volume of land-disposed
hazardous debris. . ' '.'
The volume of land-disposed hazardous debris that may require treatment is
estimated to( range from 700,'OOQ to 2.S million tons per year using Method 1.. .Using
Method 2, the estimated quantity of hazardous debris thai may require treatment is
approximately 1 million tons per year. The methods described above are discussed in
greater detail in'the following sections. . - ,
\ < ,.
. 63.1.1 Method 1: Approach and Results ' ' ,
i , -
Method 1 updates the hazardous debris quantity estimate from the TSDR Survey
with data submitted in roundtable meetings and in response to the Proposed, Rule and
the ANPRM. As noted earlier, the TSDR Survey data on hazardous debris is limited.
Because the survey was conducted in 1987, it'does not include most of the Newly Listed
wastes covered in today's proposal. The survey requested data according to .waste code
and did not distinguish debris and soil from industrial waste streams.
Using descriptive information on the waste streams for which quantity information
was submitted, EPA, however, was able to apportion quantities to the debris category.
For waste codes describing waste streams that contain soii and debris, the Agency
assumed that debris comprise 10 percent of these waste streams. This assumption is
based on information 'provided in the roundtable discussions on the approximate
proportion of debris in soil arid debris mixtures.2
From the TSDR Capacity Data Set (a database containing TSDR Survey data),
EPA extracted the quantity of hazardous debris reportedly land disposed in 1986 by using-.
* While several companies reported trial debris is about 10 percent of [heir soil and debris mixture, oiher
companies reported a higher proportion. Therefore, this'assumption may underestimate the quantities of
debris generated. , ' ' . . .
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the waste descriptor codes shown in Exhibit 7. Exhibit X provides an example of the
types of data extracted from the TSDR Survey, The tot:il quantity of hazardous debris
reported in the TSDR Survey is approximately 330,00(1 tons. However, .tin's quantity is .
likely to be an underestimate of the actual amount kind disposed due to the potential
misinterpretation of the hazardous debris.definition', the resultant misdassification of the
wastes, and limitations of the TSDR Survey mentioned above/
To' derive total quantity estimates, the Agency compared..the TSDR Survey data to
debris/contaminant.descriptions in the recently submitted data for specific facilities.4
"Exhibits 9 through 12 compare recently submitted data with TSDR Survey data for five
landfill facilities.? The comparisons suggest that, in "most"cases, facilities in the TSDR
Survey may'have under reported'hazardous debris quantities. Exhibit 13 shows that
hazardous debris quantities reported by-facilities that recently submitted data are
approximately two to ten times higher than quantities'reported in the,TSDR Survey,
Adjusting the total hazardous debris quantity of 330,000 tons/year from the TSDR Survey
by factors of two and ten,, results in an estimate of total hazardous debris quantity
ranging from 660,000 tons/year to 3,300,000 tons/year, respectively.
' '
Exhibit 14 summarizes the data provided by facilities that recently submitted '
hazardous debris data, but did not .report debris quantities in the TSDR Survey. Since
these debris waste.stream's were not reported in the TSDR Survey, they .were not
included in the estimated total debris quantity calculated by adjusting the 1986 total
debris'quantity. EPA then added the estimaied debris quantity at these facilities to the
range estimated above. Thus, the estimated total debris quantity land disposed that
results from this adjustment ranges from 880,000 tons/year, to 3,500,000 tons/year.
Land disposal facilities that participated in roundtable meetings with EPA ,
indicated that approximately 80 percent of the hazardous debris they receive is under a
national capacity variance and has not been treated prior to land disposal. Thus, the
total debris quantity that may require alternative treatment is estimated to range from
700,000 tons/year to 2.8 million tons/year. :
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hazardous debris as the listed waste iisctf.
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J Income cases, engineering judgement was use4 to match WBMC descriptor codes with hazardous debris'
descriptions in the submitted data. ' '
5 To maintain confidentiality, facilities that did noi formally Mjhniit daia to EPA in response to the
ANPRM are identified using letters (e.g.. Landfill A). '
-------
6- 19'
, - EXHIBITS
"CHEMICAL -WASTE MANAGEMENT (EMELLE, AL)
.The exhibit below, based on data from the TSDR Survey, presents.the types'of
hazardous debris landfilled in a commercial landfill.
Debris Descriptor
Code
BEM
BIT
BJS '. 1
B45 and BIM
B43
" B42
A06^
B44
BJD
B39 ,
A08
BXB
BJC
BIQ and SIR
BJW
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B85
AEA
' BXJ
. BIU
Debris Description
Lead contaminated floor debris ' ",
Other debris
Contaminated trash
Spent solid filters or adsorbents
Empty or crushed metal drums or containers
Metal scale, filings, or scrap
Contaminated-soil or cleanup residue
Batteries,, battery pans, casing, cores
. . Arsenic contaminated waste solids
Other "dry" ash', slag, or thermal residue
Concentrated off-spec or discarded product
Lab cleanup material -
Grit blasting residues, metal dust
Acid or caustic spill cleanup waste
Paint pigment solids
Lab pack of debris
Empty fiber or plastic containers.
. Other untreated wastes .
Paper paint filters with heavy metals
Used mercury lamps
Quantity
(tons/yr).
85,909
13,644
4,110
3,849
3,326
1,843
1,097 ' ,
724
656
314 '
,"' 254
^79
->153 '
112
' 97 '
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6-24
'
SUMMARY OF COMPARISON
EXHIBIT !3
BETWEEN RECENTLY SUBMITTED DATA
AND TSDR SURVEY DATA .
1
'
.
Facility Name
TSDR
Survey
Debris
Volume
(tons/yr)
Debris Volume
from Recently
Submitted Data
(tons/yr)
Change in Debris
Volume from TSDR
Survey Data to
Recently Submitted
Data (multiple)
- Commercial Landfills .
Landfill A
. Landfill B
I ,
Landfill C
24,828
1,004 '
853
19,800
2,301
9,170-
0.8^
2.3
10.8
, Company-Captive Landfill
Union Carbide
Dupont .
119
45
195 to 1,048
6,531 .
1.6 to 8.8
145^
y This quantity contains 23,532 tons of ashes and slags. The large amount of ashes and
slags may be a one-time disposal quantity from remediation activities. By eliminating the
ashes and slags quantity from both the TSDR Survey data and the recently submitted data.
the quantity of debris in the recently submitted data is larger than the TSDR Survey data
by a factor of 12.5.
^ Because the data submitted comprised only building,' demolition, or clean-up debris, the
Dupont data were not
used in estimating the total volume
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' 63.1.2 Method 2: Approach and Results ' .
In Method 2, the Agency calculated the total quantity of debris land disposed at ,
commercial facilities in .three steps: ,
, * } ' . ,. *
Step 1: The Agency used- the total debris quantities provided by"commercial
landfills that submitted data directly to'the Agency and calculated the percentage
of hazardous debris as a proportion of total waste receipts in 1990 for these
facilities. . . ',
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6-25'
EXHIBIT 14
SUMMARY OF FACILITIES THAT RECENTLY SUBMITTED DATA
BUT DO 'NOT REPORT DEBRIS IN THE TSDR SURVEY "
i
ii
. . Facility Name " _ Facility Type
CWM (Model City, NY) Commercial Landfill
Landfill B Companv-Captive
' . Landfill -
Olin Company-Captive
Landfill
Chempro Waste Tre ate r
CyanoKEM ' ' Waste Treater
TOTAL DEBRIS QUANTITY
' Quantity in the recent data submission is for February
i the exhibit has been adjusted to a period of one year
Quantity (ton s/yr)
: ' 200,000^
' 12,500
. ' 756
340.' '
4.0S017 ' .
218,000
to May 1991. The quantity ..
using linear extrapolation.
=/ -Quantity'in the recent 'data submission is for one month (May to June, 1991).
The quantity, in the exhibit has been adjusted to a period of one year using linear
extrapolation. .'
Step 2: For facilities that provided an approximate percentage of their total waste
receipts that can be classified as hazardous debris, this percentage was multiplied
by the total quantity of waste landfilled at the facility in "1990 to estimate the total
hazardous debris quantity.
Step 3: A weighted average percentage of hazardous debris as a proportion of
total wastes was calculated based on the results of Steps 1 and 2. This
percentage was then applied to the total quantity of waste received by facilities
that did not provide any data to EPA. -
Exhibit 15 shows hazardous debris as a percentage of total waste quantity disposed
at facilities that recently, submitted data to EPA. Between 9 and 63 percent of the'total
wastes land disposed at these landfills is classified as hazardous debris. This range is
between 15Jto 50 percent for the company captive landfills that submitted data.
Exhibit 16 shows how EPA calculated the total quantity of land-disposed
hazardous debris that may require alternative treatment. As with Method ,1, EPA
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6-26
. . EXHIBIT 15
ILAZARDOUS DEBRIS AS
PERCENTAGE OF TOTAL WASTE VOLUME
AT SELECTED LANDFILLS
,
Facility Name
Debris
Volume
(tons/yr)
Total
Volnme
(tons/yr)
Debris as
Percentage of
Total
., Commercial Landfills
CWM (Emejle, AL)'
'CWM (Mode! City, NY) .
Landfill A'
116,000
. 2QQ,QQ<&
20,000
290,000^
375,000!'
156,000^
40
.. -53
13
Company-Captive Landfills
Union Carbide
Dupqnt
Landfill D .
200 to 1,050
6,500
11500 '.
400 to 2;050
120,000
73,000
' 50 ',
. .5 -
17
Waste Treaters
Ghempro .
. CyanoKEM
340
340
Debris volumes from information submitted in
14,000 -
173,000 -
1 2 - .
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' .
roundtable meetings and in respo
,
nse
to the ANPRM, except as otherwise mentioned in a footnote.
y Smith, J., "Hazardous Waste
1992. '
2/ First quarter 1991 hazardous
Landfills Facility Information", £. /. Digest, February
debris quantity
from response to the ANPRM. The
quantity in1 the exhibit has been adjusted to one year.
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assumed that SO percent of the hazardous debris received at commercial facilities is
under a national capacity variance and has'not been treated. As Exhibit 16 shows',
approximately 940.000. tons of hazardous .debris requiring treatment were land-disposed
in 1990 at commercial facilities. By adding the quantities of hazardous debris reported
by a few company captive facilities. EPA estimates that the total quantity of hazardous'
debris requiring treatment is approximately 1 million tons. This quantity may he an
underestimate because it does not account for ail company captive facilities, and because
.a large number of demolition/construction and ,'emedial actions could generate large .
volumes of hazardous debris in any given year.
The 'total quantity of hazardous debris that may require treatment is estimated to
be between 700.000 tons/year and 2,500,000 tons/year using Method 1, and is estimated
at approximately 1 million tons using Method 2. Variability in the estimatesjesuhs from
extrapolation using hazardous debris data from a very limited number of facilities that
'are different in the quantity (and type) of hazardous debris they land dispose..
. ' " 6J.2 Debris Contaminated with the Newly Listed Wastes
j ' .i
Of the'total quantity of hazardous debris that will require off-site commercial
treatment, EPA estimated in the proposed rule that approximately 10,000 tons were
contaminated with wastes covered in this rule. Debris contaminated with F037 and F03S '
petroleum refining wastes were estimated'to be generated at a rate of 8,000 tons per
year and were the most prevalent of these Newly Listed wastes. This estimate was based
on the assumption that debris contaminated with F037 and F038 petroleum refinery
.wastes have.similar characteristics and are generated in similar quantities to debris ' .
contaminated with K048-K052 petroleum refinery wastes. In the TSDR Survey, 40,000
tons of soil and debris contaminated with K048-K052 petroleum refinery wastes were
reported. The Agency assumed that 20 percent of these mixtures would be debris. Thus,
EPA's estimate for debris contaminated with F037 and F038 wastes was 8,000 tons per
year (.20 * 40,000). ( - .. .
' . .< ' ' .
EPA's estimate in the proposed rule for debris contaminated with the.remainder
of the wastes covered in this rule was less than 2,000 tons per year. Because these
wastes were listed recently, EPA did not receive primary data on'the quantities of debris
contaminated with the Newly Listed wastes covered in this rule other than F037 and
F038. EPA derived its estimates of the debris contaminated with the Newly Listed
wastes covered in this rule based on the relative proportion of the Newly Listed wastes, to
total.wastes, and best professional judgement; EPA identified 15 facilities generating
these wastes (see Document 1). EPA estimated that each of these facilities would
typically generate less than 100 tons of hazardous debris. Therefore, EPA estimated that
fewer than 2,000 tons of debris contaminated with these wastes would require '
commercial treatment. - . .
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Several cnrr.menters to the proposed rule felt that EPA had significantly
underestimated the quantity of debris contaminated by Newiy Listed wastes covered in
this rule. Therefore, EPA solicited experts' estimation of quantities of debris
contaminated with Newly Listed »vastes.6 EPA reviewed the information that was
already available and then focused on large debris contributors. EPA obtained several
experts' estimates for the largest-volume waste types! and focused on debris
contaminated with four categories of wastes: F037 and F03S wastes; U359 wastes, Kill
and K112 wastes; and K118, K131, and K332 wastes. EPA focused on these wastes
" groups alone because the volumes of the Newly Listed wastes covered in this rule that1
were excluded were expected to be so small that their contribution' to the total would
have, been insignificant and indistinguishable from the'uncertainty, in estimates associated
with the larger-volume wastes. EPA developed an interview protocol and conducted
structured interviews with the identified .experts. For each set. of estimates, the experts ,
were asked to consider uncertainties that could cause the levels to be significantly higher
or lower than their estimates- The information gathered from the interviews was. then
used as input for a probabilistic model .
Using the information gathered'from the experts, EPA estimates that the_ quantity
of hazardous debris contaminated with Newly Listed wastes covered in this rule ranges
from'18,000 tons per year to 120,000 tons per year, with a median of 33,000 tons per
year/ The estimated quantity, of hazardous debris contaminated with Newly Listed wastes
consists of two basic categories of debris: (1) debris contaminated with F037 and F038,
and (2) debris contaminated with the remainder of the wastes covered inuhis rule. EPA'
estimates that the quantity of debris contaminated with F037 and F038 ranges from
13,000 to 24,000 tons per year, with a median volume of 17,000 tons per year. The
estimated quantity of debris contaminated with the remainder of the wastes covered in
this rule ranges from 3,000 .tons to 98,000 tons with a median of 13,000 tons per year..
6.4 AVAILABLE CAPACITY FOR MANAGING HAZARDOUS DEBRIS
As noted earlier, EPA is establishing a number of technologies as -BOAT for
hazardous debris, but leaving the choice of technology up to the generator and or treater
of the debris/7 The treatment methods include extraction, destruction, and
immobilization technologies! The Agency expects a shortfall in available treatment
capacity for hazardous debris in all families of debris treatment. The time 'required to
.engineer, build, and permit new technologies is like to constrainahe availability of many '
,6For a full discussion of EPA' approach 10 updating the estimated quantity of debris contaminated with
the Newly Listed wastes, please refer to Cost and Economic impact Analysis of Land Disposal Restrictions
for Newly Listed SVastes and Hazardous Debris. '...''
'Under this rule, EPA also allows.generators and/or ireaters the alternative of treating hazardous debris
to the existing waste-specific ircaimem'standards, as long as the gcneraior briii/or treater can comply With
those standards (i.e., can perform the necessary "sampling and analysis required to demonstrate compliance).
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of these technologies. Material-handling problems are also expected to limit the
available destruction and immobilization capacity.
6,4.1 Current Treatment of Debris '
i
Under the Third Third LDR standards, hazardous debris must be treated to meet
BOAT standards for the waste or ^wastes with which it is contaminated. According to
hazardous waste management industry sources, most hazardous debris was being land
'disposed without treatment under a national capacity variance until May 8, 1992.
Because of the regulatory action taken by EPA to gran! a generic one-year case-by-case
extension to facilities managing hazardous debris (57 FR 20766), this practice is expected
to continue in the near term. Of the debris that is currently being treated, a variety of
technologies are being used, including stabilization, incineration, acid washing, and metals
extraction.' However, some of these treatment technologies are not available'
commercially as permitted RCRA treatment.
6.4.2 Materials Handling Problems
Current treatment of debris is limited by the characteristics of the -debris itself.
For example, many types of debris cannot be directly stabilized because of their particle
size, and require shredding or grinding prior to stabilization. The ability to incinerate
debris is also limited because some incinerators may hot be able to handle debris,'
- depending on .the type of debris, the size od the debris, and the incinerator feed .system..
In most cases, large-sized debris need some form of preireatment (e.g.; shredding or
sizing) prior to incineration. This could require large and specialized equipment.
6.43 Available Treatment Capacity
EPA used the data sources described in previous sections to assign quantities of " .
hazardous debris to specific treatability groups. Exhibit 17 shows the quantities of debris
by debris type and contaminant types. The data used for this table are based on
voluntary data submissions from: Chemical Waste Management (Emelle, AL and- Model.
City, NY), Union Carbide, Dupont, Laidlaw Environmental, Envirosafe Services of Ohio,"
Chempro, CyanoKEM, U.S. Ecology, and Ashland Chemical. .
EPA used the following methodology to assign debris and contaminant types:
. Step 1: All wastes with known debris type and contaminant type were fitted
into the table. " . '
, Step 2: All wastes of known debris type but' unknown contaminant were
. divided among the six predominant contaminant types.
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Step 3: Debris of unknown type ;md unknown cnniaminant were divided
proportionally among the types of debris (based on the proportions of
known debris type) and equally among '.he contaminant-types.
The table shows that the predominant types of detiris are .brick, concrete, rock
and pavement (approximately rwo-thirds of the to(al), which is consistent with'the finding
'that the'biggest source'of hazardous debris is through demolition and construction ,
activities'. Most reported debris (approximately 80%) were contaminated with metals
(both non-volatile and volatile). However,,this finding may be influenced by the-fact that
debris volumes analyzed forthis analysis were generated in 1990 or earlier, and do.not
reflect the effect of the organic TC rtile. .
Participants in the three roundtables on .hazardous debris and commenters to the .
Proposed Rule and ANPRM state that many of the debris treatment optionosuch as
vitrification and macroencapsuiation are not currently available in significant quantities.
EPA also recognizes that facilities will require some time to design, test, and install
engineered treatment technologies and pre-treatment systems. .Exhibit IS presents
EPA's estimate-of the commercially available capacity for the various extraction
destruction, and immobilization technologies. .
. For debris contaminated with the Newly Listed wastes, the large quantities of
debris contaminated with previously listed wastes ihat_ will require off-site commercial
treatment after the one-year extension expires in May 1993 will compound the lack of .
available capacity due to the problems described above. Hence, to minimize the
disruption of the available treatment capacity for debris contaminated with previously
listed wastes, EPA is granting a two-year national capacity variance for debris
^contaminated with the Newly Listed wastes covered in this rule. This variance will allow
sufficient time for the installation and permitting of the treatment systems necessary to.
handle the quantities of hazardous debris affected by this rule.
Capacity Analysis ^ "
Exhibit 19 presents, the assignment-of hazardous debris quantities to applicable
treatment technologies. Because this rule provides several management options for
different categories of hazardous, debris, precise assignments of debris quantities to each
technology could not be made. EPA assigned quantities of hazardous debris to treatment
technoiogies in two ways: , ''''.
' t *
(1) EPA apportioned the quantities of debris of a specific debris type and
contaminant type to all applicable treatment technologies equally (e.g., if
there are five applicable technologies for a specific combination of-debris
type and contaminant type, one-fifth of the total quantity was assigned to
each technology).
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(2) EPA estimated the quantities of hazardous debris that could he assigned to
' each specific technology under n "worst case" scenario (i.e., by assigning to
each technology all.the hazardous debris quantities that could possibly go
to that technology). ' . . ." .
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The assignment of hazardous debris-quantities to specific technologies can be used
to draw general conclusions about trends and patterns that may occur in the treatment of
..hazardous debris given the new debris treatment "standards. The following observations
can be made from the exhibit: ' . /'
The wide range of possible debris quantities'requiring treatment capacity
for each technology reflect the uncertainties associated1 with the assignment
. of debris quantities to technologies given trie number of debris
management options. ' . .
* Large quantities of hazardous debris may.-need to be treated using
extraction technologies (especially water washing, acid washing, abrasive
, ' blasting, and vibratory finishing), and immobilization technologies
. (macroencapsulationi microencapsulation, and sealing).-
Approximately 200,000 tons of hazardous debris may require thermal
treatment'(if all debris for which thermal treatment is possible used this
. .. technology). This quantity is likely to be underestimated because the-data
used in this analysis do not reflect, for the most part, hazardous,debris
contaminated with'the newly identified organic TC wastes.
'The results of this analysis are subject to several important caveats: (1) the
analysis does not reflect the possible combinations of technologies that may be used in
conjunction with each other; (2) the analysis is based on partial data and extrapolation
and reflects all of the data uncertainties discussed in previous sections; (3) because of the
'lack of precision in much of the data available to EPA, the assignment of hazardous
debris quantities to treatment technologies is based largely, on data extrapolation and
professional judgement; and (4) the estimates provided in this exhibit differ from the
Regulatory Impact Analysis (RIA) estimates because they were derived .using different
methodologies. ' .
This analysis is useful iri indicating trends about the potentially required capacity
for treatment technologies for hazardous debris that can be used by both the regulated
1 community and EPA in planning for the future management of hazardous debris.
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EXFHBIT 18
.
REQUIRED AND AVAILABLE CAPACITY
FOR DEBRIS TREATMENT TECHNOLOGIES
- _
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Treatment Technology
Available Capacity
(tons) ' '
Extraction Technologies
Abrasive Blasting
Scarificaiion, Grinding, and Planing
Spalling
Vibratory Finishing
High Pressure Stem and Water Sprays
Water Washing and Spraying
Solvent Extraction
High Temperature Metals Recovery
Thermal Desorplion
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Destruction Technologies
Biological Destruction
Chemical Oxidation
Chemical Reduction
Thermal' Destruction i
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46.000
171,000^
' Immobilization Technologies
Macroencapsulaiion
Mtcroencapsulation - .
^Sealing
Nonel'
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Nonei'
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Note: Agitable capacity numbers based on TSDR daia, data received in response to LDR notices,
' and voluntary data submissions. . . '
-' Technology is not commercially available.
y Materials handling and preprocessing requirements may limit capacity. ' .
-' Cement kiln and incineration capacity for bulk solids, dry 'solids', and containerized solids.
Materials handling and preprocessing requirements may limit capacity. . . .
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CHAPTER 7
K061, K062, AND F006 WASTES
7.1 BACKGROUND
This rule removes the low and high zinc subcategories for K061 and establishes
the same numeric treatment standards based on High Temperature Metals Recovery
(HTMR) for all K06I nomvastewaters. 'This rule does not preclude the use of any
' treatment technology'that can meet.the numeric treatment standards for K061, K062,
and F006.' Since the treatment standards established in this rule for K062 and FQQ6 are
alternative treatment standards, any technology the can meet the previously promulgated
treatment standards for K062 and F006 may continue to be used to treat these wastes.-
In conducting the capacity analysis for K061 wastes, EPA has estimated the "
volume of K061 that must be treated and has determined that there is sufficient.available
treatment capacity for these wastes." . ', .
1 ,.
. _ EPA believes that there-is currently sufficient treatment capacity to treat K062
and F006 wastes under the previously promulgated standards. The Agency has not
received'information from generators of these wastes that treatment capacity is not,
available. EPA did not conduct a formal capacity analysis for K062 and F006, since the
alternative standards promulgated by this rule can only increase the available treatment
capacity. . ' ' '
7.2 K061 WASTE GENERATION, ''.''
In the capacity analysis for the Augusl-19,'1991 (56 FR 41164) final high-zinc '
.K061 rule, the Agency estimated the current generation,of K061 wastes (both high-zinc'
and low-zinc wastes). The-Agency used data-form'the TSDR survey to/estimate that
approximately 86,000 tons of low-zinc K061 would require LDR treatment: Two other
sources provided information on the generation of K061 wastes. The Horsehead
Resource Development Company (HRD) estimated that 50,000 to 100,000 tons of low- :
zinc K061 wastes were generated each year.' The American Iron and Steel Institute
estimated that 67,000 tons of low-zinc K061 is generated annually. Since there is a
discrepancy in the estimates of the volume of low-rinc K061 generated, for the purposes
of this capacity analysis, the highest figure (100,000 tons) was used to estimate the
volume of low-zinc K061 requiring treatment. .
o
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- 'Although ihs stibcategories of high-zinc and low-zinc K061 have been removed, for the sake of clarity
we will refer to the additional volume of K061 wastes now subject to the numeric treatment standards .
based on HTNiR as low-zinc K061 wastes. " -
-------
73' , AVAILABLE TREATMENT CAPACITY FOR K06I WASTES
.EPA conducted an analysis of HTMR capacity for the August 19, 1991 (56 FR
. 41164) final rule for high-zinc K061. This analysis concluded that 573.000 tons of HTMR
capacity was available as of August 1991, The analysis iilso concluded that up to 415,000
tons of high-zinc K061 could require HTMR. Therefore, based on data available to
EPA. almost 160.000 tons of excess HTMR capacity was available in August 1991. -
In response to the,proposed rule, Conversion Systems, Inc. (CS) submitted a
comment and data indicating that,its stabilization process can achieve the treatment
standards for K061 wastes. CS also states that they currently treat over 100,000 tons of
K061 wastes and that their stabilization capacity is currently unlimited.. In the capacity
analysis.for the August 19,J991 (56 FR 41164) final high-zinc K06I rule, EPA identified
another company, Michigan Disposal, that claims its stabilization process can meet the
K061 treatment standards. .
EPA notes that other technologies such as extractive metallurgy processes,may
also be able to meet the treatment standards. One commenter to the proposed rule,,
Recontek, claims that it can process F006 or K061 wastes in its hydrometallurigical
process. Recontek has over 240,000 tons of permitted capacity.
7.4 CAPACITY IMPLICATIONS
' EPA has determined that sufficient HTMR capacity exists to treat the additional
K061 wastes subject to the numeric treatment standards based.on HTMR. The highest
estimate of low-zinc generation is 100,000 tons. There arc 160,000 tons of HTMR
capacity available. The Agency also notes that'K06I generators are in-no way required
to use HTMR to treat their waste. Therefore, if there were to be a shortage of HTMR
capacity, K061 waste could be'-treated by another technology such as stabilization which is
widely available. ' v .
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> ,.'- APPENDIX A: ORGANIC WASTE PHONE LOG
Contact: , Morgan French
Company: Olin Chemical Corp., Lake Charles. LA
Phone: ," ,318-491-3107
Date: June 20, 1991
Callers: Gary Light and Frances Steinacker.
i''
Subject: OXL,Capacity Analysis
Report of Discussion: , ' . ."
Olin Lake Charles currently generates several forms of Kill:
FORM: .
Wastewaters
Spent Carbon
from WWT
Methanol Column
Sidedraw
Incineraior Scrubber 1
Slowdown (estimated)
Spent Carbon- from
Incinerator Slowdown Treatment
Soil and Debris
1989 Clb)
125,748,300 '
327,430
4,294,680
,050,840,000
.. 40,000
0
. 1990 fib)
.153,332,340
- . -300,340
. 5,364,180
/ ' 1,050,840,000
^40,000
63,660
Olin Lake Charles does not currently generate:
U328, U353: Does not produce o or p-toluidine.
K107-K110: Uses'different process-in UDMH production.
Kill: ' Does not make DNT.
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MANAGEMENT
Wastewater is treated in standard Calgon Carbon beds and discharged under NPDES.
Spent carbon from ,WWT is returned to Calgon Carbon for regeneration (in '
Catlettsburg, KY or Pittsburgh, PA). .
The sidedraw from the methanol still column is considered a nonwastewater (whose
primary hazardous'constituent is methanol). All sidedraw was incinerated on site in 1990. .
In 1989, a small amount (71,870 ib, or 1.67%) was incinerated offsite. The Olin Lake
Charles TDI residue incinerator receives several million pounds of TDI residue, plus the
K112,(liquid injection; can't handle solids). .
Incinerator'scrubber water blowdown coming in cpntact-(mixed) with Kl 12 streams
is treated in standard Calgon Carbon beds, then discharged under NPDES. (The generation
volume above is based on an estimated 250 gpm; the actual flow rate is not measured).
Practically no orgamcs are in the input.stream to the carbon beds.
Spent carbon from incinerator blowdown treatment is believed to be incinerated
offsite (the carbon being replaced no more than once a year). Calgon does not want the f
carbon back if it is contaminated with a lot of solids, and .there are no sand filters in front
. of the carbon,beds (so that they trap a significant amount of solids). , . '
Soil and debris was probably -landfilled. ' ' v
OTHER ISSUES DISCUSSED/COMMENTS:
Olin expressed concern over the consideration of setting the BDATstandard for Kl 12
as a method:. chemical 'oxidation followed by carbon adsorption. Tremendous treatment
capacity would be required. Olin claims to get good results with carbon adsorption alone..
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Contact: Don Liermart ,. ' .-
Company: BASF, Ureihanes. Geismar, LA ' .
" Phone: (504) 339-2529 .
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Date: May-21, 1991. ' . . '
Calier: Frances C. Steinacker, '
Subject: ONL Capacity Analysis
Report of Discussion: . . ' . ,
, J The plant currently generates Kl 12, no Kill. The Kl IZ'is'much cleaner than the
listing "typical stream description", ("mostly distilled water"), with TDA, the main
contaminant, in the ppb range. The Wastewater Permit water balance gave the maximum
permitted values for this stream as 40,000.gallons/day.
MANAGEMENT:' ' -- . ' -- ' '
K112 is currently carbon treated (Calgon), and the facility has installed a separate
'-- distillation tower for the water. ', ' .
.1
In the future, a new above-ground biological treatment plant will be built to treat the
K112, replacing the current bio-plant, which is only, permitted for TC (in accordance with-
regulations to be effective March 1994, requiring above-ground treatment tanks).
The carbon, is sent-back to Calgon for regeneration, to Neville Island facility in
Pittsburgh, PA or.to Catlettsburg, KY. Lierrnan has visited the facilities himself. . -
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Contact: Richard'.Vfercenhagen in TDI plant
Company: Dow Chemical, Freepor;, TX . ..."."
Phone: (409)238-0000,
Date: ' May 2), 1991 . ' \ . ,' '"
Caller: Frances C. Steinacker . ' ' >
Subject: . ONL Capacity Analysis .
Report of Discussion: . . , " "
The plant does riot generate Kill or KI12. TDA is purchased from Air Products
and the products do not enter into the wastewaters.
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Contact: Jim Myers ' ' , ' -I *'
Company: Bayer (Mobay), New Martinsville, \VV
;
Phone: ' ,(304) 455-4400 ' ' ' . / '
Date: July 2, 1991 ".' ,
Caller: Frances C. Steinacker
Subject: ONL Capacity Analysis . '
Report of Discussion:
Kill and K112: The company generates 400,000 tons total svastewaters, which is
incinerated on-site. Very little ash is generated from these 2 wastes.
The residual ash from incineration go to a hazardous landfill.
The KI11-K112 is at most 0.1% ash, so the residua! is only about 5-10 Ibs, out of the 2.7
million Ibs total (in 1990) from incineration at the facility. Most "of the ash is from
' wastewater treatment .sludge. ' - /
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Mentioned K027 (distillate bottoms from manufacture of TDI) - 10 million Ibs.
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Contact: Phi! Shews . '
Company:.' Bayer .(Mobay), New Mnrttnsvflic, WV ' -
Phone: ' (304)455-4400 .
'Date: My 2, 1991 '..''
Calier: . Frances C. Steinacker v ' ,
Subject: ' ONL Capacity Analysis . . .--"
Report of Discussion: .
Combined waste streams: . . .-
Process about 5,327,000 tons annually total WW (of which Kill and K112 make up'about
' ' '
Incinerate in a flutdized bed-'incinerator (ONSITE) about. 16,000 .tons mixed WWT clarifier
sludge, biosludge (a small stream), waste liquids from plant, and solid wastes annually.
The highest ash content in the WWT stream would be about 1%. The highest-ash content
of the WW treatment sludge would be about 7%.
Permit limits: 9,600 pounds/day of ash. This ash is shipped offsite for landfilling and is most
likely not stabilized. It is considered nonhazardous except for its nickel content. The
; company has considered delisting, but doesn't think it's worth it.. Probably Rollins or TSX
is the offsite recipient.- ,. .
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Contact: .Joe Perrigi ' . .
Company: Bayer (Mobay), Baytown, TX . v . .,.
Phone: ' (713)383-2411 ' '. ' .
Date: .July 2, 1991 / .
Caller: Frances C. Steinacker
Subject: s- ONL Capacity Analysis
Report of Discussion: . ...
Should talk to Harry Heiiein tomorrow (ext. 4S05). "
Joe Perrigi says they might generate Kill and K112; they do have DNT and TDA units.
The.wastewaters are treated with bacteria and aeration, and discharged through NPDES
permits. All,s!udges go to incineration (offsite?)
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.Contact: Harry I tcinlcin (xvill he -out until July 11)
Company: Bayer (Nlubay). Haytown. TX ' ^.
Phone: (713) 3.H3-2-I11 c.xt 4H(ii
Date: July«,. |W! .-".'
Caller: ' Frances C. Stcinackcr . ' . .
' '' ' S'
Subject: ONL Capacity Analysis
Report of Discussion:
GENERATION: '
All information should be in the sun'ey sent to OSVV'Information Management (Lisa Jones).
If not complete, call back. .
MANAGEMENT: ' '
Kill: DNT is extracted using toluene and returned to the unit. The water containing
residual DNT goes to above-ground biotreatrnent, carbon absorption after primary
clarification, prior to discharge under CPSF guidelines. ...
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Biosludgc is treated in a filter press to about 50% water (a quasi-solid cake is produced),
'then incinerated'offsite, as part of a mixed,stream. Ash goes to land treatment. The ash
is primarily from the inorganic lime used for enhancement of filter press operation...
Total biosludge 365-700 tons/year. This contains primarily silt and sand from the clarifier,
along with.the minor volume of biosludge. '
Carbon is regenerated onsite in a BIF unit.
OTHER: ' r . ' .
Very concerned about BOAT being set up in the wrong way. Feel their method is very"
successful in cleaning up problems. .
Will fax copy of 3007 response.
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Contact: Mary Ann Smith ,
Company: Rubicon Chemical, Baton Rouge, LA ' ' . -
Phone: (504) 383-7771
* ' i
Date: July 2, 1991 ' ' ...
.Caller:' Frances CSteinacker ' ,
Purpose: '.ONL Capacity Analysis'
Report of Discussion: ,
GENERATION:
The facility generates Kill and K112 (see MANAGEMENT). The facility injects roughly
46 tons/year of-Klll and 44 tons/year of K112 within a.combined wastewater stream.
Treating Kill and K112 generates 86 pounds/year of nonwastewater residuals from each
waste stream. These residuals currently are sent off site for incineration.
MANAGEMENT: ''' ' ,
Residuals are incinerated off site, usually by Rollins. Kill and K112 wastewaters
undergo pretreatment, which includes neutralization and filtration. The pretreated Kill and
K112 wastewaters (with a combined wastewater stream of unknown volume) are deep-weir,.
.disposed on site. The facility currently has a no-migration petition for this operation.
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Contact: Bill Hampton . , .
Company: Carbolafas, Bethany, CT '
Phone: (203) 393-3029 , ',''
Date: - July 2, 1991 . - , ' ' '
Caller: . Frances C. Steinacker - - . .
Subject: ONL Capacity Analysis
\'
Report of Discussion: ' ' ' . .
GENERATION: , ' :
Carbolabs purchases TDA from AJdrich Chemical rather than making it themselves.
Everything they sell is for laboratories (therefore small amounts).
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Contact: John Knatts
Al Pogamo (609-540-4106) is on vacation until 7/10
. Company: .} Du Pont, Deepwater, NJ
Phone: . (609) 540-2938 ' .' . .
Date:.' July 2, 1991
Caller: Frances C. Steinacker
Sub'ject: ONL Capacity Analysis . ' '
Report of Discussion: . -
GENERATION:
John Knatts is not very familiar \vith'KHl-Kll2, but tried to assist. He only located a
remediation report of a ditch system from the process, where a waste stream with 8 or so
codes, including Kl 11 (but not Kl 12) were grouped together. In 1989 this total volume was
800,018 Ib. In 1990, zero was recorded, but 428,000 Ib was shipped offsite, presumably from
the previous year's 800,018 Ib total. .
i '
MANAGEMENT:
The facility has its own \VWTP (using biotreatment and aeration) and Subtitle C landfiU'fdr
residual sludges (i.e., no wastewater or residual is being shipped offsite).
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APPENDIX B
Hazardous Debris
Issues and Concerns
The Capacity Programs Branch of the Waste Management Di'.'ision of EPA held
three roundtables on hazardous debris on May 14, June 18, and June 27, 1991.' During
the roundtables, the participants shared their practical experience with the management
of debris and provided an understanding of the critical capacity issues related to the land
disposal restrictions for hazardous debris. EPA held the roundtables to gather
information on the current management practices for hazardous deuris. In order to get
a, complete picture of the management of debris, each roundtable concentrated on a
different group of facilities that manage hazardous debris: participants in Roundtable One
represented commercial landfills; participants in Roundtaple'Two represented hazardous
waste generators with on-site landfills; and participants in the Roundtable Three
represented hazardous waste.brokers and treatment facilities.
The quotes used here illustrate in the participants' own. words their views.and
opinions on hazardous debris.- We have taken these concerns and comments into
consideration in the capacity analysis for hazardous debris. All quote's are,in plain text;
, notes by the Agency are in italics., .
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Roundtable One Commercial Hazardous Waste Landfills
Roundtable Two Hazardous Waste Generators with On-SHe Landfills
Roundtable Three Commercial Hazardous- Waste Brokers and Treafers
-Although these quotes relate issues raised in the roundtable meetings, they are also
reflective of the issues and concerns raised in the ANPRM in connection with hazardous
debris. The term "contaminated debris" is often used by the particpants instead of the term
"hazardous debris." . ' . . . '
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I. The Problem of Hazardous debris
during the three round'ables, the participants discussed whether hazardous debris
was a major problem. Alt the participants agreed that the answer was "yes". The
participants in all three roundtabtes indicated that, to them, hazardous debris posed different
challenges than did usual industrial hazardous waste streams. The quotes belovs explain
some of the reasons why hazardous debris can bs a major problem. :
. Debris is a scary topic...Debris is a frightening subject because it's so open to interpretation that
you're subject to enforcement actions at any time. - Roundtabte 1 Participant
[In classifying hazardous debris] you go conservative...It's a fear factor. . . .
- Roundtable 3 Participant ' v .
When I used the word'paranoia...I wasn't .kidding abou! that, > We will err on the side of
conservatism rather than take [hazardous debris] material. One load is not worth your perm.it.
One 'customer is not worth your permit. -.Roundtabie 1 Participant
How are you gofng to sample the material anyway? ... Duct work, for example, that is potentially
contaminated with chrome, duct work is that thick, you know. How dp I draw my sample? Do
I get a wipe,sample? Is trial valid?...So you go conservative. Say yeah, I've got a TC problem.
- Roundtable 3 Participant
It's difficult to really pin down [what is RCRA hazardous debris] because if people are going to
go the conservative route, then a Tivex suit when someone walks by a lead-contaminated filter
then becomes a contaminated material...that's RCRA hazardous. Would-we do an actual TCLP
on it? No. - Roundtable 3 Participant
* * /
I think there's a perception by the people who have to sign on the line when they're sending stuff
out for disposal that they'd rather hot'make a mistake because they'll get in trouble. So they'll
go the most rigorous way, because that makes their life easier...You know, they're not going to
make the fine distinction if it saves them, trouble and it saves them a potential .fine.
- Roundtable 3 Participant '
[// we have a debris contaminated with a listed wasfej...we have a problem,
- Roundtable 3 Participant- .
Sure, (hazardous.debris] is.a big 'problem for us. It's filling up bur landfill.
- Roundtable 2 Participant
\ . ' _ '
The refiners 'and-the whole chemical coast is worried about [having to replace their] sewer
systems [which would then be considered hazardous debris]. I mean, hundreds and hundreds
of miles of piping systems. - Roundtable 3 Participant . .
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The kinds of contamination we have.in [remediation] is everything. Acids, bases, PCBs. mercury.
Thai's one reason people like tp- decontaminate plants, because cf rnc-rcury coniarfiination,
cyanides, phosphorous, carbon disulfide. crganics, pesticides, the v.-hcie gamut...Any given
project can generate a lot of stuff, one-decontamination of a chemical pJant,- a smail one in
Bnode Island, 25,000 tons [of hazardous debris].'- RouncHsble 3 Participant
Ws have a principal smelting facility...and-in the filter line.'we have a bag house [for hazardous
rfusfj...This bag house contains'approximately 600 and some odd bags per chamber. Each bag'
[is contaminated with hazardous waste and] is about i 8 to .20 feet long and 18 inches in diameter
and is basically of dacron fabric. There are eight chambers. We change cut two chambers every '
year. The nature of the fabric material does not lend itself well to.stabilization, even as an'indirect
mode. - Roundtabte 2 Participant .
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. 8-4
Data Concerns for Hazardous debris
In' estimating data on 'volumes and characteristics of hazardous debris, the
participants indicated that they did not keep, data in a form that could easily yield that
information.. The participants added that the Agency was likely to encounter many data and
analytical problems due to the nature of hazardous debris and the lack of a clear definition
. oi hazardous debris. The quotes below describe some of, these data and analytical
problems. '- ' ' .
. -- you know, [trying to get a complete picture from the available data is like] somebody said,
patching up an airplane, with chewing gum, something like that, But here vys're talking about a
significant regulation.,.and we don't eveni know how to ask the questions, so we're kind of at the
end of the finishing line and we didn't know what race was on. - Roundtable 2 Participant
You know, this concept of taking a big universe and trying.to apply some universal patty to it to
fix it [or regulate it] usually doesn't work. - Roundtable 2 Participant '
Evaluating or assessing the availability of capacity is going to be more difficult because now you
are going to have to figure out how this waste is going to be generated over time, when capacity
is going to become available under the current regulatory program, who's going to opt to permit
that capacity...what'disincentives are there going to be for people to permit that capacity, what
incentives ate there going to be. - Roundtable 1 Participant '
it's such an enormous package of unknowns in developing numbers. I dori't know what to give
'you in the way of the numbers. I dbn't'know how to give you a number of what constitutes what
we're going to have to be doing over the next two to five years.'- Roundtable 2 Participant
We can certainly begin to appreciate the corner that EPA is in, in trying to come up with data on
[hazardous debris]. - Roundtable 2 Participant .
A lot of the regulations were considerably different [during the TSDR Survey], so what we're doing
with materials and what we thought we were going to do with materials then versus what we're
' doing now is completely different. I would have thought at the end of doing the survey,
personalty. I would have thrown it in the garbage because.by '87 when the survey was done, the
information was already out of date. - Roundtable 3 Participant , ' '
[Much contaminated] debris is sub-surface. You're going to have a 30 foot lagoon and ail of a '
sudden a trunk appears or steel that was in there, are all sorts of various problems you didn't
know were in there. Or they are literally underground. A lot of debris ends up being debris you
didn't know was buried...You might be looking at the end of a freight car on its nose. So you
have to realize that a lot of that data can't be gotten. - Roundtable 3 Participant '
But I think the problem [EPA is] having is that we ourselves don't even know how to define the-
basis for which the numbers'are to be calculated. - Roundtable 2 Participant
\ know why [EPA] wants to [separate debris out] but why would I want to do it in my records
now? - Roundtable 2 Participant ' '/. . .
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[Hazardous c'ebris volumes are] not measured/eally/at the facilities. Not as accurately as [EPA]
would like. - Roundisble 3 Panic/pant . '
Net really knowing what questions are going to be asked, you don't keep trie daia available the
L way the folks at EPA really need it, and that's part of our problem. But once you get She
questions - I mean we don't have a lot of the data. -- Roundtable 2 Participant
Well, you know, contaminated...debris almost by definition is unlike industrial [hazardous waste
sfrea-Tis] and it's impossible to say what the generation is because it'varies so much...it's almost"
impossible to estimate what [the volume of hazardous debris is] going to be.' i think all you can
do is look at the current rates and say 'there's no reason to think thai next year is going to be
substantially different from this year.' Who knows when Superfund is going to start generating
stuff or Defense? - Roundtable t Participant
I cari give you numbers [on hazardous debris] that would be huge over certain periods of time,
and then we go through nothing. I don't know what the future holds, I don't know if the past has
anything at ail to say about the future. That's your big problem.
- Rour.dtable 2 Participant
Another corollary to this story is if you'generate all this data and the de minimis rule comes out,
the amounts,and numbers you get may be way off. We've got a lot of stuff that is de minimis,
a lot of stuff. - Roundiable 2 Participant - -
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B-6
Ml. Regulatory Issues for Hazardous debris
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During the roundtables, participants pointed out a variety of regulatory issues related
;o hazardous debris. Participants in ail three roundtables noted that it is difficult to define
hazardous debris, particularly because there is no way to sample debris. The psrticipa/its
in :he second and third roundtables (generators with on-site landfills and brokers/treaters)
also discussed the difference-in their minds-bsfa'esn decontamination of debris and
treatment.- The quotes, below illustrate their views on these regulatory issues.
You know, I guess it comes down to, is [the debris] a waste or not a. waste?
- Roundtable 3 Participant;,.
Let's put it this way, debris is...waste to a.very small extent and commodity to a large extent, ft's
a commodity. It's a commodity that happens to be tainted. Don't look at it as a very high
' volume -[situation], but'rather as a very high problem situation. -- Roundtable 1 Participant
If you-spill material...and it goes on a wooden floor, did you spill waste ordid you spill good
product? Does.it have'to carry an F listing or [do] you just have to look for the characteristic
codes?...! would say .it's only a waste when you want to get rid of the floor, that's when it
1 becomes [a waste} - it's just like, any spill into soil and you could claim the contained in theory, .
I guess so, maybe not. -- Roundtable 3 Participant . . .
I'm sort of concerned with the numbers like 9.5 millimeters [i.e.,' the lower size limit on geologic
debris]...who's going to be measuring these particles? You know, when you're actually dumping
a'fiitsr or you're taking your bag house and you're going to separate, those are 9.5 and these
are 9.3 and.this goes that way and that goes [there]. That's hot the way the real world operates.
.You've got a whole pile of junk called debris, and you say 'that's debris'.
- Roundtable 2 Participant ' '
We have contaminated debris, we have uncontaminated debris...We get the regulations to be so
darn specific that we're cutting our own. thro at... I think we need to forget about all these what is
it, -.3 millimeters or .5 millimeters, and say we're trying to regulate a chemically made waste...not
the pipe that is handling that waste, you know. Let's do something else with the pipe; let's do
something eise with the filter that filters that K waste. Give me a handle that I can say, 'I can do
something with the pipe and to-heck with it, contaminated, derived from or whatever. The pipe
is a pipe, it's not the waste. You are regulating the waste.'' And,if I can do something, let's tfo
it. - Roundtatls 2 Participant
Right now, I have KO11 and K013 [debris]. That's doomed forever because of the genes [by the
mixture rule]. If the genes in K011 and K013 are there. And nobody tells me, says, 'Well, yes,
but if you can prove that it's got less than point triple 0 million parts per trillion or whatever,'...So
I've got all this stuff...just because it carries those genes. - Roundtab/e 2 Participant
I think of the debris that we put! off of -- forget the bricks and the boulders and the rocks - the
continuous debris that we make, like boards out of our- API separators, fly boards, or the hard
hats and coffae cups and whatever that comes up on our bar screen, how do you sample a hard
hat? - Roundtable 2 Participant . ' -
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One of the things that we found is that sampling is a big problem with contaminated .debris. You
can take a piece of piping and you can sample six inches apart and you might get mercury a
magnitude different. - Roundtable 2 Participant \ \ '
It's very difficult to 'have a good representative analysis of debris. You may- have a piece of
debris that's going to have something [on it] but the other piece you took the sample of may not.
So in one case you may have something that isn't contaminated that's being treated as
contaminated, but on the other hand you might have [something that]...is contaminated, but the
piece that they're [testing] from isn't, and so then you're going to have a mystery waste. You're
going to have like a lesser of two evils. - Roundtable 3 Panic/pant .
One of the problems.,-.is that EPA has a definite position on what constitutes treatment and it's
fairly broadly construed and then the States just construe the hell out of it!..'so now everything
needs a permit. - Roundtable 1 Participant ' -
If ws need treaiment permits when we decon debris, we're not going to do any work.
- Roundtable 3 Participant ... . '
I think we never considered [de-con] to be treatment. And-this [ANPRM] is sort of the first thing
I've read that said it would be treatment.* It is a separation process' and in that sense it is
' treatment, but we've never.vtewed it that way. - Roundtable 3 Panic/pant
Weil, I'm fairly certain all the decon 'work we do is done without permits. If the rules now will
specify that this is treatment and we have to obtain permits, it will basically shut down our decon
business...! don't think we're aware how upset we would be...But if we have to get permits to
scour concrete or to sandblast a ship, it's going to be very difficult for us.
- Roundtable 3 Participant .
[Any treatment for debris] that we can do on concrete pad, and that includes about-half of. the
things included in extraction-water washing, hydro blasting, sand blasting, steam cleaning-we
would probably take the position that that is not subject to a permit. We might be challenged.
- Roundtable 2 Participant, ' . .
1 think there is something the Agency can do; if they can define for us decontamination and the
concept of decontamination being something totally different from treatment, that you can
decontaminate without a RCRA permit, we could certainly decontaminate and do the right thing.
And define 'decontamination', as applied only to debris. - Roundtable 2 Participant,
[Testing the rinsate is] extremely, difficult to do when you're decontaminating debris - you've got
to now have a container, you've, got to build facilities that youVe got to store all this rinsate in.
Now you've got this rinsate, you know, you've got to store this rinsate from a large facility, you've
got to sample it, you've got to send it out, three weeks later you get back the results and then
you can drain it into your process sewer. [Ws] just not going to happen in the real world. I see
it as being a real problem. - Roundtable 2 Participant ' /
I mean, just because something is stained doesrt't.mean that it's contaminated. We had recently
a concrete tank.;.the tank was clean, -even though it was stained. We found no
hazardous...constituents tor which the waste was listed...You can' decontaminate things like
concrete with steam - and that's alt we did, we steamed it. No problem. It will still look like hell,
though. i- Roundtable 2 Participant ' . . '.
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.Every job we do where we de-con a plating room or material - [the entire room] isn't necessarily
de-coned. Debris is generated, that still carries codes. Our goat is to de-con it, but that doesn't
happen all the time. -- Roundtable 3 Panic/pant
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IV, Capacity Issues for Hazardous.debris
In discussing cspacity issues.' all the participants stated {hat there could tie capacity-
problems for debris when the variances expire in May, T992.' Panic/pants in roundtables one
and th'ree (commercial landfills and brckers/lreaters). also made the point that they might
decide not'.o manage hazardous debris. ' .(
We have a horrendous number of things known as debris. And we find out that there are very
few commercial businesses really wanting to make [hazardous debris] a bread and butter
practice. - Roundtable 3 Participant
the problem is that you don't know, you're going to promulgate 'a regulation but you won't know
when you do jt when the capacity is going to'become available. By the time the capacity
. becomes available there may be a better thing,..to do with that waste. You know, we lock,
. ourselves into yesterday. - Roundtable 1 Participant
Well, I think that the general consensus [is] that more-than'the.technical issues associated with-
treating debris, it's the procedural, the policy, the regulatory issues that are going to determine
whether or not there actually is any capacity and whether or not we will all choose to be
participants'in the treatment of debris and not leave you guys sluck with a gigantic problem out j
there. - Roundtable t Participant \ . .
. [V/aste treatment is] a finite' universe, it's not expanding. People hate to hear about waste
disposal sites, they hate to hear about incineration...We've got...to figure out how to recycle and '
.conserve...Until we do that, there is going to be a capacity problem.1- Roundtable 2 Participant
I think it would be foolish to start messing around with incinerator ash and calling it contaminated
debris. The way to control that is of course, control of what goes in the incinerator.
- Roundtable 2 Participant .
The processing part of [our] facility, the pre-processing before incineration,... [is] actually quite
.iarger than the actual incineration operation. Getting the [debris] prepared to feed to the
incinerators is a very important part of the overall processing. - Roundtable 3 Participant
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I think, too, it's maybe not necessarily that one tree [that's causing the prob!em];..[lt's].lbe
cumulative effect of all these materials...you say you don't have a problem with [contaminated]
wood, we don't have a problem with this, we don't have a problem with that. Put them all
together and we've.got a capacity problem. - Roundtabte 3 Participant
Basically our biggest constraint is the ability to get equipment and do the processing.
- Round table 3 Participant ' ' . '
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There is the unknown, what kind of quantity am I looking at in this type material? What kind of
standards am I going to have to meet when I finish [treating]"? Is it worth paying this much
money for,this equipment to process a waste stream when I really don't know what kind of
volume I'm going to get. I have to recover my capital cost. 'If I assume I've got 200 yards and
I've got to recover my capital costs of 5200,000 -- it doesn't take a lot of math to know that I'm'
going to ha.'ve to turn some customers around! So it gets difficult on even deciding what you're
going to permit and how you're going to put it in. -- Roundlable 3 Participant'
.What are we going to do with this waste that's going to be coming on? I'd say about 30 to 60%
of our major waste streams are debris conta'minated. Well, what .are you going to do? Along
with everybody else, what are you goingjo do with it? - Roundtable 3 Participant
We need systems like [the one's described in the ANPRM] today, but we don't have them. No
ons's out there doing .this on a commercial basis. We have landfills and incinerators [but]'we
have very few people who are trying these levels of encapsulation or immobilization or extraction.
All .of these will be a TSD activity, all will be a RCRA license. - Roundtable 3 Participant
...if you started stretching the derived-from rule or the contained-in rule to extremes, there's a lot
of things that don't really need trie treatment that 'could choke capacity. We should limit the
capacity that is available for things that really need the treatment. - Roundtable 3 Participant .
...it-doesn't have anything to do with whether-or not ybu^can manage [debris], but it has a lot to
. do with whether or not you will. ~Roundtable 1 Participant"
...these' regulations aren't considering whether or not a facility will take a [hazardous debris]
waste. When it becomes a health and safety risk for us to take a waste, we don't care what it
is and we don't care how much you'll pay. We don't want it,..the bottom line on a waste like that
is there is probably riot anybody,, .who could do anything with it. -Roundtable 1 Participant
-...if I have a feeling like this [hazardous debris] is a marginal revenue waste stream, and I'm not
real sure whether or not it's going to be reactive or not reactive, or how should I treat it, I'm'not
going to.take it. I'm going to say, go to [another company], let them lose money on.you.
- Roundtable 1 Participant - "
The one thing that there's never been in the world is a problem getting waste streams. We pick
and choose. The impact [of the LDRs for hazardous debris] is not going to be on us.
- Roundtable 1 Participant '
';.. it we feel that somewhere down the road we're going to have a problem, we just won't take.
it! If we can't take his [hazardous debris] waste, we can't take his waste. We 'don't work,
generally speaking,-as a consultant to make sure that his waste is handled properly. [The
generator is] .out on his own. - Roundtable '1 Participant ' . .
...we're a conservative company, we're waiting for somebody else to stick their neck out [in trying
new methods to decontaminate debris] and if they don't get it chopped off then maybe it's okay
for us to do it. - Roundtable 2 Participant , . ' .
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...I'm going to protect my larger customers, whatever material I can .get in .will be for the larger
customers. The smaller customers, the ones that are incinerating 2, 3, 4, 5 drums a month or
something like thst, they'll be left out in the cold, and 90 days after that time, the Department of
.Ecology in Washington is going to come knocking'on their door, and I'm not going to be able
to help them. - Roundiable 3 Participant
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V. New Capacity for Hazardous debris Treatment
The participants in alt three, roundtables stated that the two major reasons that
capacity'for treating debris would not be available in May 1993 when the variance expires
were the specialized'equipment that would on required and the length-of the permitting
'process. In rte quotes below, the participants express 'their views on these two issues.
We're out there in life boats. - Roundtable / Participant ' '
...the only type of relief that we can hope for is regulatory relief that would allow us the
opportunity to get into the business to provide that capacity. Because unless it's existing now,'
or its been permitted now, it won't be on line by May of '92 and maybe by May of '93.
- Roundtable 1 Participant
God help us if we got to crush and do a lot of fancy extraction because there is no way in hell
you're going to be able to find all the contractors, all the'engineers, and all the designers.to
[build] it in such a short period of time. - Roundtable 2 Participant . '. ' ;.
Even without.permitting,...many of these systems in [the ANPRM] for destruction and extraction,
(are} going to have to be engineered systems, because they're tricky to operate or because they
involve materials which have some hazard in them, and you're not going to be able to do that
in the time frame that says 'go' on May 8th {1992]. ~ Roundtable 2 Participant
Even if we went right now and said, 'ok, we're going to put in a shredder', there's no one piece
of equipment out there that could do the job'. - Roundtable 1 Participant
[In the permit process] a lawyer, ten lawyers is no match for one citizens group...A fleet of 80
Cadillac lawyers is no .match, no match for one concerned Alabama land owner.
- Roundtable 1 Participant
There's two issues on permitting; one is the time and. the other is, I'm not sure that we can get
a permit to do anything with the label of hazardous waste on it. You're going to have them lined
up, you're going-to have them chaining themselves to the front gate and everything else.
Reasonable is still two years to get a permit sometimes. - Roundtable 2 Participant
Assuming you're doing something that is going to emit, or if we're going to do, let's say/ a
solvent wash or some kind of situation like that for some debris, and you're going to emit
something, you're going to need [art air] control device and/or a permit. And if [RCRA] won't get
you, the Clean Air Act will, anyway, -i Roundtable 2 Participant . .','-
It's the RCRA [permit] that's the killer.'- Roundtable 3 Participant
But my experience is that major [permit] modifications aren't any fun, either, on the federal level
because of the public comment period. - Roundtable 3 Participant
I don't do air permitting, but I do do RCRA permitting, and RCRA permitting is a bear...It's
generally when you map out permitting processes that the'RCRA oerrhit is going to take the
longest, I can tell you that. - Roundtable 3 Participant . '
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i was just thinking emergency response and all the fire departments, what a bad precedent io
start...Contractors aren't the only ''people that decon. there are certain circumstances* where
firemen get involved in it as well...Permitting [applies'to] that as wei), the whole .emergency
response function. - Roundtetife 3 Participant' :
There's nothing simple about getting a permit. It may be a very simple process, but getting a
. permit is hot simple. - Roundtable 1 Participant
Depending on where you are going to live in this country, the states [in their permitting process]
are'going to cause [you] more or less grief than the EPA themselves. - Roundtable 2 Participant
One thing we have found that helps'is if something is a HSWA provision and we have gone after
modifications for a HSWA provision, we have found that it's easier to get that permitted because
you we're in the federal program, until the state adopts the rule. - Roundtable 3 Participant'
Everybody knows that states are erecting barriers and they're trying,their best not to allow you
to add on capacity. But I would say in the case of debris, to the extent that you do...allow simple
equipment to be added as a HSWA provision, that will help to expedite the permitting of
additional capacity. - Roundtable 3 Participant ' i . - -
There's no consistency [in permitting] and that's the problem I see.because we're dealing with
different States and different regions and each State and each EPA has its own personality.
. - Roundtable 1 Participant ' . .
Right novy, we face the prospect in many states of getting the specific permits...for.states.- That
Ms a major problem. What it leads to is this, all the [hazardous dsbris] gets sent to a central
treatment facility, few of which are getting permitted, and th'en you really have a capacity
.problem.-Roundtable 3.Participant . ' ' . '
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In some states, if [the regulations are] ambiguous! 'they will err on the conservative side.
Because that way they can never be wrong. And then the work doesn't get done. I would prefer..
not to.have it ambiguous because.-.depending on who's running the job, [they] will be more or
less stringent in enforcing regulations of States. [If there are] discrepancies all over the country,
how would we work? - Roundtable 3 Participant . , . .
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VI. Generation, Management, and Treatment of Hazardous debris
Participants in the rouridtables discussed the generation, management, ancf treatment'.
of hazardous debris. ; They discussed debris from continuous sources,- debris from
remediation actions, and debris from demolitions: The quotes below characterize their views.
on these subjects. ..-. .' '', -.-.'. ' .. . - . ! . " '
Gee, how do you manage all this stuff?' Because it's a problem of a lot of little things. Some
manufacturing plants have a different situation^ they've got a few things, but they've got a lot of
it. And distribution and handling this stuff - the logistics [are] a big concern. We don't have*
the answers, we're trying to definethe problems. - Roundtable 2 Participant . .
We're cleaning up the past 100.yeai&olsins.-Roandtable 3 Participant. : . . ' -
What you're hearing 1 think is - everybody's mentioned that a lot of this debris is going to be
episodic. It's already there. There; aren't gc.ing'to be any waste minimization efforts that can be
"taken to reduce this materiaL.it's there now! and there's nothing that can be done about it. For.
. stream's'that are continuous, yes,: waste minimization will be an important fector;..but when we're.
talking about debris, we're talking about no reduction today or in the future of how much debris
is going to be generated in:a real sense."- Roundtabte 2 Participant '''-'.' . :
...a big problem is dealing withThis point of generation [for debris],.separation of the components .
kind of idea, because the landfill has no control over that...the regulations kind of squarely place
the burden 61 compliance with the land 'disposal restrictions upon us and...often times we don't
. have any control as to whether or not.we're:ab!e to comply. - Roundtable i Participant- -.. '..:
...this whole question of remediation is going to increase by leaps and bounds for all of us arid
others who are not here, and the amount and volume of what we have to deal with is going to .
get larger every year -Roundtable 2 Participant '. . ''_
{The volume of hazardous debris generated at remediations Is] still going to be awfully hard.tb
estimate, because there's a million varieties of them out there. We have them going officially
under corrective action, you 'know," some under Superfund...m6st of them are under some sort.
of state authorities, many of them are strictly voluntary...those are going to be awfully hard to
estimate...! would guarantee you they're going to overpower everything else we have. ' - '.
~ Roundtable2Participant . , . .-";' : ;' -." '-..'-. > ..:
My point is that yes, maybe you should treat [hazardous debris] separately, but the trouble is the
.non-remediation related are going to be fairly trivial [volumes] compared to the remediation
related things. But the non-remediation related things are the one's you could get a handle oh..
-Roundtable2Participant . .; . ; ' ; . ,
I think niters [may be considered hazardous debris and.are] a real big wild card for everybody.
Nearly every piece of equipment that operates and handles...fluid had some type of filter-
.associated withlit. - Roundtable i Participant ;,.. ' . .
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[The routine things are] a very.small portion of bur.hazardous debris...lt's the corrective action
things that make up by far the largest percentage part.. By corrective action, again. I want to
,point out that I don't mean just necessarily formal corrective action. I mean all kinds of clean up -
.'- self initiated, state'Initialed, on and on; - Roundtable 2 Participant ', ;
We'll hear that a certain [hazardous waste contaminated] material is a problem; and when you,
look at it, it's a problem because whoever has that material has a nice little definition of how it
should be treated and how much ft should cost to b'e treated. Well, all it takes is money.
-.Roundtablg 3 Participant .'..' ' ;
there's always going to be a place for us [to send hazardous waste to].-.'.
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There's always a home for something: Send half of it up to Stablex...and some of the stuff to
Ensco orsome of thei stuff to Thermalkem. -Roundtable 3 Participant
You remember that the generator for the most part is not going to have the/direct contact with
a disposal site per se and if they go through a. [broker], they're going to have what they call
generic profiles into places where they can usually have three or four slots a month. It's going .
to be cheaper for them to send it to [a broker] than it Is for direct incineration. If they only get.
a one-shot deal; incinerators aren't going to offer them a [good] deal.:,With us they know they're
going tiptget itcheaper. So they'll come to us. - Roundtable 3 Participant :
The military is probably in the same place that industry was in 1981 or something like that/when
the 55 gallon drum was a garbage can. It was less expensive to get rid of hazardous waste: in;
.1581, and we would find soda cans, baseball caps, cigarette butts, - Roundtable 3 Participant
Weil, you've got your DOD insta|lations...you have people constantly changing, changing-oMhe-
guard, and you've got people managing the waste on those sites that the Sergeant will tell them .
to 'put that sandblast grit into the drums and then'anything else that you see around the. area,
Just toad it up into those drums.' You end up. getting a myriad of different components..,An
industrial generator,;..they know that you don't put paint filters in with the sandblast grit,' you
don't put the respirator cartridges, the Trvex, the gloves, the boots in with any of the above...But
with DOD, DOE...it's not consistent - Roundtable 1 Participant '.-''
The Corps of Engineers is keeping all of our water ways. They're constantly dredging [debris]
materials...that have chemical contamination. - Roundtable 3 Participant. -.";.
I guess what we're saying is the metals are never isolated by themselves, whether they're from
cleanup or they're debris that are generated by specific customers, or it's our own debris. It's a
collection over a period of time of everything that has been added to that debris batch. A lot of
times it's wire and everything else, and it's tied all in with plastic pieces, pipes..To.try to break
that down Into uniform discreet types of materials that are going to have different treatment
standards wou|d be very difficult, cost prohibitive. - Roundtable .1 Participant ' . .'. -
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VII. Potential Hazardous debris; Problems
,. , T/re participants noted various types or categories of debris that could be
potential problems. The quotes below describe some of those problems.
All'[tfte] service stations have the mini based car filter, and.;.we're finding that we have a wide
variety of those kind of filters - from automobiles alf the way to large size equipment. We have
a great deal of filters that are...elements that we put into process equipment; these filters, they
. could be paper, they can be polypropylene...and we have to deal with those filters as debris, and
. we have to dispose of them as debris, as contaminated debris. - Roundtable 2 Participant
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If you do some excavation in an area and you dig up old buildings, especially for those of us
' who'are involved in older sites, as you work through this whole situation of corrective action or
' remedial type actions of RCRA facilities, as you dig up old facilities, how do [you] separate?...!
don't know how tb separate the concrete from the. brick from the pipe from the grass from the
'." plastic from the wood necessarily, because normally the guys.go. in and dig out this whole thing
and fypuj have this great big pile.."- Roundtable 2 Participant .. : ,. ; -
I'm thinking to myself I bust a building; I go down below grade and here I have all this concrete,
'now I'm going to backhoe in there'and it's tough to dig this stuff out, and out it comes with ,
.. concrete, rebar, and everything in great big chunks,: and that's all listed waste contaminated,
possibly.»what can you now dp to deal with those various chunks of concrete which are this big
, and this big arid you've got bars sticking out of them?- toow can you practically deal with that?
-Roundtable 2 Participant . V. . . ' "'>'.' .... . .- -
It's hard to do demolition, you can't take [a building] apart piece by piece. You do have to take
bulldozers in, you know, move stuff around, pile it up.. You know, we wouldn't want to get
trapped, especially non permitted facilities, in creating waste piles that then could become RCRA
regulated by a zealous regulator of same sort. It's the same problem you have with digging a
ditch and digging up some soil that is potentially contaminated...you're doing art excavation just.
to-uncoveir a pipe, to chango.a:varye or something like that, and that material potentially
. contaminated - is that or is that not a. waste, is it hazardous, is it non hazardous* how much do
; you have to pile up before it becomes a waste pile?' You have some of those same problemsx
with the contaminated 'debris, and right now that's :all grey area:..:-- Roundtable 2 Participant
Radios, I don't think you can wash them off, and [lead] painted glass. (i.e.,:Wiridsnields], I don't
think we can wash that offi chrome refractory bricks, I don't think you can wash that off.
- Roundtable 2 Participant ' ' - , -,' . ' ; .
And there is specialized equipment needed, yes. [For example, contaminated trees] still need -
- logging, special, handling equipment; and you have to have special equipment added on,
particularly [for] boulders. - Roundtable 3 Participant , : -'..-.
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