May 1990
Environmental Protection . .,.*- •. »si&
Agency- Washington, DC 20460
Solid Waste '
Background Document For
Third Third Wastes To
Support 40 CFR Part 268
Land Disposal Restrictions
Final Rule
Third Third Waste Volumes,
Characteristics, and Required and
Available Treatment Capacity
Volume
CHAPTER 4
APPENDIX A-APPENDIX I
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BACKGROUND DOCUMENT FOR
THIRD THIRD WASTES TO SUPPORT 40 CFR
PART 268 LAND DISPOSAL RESTRICTIONS
- .. FINAL RULE
THIRD THIRD WASTE VOLUMES, CHARACTERISTICS,
AND REQUIRED AND AVAILABLE TREATMENT CAPACITY
Volume III
CHAPTER 4
APPENDIX A - APPENDIX I
U.S. Environmental Protection Agency
Office of Solid Waste
401 M Street, S.W.
Washington, D.C. 20460
May 1990
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TABLE OF CONTENTS
Page
Section No.
Volume I
EXECUTIVE SUMMARY E 1
INTRODUCTION 1 1
1.1 Legal Background 1 1
1.1.1 General Requirements Under HSWA 1 1
1 1.2 Schedule for Developing Restrictions 1 1
1.1.3 Variance from the Schedule 1-2
1.2 Summary of Previous^Land Disposal Restrictions 1 3
1.2.1 Solvents aivd Dioxins 1 3
1.2.2 California List 1-5
1.2.3 First Third Wastes 1-6
1.2. (4 Underground Injected Wastes L 7
1.2.5 Second Third Wastes (surface disposed and
underground injected wastes;
:*
1.3 Introduction to the Third Third Final Rule ^
1.3.1 Surface-Disposed Wastes 1-T.O
1.3.2 Deepwell-Disposed Wastes 1 11
1.3.3 Soil and Debris 1 11
1.34 Mixed Radioactive Wastes 1 11
CAPACITY ANALYSES RESULTS 2-1
2.1 General Methodology 2-1
2.1.1 Data Set Development 2-2
2.1.1.(1) National Survey of Hazardous Waste
Treatment, Storage, Disposal, and
Recycling Facilities 2 - 2
2.1.1.(l)(a) Background 2-2
2.1.1.(l)(b) Schedule and status 2-3
2 l.l.(l)(c) Technology capacity
information 2-4
2.1.1.(l)(d) Waste volumes land
disposed 2-5
2.1.1.(l)(e) Overview of data
handling, technical
review, and quality
__—«^^ assurance ^*. 2-6
2.1.1.(l)(f) Chemical Waste
Management Emelle
Alabama 2-7
2.1.1.(2) National Survey of Hazardous Waste
Generators . 2-9
2.1.1.(2)(a) Background 2-9
2.1.1.(2)(b) Schedule and status 2-9
2.1.1.(2)(c) Uses 2-9
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TABLE OF CONTENTS (continued)
Section
2. 1.1. (3) Multi-Source Leachare Para bources
Page
No.
-
2. 1.1. (4) Mixed Radioactive Was r ft Data Sources 2-10
2 1.1. (5) Other Data Sources ^ ~ 10
2.1.2 Capacity Analysis Methodology "
2.1.2.(1) Required Capacity ^"11
2.1.2 (2) Available Capacity
Results 2'14
2.2.1 All RCRA Wastes 2'l5j
2.2.2 Solvents 2'17
2.2.3 Nonsolvent -RCRA Wastes Containing
Halogenated Organic Compounds (HOCs) 2-1?
2.2.4 First Third Wastes 2-26
2.2.4.(1) All First Third Wastes 2-26
2.2.4 (2) First Third Wastes for Which Formal
Treatment Standards have been
Promulgated 2-26
2.2.4 (3) Soft Hammer Wastes from the First
Third Final Rule ^ 2|31
2.2.5 Underground Injected Solvent Wastes 2-32
2.2.- Underground Injected California List Wastes 2-34
2.2.6.(1) Free Cyanides 2-34
2. 2. 6. (2) Metals 2-34
2. 2. 6. (3) Chromium Wastes 2-34
2. 2. 6. (4) Corrosives 2-36
2.2.6 (5) Halogenated Organic Compounds 2-36
2.2.6 (6) Polychlorinated Biphenyls (PCBs) 2-37
2.2.7 Underground Injected First Third Wastes 2-37
2.2.7 (1) K062 Wastes 2-37
2.2.7 (2) K049. K050, K051, and K052 Wastes 2-37
2.2.7 (3) K104 Wastes 2-39
2.2.7 (4) K071 Wastes 2-39
2.2.7 (5) K016 Wastes 2-39
2.2.7 (6) K019 Wastes 2-40
2.2.7 (7) K030 Wastes 2-40
2.2.7 (8) K103 Wastes . 2-40
2.2.8 Second Third Wastes 2-40
2.2.8.(1) Overview 2-41
2. 2. 8. (2) All Second Third Wastes 2-41
2. 2. 8. (3) Second Third Wastes for Which Formal
,_^— __ Treatment Standards Have Been "*-"
Promulgated . 2-41
2. 2. 8. (4) Surface Disposed Second Third
Promulgated Wastes 2-44
2. 2. 8. (5) Underground Injected Second Third
Promulgated Wastes . . . 2-46
2. 2. 8. (6) First and Second Third Soft Hammer
Wastes . . .... 2-48
2.2.9 Determination of Available Capacity for the
Third Third Proposed Rule . . 2-50
11
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Section
TABLE OF CONTENTS (continued)
Page
2.2 9 (1) Effects of Previous Land Disposal
Restrictions 2-50
2.2.9 (2) Impacts of Third Third Final Rule
on California List HOCs 2-51
2.2.10 Third Third Promulgated Wastes 2-51
2.2.10 (1) Overview 2-51
2.2.10 (2) Surface Disposed Third Third Wastes 2-53
2.2 10 (3) Underground Injected Wastes Included
in Third Third Rule 2-55
2.2.10 (4) Soil and Debris . 2-59
2 2.10 (5) Mixed Radioactive Wastes 2-62
Waste Code Specific Capacity Analysis for Third Third
Promulgated Wastes . 3-1
I 1 Characteristic Wastes 3-13
3.1.1 D001 Ignitable Wastes 3-13
3.1.2 D002 Corrosive Wastes 3-17
3.1.3 D003 Reactive Wastes 3-20
3.1.4 EP Toxic Pesticides (D012-D017) ^ 3*25
3 . 2 Metal Wastes . . 3-34
3 . 2,. 1 Arsenic Wastes ... 3-34
(D004, K031, K084, K101, K102 , P010, P011,
P012, P036. P038, U136)
3.2.2 Barium Wastes (D005, P013) 3-42
3.23 Cadmium Wastes (D006) . . 3-44
3.2.4 Chromium Wastes (D007 and U032) 3-47
3 2.5 Lead Wastes 3-50
(D008, P110, U144, U145, U146 , (K069, K100)
3.2.6 Mercury Wastes 3-58
(D009, K071, K106, P065, P092 , U151)
3.2 7 Selenium Wastes 3-65
(D010, P103, U204, U205)
3.2.8 Silver Wastes . 3-68
(D011, P099, P104)
3.2.9 Thallium Wastes . 3-70
(P113, PH4, P115, U214, U215, U216. U217)
3.2.10 Vanadium Wastes . . . 3-74
(P119 and P120)
3.3 Tre**ore-HS- Standards for Remaining F and K Wastes ^ 3-77
3.3.1 F002 and F005 . . 3-77
33.2 F006 and F019 3-79
3.3.3- F024 . . . 3-85
3.3.4 F025 . . . 3-87
3.3.5 K001 and U051 3-88
3.3.6 Waste from Pigment Production ... 3-90
K002, K003, K004, K005 , K006, K007 , and K008
3.3 7 Acrylonitrile production wastes K011, K013 and K014 3-97
3.3 8 Benzyl chloride distillation Wastes K015 3-101
i-ii i
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TABLE OF CONTENTS (continued)
Section
3.3.9
3.3.10
3.3.11
3.3.12
3.3.13
3.3.14
3.3.15
3.3.16
3.3.17
3.3 18
3.3.19
3.3.20
K017
K021
K022
K028
K032
and K073
and K098
K036 and K037
K025, K026, K035; K083
K029, K095. and K096
K033. K034 K041. K097
Disulfoton Production Wastes
K042, K085 and K0105
K044, K045. K046, K047
K048, K049, K050 K051, and K052 Petroleum
Refining wastes
Coking operations wastes K060
Electric furnace steel production
Wastes K06l
Ink Production Wastes K086
3-102
3-105
3-107
3-115
3-116
3-120
3-121
3-129
3-130
3-131
3 4 Treatment Standards for U and P Wastewaters
Nonwastewaters Excluding Metal Salts and
Organo-me tallies
and
3.4.1
3 4.2
3.4.3
3.4.4
3.4.5
3.4.6
3.4.7
3.4.,
Halogenated Aliphatics
(U044, U074, U076, U077, U078, U079, U080, U083,
U084, U131, U184, U208, U209, U210, U211, U226,
U227, U228, U243)
Halogenated Pesticides and Chlorobenzenes
(P004, P037, P050, P051, P059. P060, P123,
U036, U037, U038, U060, U061, U070, U071,
U072, U127, U128, U129, U130, U132, U142,
U183, U185, U207, U207, U240, U247)
Halogenated Phenolics
(U039. U048, U081, U082)
Brorainated Organics
(P017, U029, U030, U066, U067, U068, U225)
Miscellaneous Halogenated Organics
(P016, P023, P024, P026, P027, P028
U006
U033
U047
U138
P118.
U027
U046 ,
U121,
U017,
U034,
U049,
U156,
U020,
U041,
U062,
U158,
P057
U024,
U042,
U073,
U192,
P058, P095
U025, U026
U043, U045
U075. U097
U222)
Aromatics and Other Hydrocarbons
(U019, U055, U056, U186, U220, U239)
Polynuclear Aromatic Hydrocarbons
(U005, U016, U018, U022, U050, U063,
764, U094, U120, U137, U157, U165)
Phenolics
(P020, P034, P047, P048, U052, UL01, U170,
U188, U201)
3-133
3-133
3-152
3-177
3-182
3-189
3-218
3-225
3-232
IV
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TABLE OF CONTENTS (continued)
Section
Page
No.
3 . 4 9 Oxygenated Hydrocarbons and He terocyclics
(P001, ?003. POOS, P088, P102 , UOOl". U002,
U004, U008, L'031, U053, U057 L'085. U108 ,
U112. UL13. U117. U118, U122 . U123 U124
U125, U126, U140. U147, U154, U159, U161,
U166. U182, U197, U213, U248)
3 4 10 Organo-Nitrogen Compounds
(1) Nitrogen Heterocyclic Compounds (POOS,
P018, P054. P067', U011, U148 , U179,
U180, U191, U196)
(2) Amine and Amide Compounds (P046, P064.
U007, U012, U092, U110, U167. U168 ,
U194, U238.0
(3) Aminated DiphenyLs and Biphenyls (U014,
U021, U091, U093, U095, U236)'
(4) Nitriles (P069. P101, U003, U009 , U149 ,
U152)
(5) Nitro Compounds (P077, U105 , U106 , U169
U171, U181, U234)
(6) Nitroso Compounds (P082, P084 , (Jill, "
U172, U173, U174, U176, U177, U178)
3.4 11 Organo - Sulfur Compounds
(P002, P014, P022, P045, P049 . P066, P070,
P072, P093, P116, U114, U116, U119, U153, U193.
U218, U219, U244)
3.4 12 Additional Organic Wastes- -Pharmaceuticals
(P007, P042, P075, P108 , U010, U015, U035,
U059, U089, U090, U141, U143 , U150. U155, U163,
U164, U187, U200. U202 , U203 , U206 , U237)
3 5 Potentially Reactive P and U Wastes
351 Incinerable Reactive Organics and Hydrazine
Derivatives
(P009, P068, P081, P105, P112, U023, U086, U096, U098
U099, U103, U160, U109, U133)
3.5.2 Incinerable -Inorganics (P006, P096, P122,
U135, U189, U249)
3.5.3 Fluorine Compounds (P056, U134)
3 5.4 Recoverable Metallics (P015, P073, P087)
3-275
3-312
3-326
3 . 6 Gases
U115)
3.7 U and P Cyanogens
(P031,~ P033. U246)
3-334
3-334
3-342
3-346
3-349
3-353
3-355
3.8 Contaminated Soils
3-357
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TABLE OF CONTENTS (continued)
Section
Page
No.
CAPACITY ANALYSIS METHODOLOGY
-* 1 Determination of Required Treatment Capacity
4 l.L Waste Volumes Affected
4 . 1. 1. (1) Data Sources
4. 1.1. (2) Identification of Waste Volumes
4. 1.1. (3) Determination of Affected Volumes
4 1.2 Treatability Analysis
4.1.2.(1) Waste Characterization
4.1.2.(2) Treatability Grouping/Assigning
Alternative Treatment
4.1.2.(3) Treatment Residuals
4.1.2.(4) Previous Management
4.2 Determination of Available Treatment Capacity
4.2.1 Determination of Combustion Capacity
4.2.1.(1) Introduction
4.2.1.(2) Approach and Methodology for
the Original Combustion Data Set
Used for the Proposed Rule
4.2.2 Determination of Other Treatment System
Capabilities
4.2.2.(1) Unit Process Capacity
4. 2. 2. (2) Hazardous Waste Treatment/Recovery
System Identification
4. 2. 2. (3) Determination of System Capacity
4.2.2. (4) Projections of Available Capacity
4.2.3 Development of the Treatment Capacity Data
Set and Results
4.2.3.(1) Incineration/Reuse-as - Fuel Data Set
Results
4. 2. 3. (2) Development of the Data Set for
Other Treatment Systems
4.2.3. (3) Treatment Capacity Data Set Results
4.3 Capacity Analysis (Comparison of Required and
Availabl-e Treatment Capacity)
Volume II
APPENDICES
Appendix A
Appendix B
Appendix C
Appendix D
Leachate . .
Mixed Radioactive Waste
Available Capacity Analyses for Each Rule and
Addition of Recent ChemWaste Management Data
Capacity Analysis for Third Third Promulgated
Wastes
4-1
4-1
4-2
4-2
4-5
4-5
4-8
4-10
4-11
4-12
4-12
4-12
4-19
4-19
4-22
4-25
4-32
4-33
4-33
4-37
4-39
4-43
A-l
B-l
C-l
D-l
VI
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TABLE OF CONTENTS (continued)
Section
Appendix £ Capacity Analvsis for Contaminated Soil Wastes
Appendix F Documentation of waste Volumes for Waste Codes
Addressed in Previous Rules
Appendix G Documentation for California List HOCs
Appendix H Bibliography for the Third Third Land Disposal
Regulations
Appendix I Memorandum on Availability of Surveys
Appendix J Analysis of Commercial Alkaline Chlorination
Capacity
Appendix K Analysis of Commercial Sludge/Solid Combustion
Capacity
Appendix L Miscellaneous Phone Logs
Appendix M Analysis of Large Volume Underground Injected
P and U Coded Wastes
Page
No.
E-l
H-l
I 1
J 1
K-l
L-l
I
M-l
V1L
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LIST OF TABLES
Page
No.
Table ES-1
Table ES-2
Table ES- 3
Table ES-i
Table ES-5
Table ES-6
Table ES- 7
Table ES-8
Table 1 1
Table 2-1
Table 2-2
Table 2-3
Table 2-4
Table 2-5
Table 2-6
Table 2-7
Summary of National Capacitv Variances for Surrace
Land-Disposed Wastes
Summary of Two-Year National Capacity Variances for
Underground Injected Wastes
Determination of Available Commercial Capacity for
Third Third Wastes (million gal/yr)
Required Alternative Commercial Treatment/Recycling
Capacity for Surface-Disposed Wastes (million gal/yr)
Required Alternative Commercial Treatment/Recycling
Capacity for Deepwell -Disposed Wastes ('million gal/yr)
Required Alternative Commercial Treatment/Recycling
Capacity For Soil and Debris Wastes (million gal/yr;
Summary of Capacity Analysis for Mixed Radioactive
Wastes
Summary of Capacity Analysis for Third Third Wastes
by Waste Code [includes all wastes regulated under
Third Third]
Third Third Final Rule Wastes by Waste Code
Overview of All Surface Disposed RCRA Hazardous
Wastes (revised based on ChemWaste Data)
Overview of Surface Disposed Solvent Wastes
(revised based on ChemWaste)
Solvent Capacity Analysis (revised based on new
ChemWaste Management Numbers)
Overview of Surface Disposed Potential California
List Wastes Containing Halogenated Organic
Compounds
Overview of Surface Disposed First Third
Promulgated Wastes Containing Halogenated ^
1 "Organic Compounds
Overview of All Other Surface Disposed Wastes
Containing Halogenated Organic Compounds
Capacity Analysis for HOC Wastes (Excluding First
Third and Third Third Promulgated HOCs)
E-9
E-13
E-15
E-18
E-19
E-20
E-22
1 12
2-16
2-18
2-20
2-21
2-22
2-23
2-25
Vlll
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LIST OF TABLES (continued)
Table 2-8 Overview of Ail Surrace Disposed First Third
Wastes
Page
No
Table 2-9 Overview of Surface Disposed First Third
Promulgated Wastes
Table 2 10 Capacity Analysis for First Third Promulgated
Wastes
Table 2-11 Capacity Analysis for Underground Injected
Solvent Wastes
Table 2-12 Capacity Analysis for Underground Injected
California List Wastes
Table 2-13 Capacity Analysis for Underground Injected First
Third Wastes
Table 2-14 Overview of Second Third Promulgated Wastes
Table 2-15 Overview of Surface Disposed Second Third
Promulgated Wastes . . ...
Table 2-16 Capacity Analysis for Surface Disposed Second
Third Promulgated Wastes
Table 2-17 Capacity Analysis for Underground Injected
Second Third Promulgated Wastes
Table 2-18 Soft Hammer Wastes from the First Third and
Second Third Final Rules
Table 2-19 Determination of Available Commercial Capacity
for Third Third Wastes
Table 2-20 Overview of Third Third Promulgated Wastes
Table 2-21 Summary of Capacity Analysis for Third Third
Promulgated Wastes
Table 2-22 Summary of Capacity Analysis for Underground
Injected Third Third Promulgated Wastes
Table 2-23 Summary of Capacity Analysis for Third Third
Promulgated Soil and Debris Wastes
Table 2-24 Summary of Capacity Analysis for Mixed
Radioactive Wastes
:-28
2-30
2-33
2-35
2 38
2-42
(
2-43
2-45
2-47
2-49
2-52
2-54
2-56
2-58
2-60
2-63
IX
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LIST OF TABLES (continued)
Table 3-1 Capacitv Analysis Tables for Each Waste Code
(Use Exhibit 3-1 Index;
Table 3-237 Volume of Concaminaced Soils Land Disposed
Table 3-238 Summary of Capacity Analysis for Third Third
Promulgated Soil and Debris Wastes (Soil
and Debris only)
Table 3-239 Capacity Analysis for Each Waste Code (Soil and Debris)
Page
No.
3-15
3-360
3-361
3-362
Figure 4-1 Process Codes ..
Figure ^-2 Flow Diagram of a Simple System
Figure 4-3 Flow Diagram of Systems with Unit Process
Capacities
Figure 4-4 Flow Diagram of One System with Two Units
Conducting the Same Process
Figure 4-5 Flow Diagram With Unit Capacities
Table 4-1 Summary of Commercial Hazardous Waste
Incineration Capacity
Table 4-2 Summary of Commercial Capacity for Reuse of
Hazardous Waste as Fuel
Table 4-3 Summary of Commercial Treatment System
Capacities
4-20
4-23
4-24
*
4-26
4-28
4-35
4-36
4-40
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4 CAPACITY ANALYSIS METHODOLOGY
This section of the background document presents a detailed discussion of
the methodology (approach) and rationale for the capacity analyses supporting
this final rule.
Section 4 1 includes a brief discussion of the data sources and the of
the waste volume data set used for capacity analysis. Section 4.1 also
presents a detailed discussion of the methodology used for determining the
required alternative capacity for land disposed wastes (demand) Section 4.2
provides a detailed discussion of the determination of available alternative
capacity (supply) and the creation of the alternative capacity data sets used
for the analysis. Finally, Section 4 3 describes the methodology used to
compare the waste volumes and the associated required alternative capacity
(demand) with the supply of available capacity to determine whether adequate
capacity exists to support the land disposal restrictions.
*
4.1 Determination of Required Treatment Capacity
This section presents a detailed discussion of the analytical methodology
used to determine the demand for alternative treatment capacity required by
wastes affected by the Third Third final rule.
4.1.1 Waste Volumes Affected
To assess the requirements for alternative treatment capacity that will
result from the Third Third final restrictions, including contaminated soils,
it was necessary to identify waste volumes by land disposal method, waste
code, and physical/chemical form. With this information, it is possible to
identify which treatment technologies are applicable to the waste volumes and
to determine required alternative treatment capacity. ^
(1) Data Sources
The TSDR Survey, which includes data from the CWM-Emelle Chemical Waste
Management data bases described earlier in Section 2.1.1, was the primary
source used to estimate surface-disposed waste volumes. The TSDR Survey data
4-1
-------
base was the primary source used Co estimate underground injected waste
volumes.
(2) Identification of Waste Volumes
Land-disposed Third Third final wastes were identified on a waste code
basis. For wastes described by a single waste code, the volume was allocated
to the ap--opriate waste code.
For waste groups (mixed wastes and/or wastes described by more than one
RCRA waste code), the entire volume was included in the regulatory group of
the highest priority code in the group. For example, if a waste group was
described by both a solvent waste code (F001-F005) and a Third Third final
code, the entire waste volume was assigned to solvents because they were
restricted prior to Third Third wastes.
Consequently, to avoid double-counting, only waste volumes for waste
groups containing a Third Third final code but no solvents, Ffrst Third wastet
for which a treatment standard was promulgated on August 8, 1988 (i.e.,
non-soft hammer First Third wastes), or Second Third promulgated wastes (i.e.,
non-soft hammer Second Third wastes) have been included in today's estimates
of required capacity unless promulgated standards are being revised.
Furthermore, if a waste group contained more than one Third Third final code
but no previously restricted codes, the volume was divided equally among the
Third Third final codes.
(3). Determination of Affected Volumes
Land disposal is defined under RCRA as any placement of hazardous waste
into or on the land. Therefore, storage and treatment of hazardous waste in
or on the land are also considered land disposal. Land disposal methods can
be divided into numerous categories. Five types of land disposal are
addressed in de^ajj^in this document: disposal in landfills; tre-aXment and
storage in waste piles; disposal by land application; treatment, storage, and
disposal in surface impoundments; and underground injection. Utilization of
salt dome formations, salt bed formations, and underground mines and caves are
additional methods of land disposal that are affected by this rulemaking.
Currently, there is insufficient information to document the volumes of Third
Third final wastes disposed of by these last three methods; therefore, they
4-2
-------
are not addressed in the analysis of volumes and required alternative
treatment capacity
Estimates of the volumes of affected wastes that have been stored (but
not treated or disposed of) in surface impoundments or waste piles are
presented. Storage implies a temporary placement of wastes in the surface
impoundment or waste pile. EPA has assumed that all of the affected wastes
stored in surface impoundments are eventually treated or recycled or that they
are routed to permanent disposal in other existing units. To avoid
double-counting in this analysis (i.e., counting waste volumes once when they
are stored and again when they are finally disposed of), the volumes of wastes
reported as being stored in surface impoundments or waste piles were not
included in the estimates of volumes requiring alternative treatment capacity
Nevertheless, these wastes will be affected by the restrictions and will
require alternative storage capacity However, if during the facility-level
analysis of the responses to the TSDR Survey it was determined that wastes
were being stored indefinitely in the impoundment or waste pile (i.e., «
long-term storage), these volumes were included as requiring alternative
treatment capacity because they would not be counted elsewhere. If hazardous
waste entered a waste pile or surface impoundment for storage in 1986 but no
waste was reported as having been removed from the impoundment or waste pile
for treatment or disposal prior to or during 1986, the waste was considered to
have undergone long-term storage.
HSWA required that all surface impoundments be in compliance with certain
minimum design and operating criteria (minimum technology requirements; see
RCRA section 3005(j)) to continue receiving, treating, or storing hazardous
waste beyond November 8, 1988. Furthermore, the land disposal restrictions,
upon promulgation, forbid placement of restricted wastes in surface
impoundments, except for treatment. Consequently, most surface impoundments
were replaced by tanks, retrofitted to meet the minimum technical standards,
or closed by November 1988. However, because the baseline year for" the TSDR
Survey is 1986, the 1986 land disposed volumes do not reflect these changes.
Therefore, a special analysis of the management of wastes in surface
impoundments was conducted. As described in Section 2.1.1, if it could be
determined from the survey responses or through facility follow-up that a
treatment surface impoundment was being closed without replacement (i.e., the
4-3
-------
surface impoundment was Co be bypassed because it was not crucial to the
effective operation of the treatment system), was being replaced by tanks, or
was being retrofitted, then the volume was dropped from further analysis of
waste requiring alternative treatment capacity
For surface impoundments used for treatment and long-term storage or for
treatment and disposal that were being replaced by tanks or retrofitted, it
was sometimes necessary to include the volume of treatment residual generated
in the impoundment in 1986 in the volume requiring alternative treatment
capacity Because the impoundment was used for long-term storage or disposal
of the treatment residual, the volume was not counted elsewhere as land
disposal. Where it could be assumed that the treatment residual would
continue to be generated after retrofitting or replacement, the volume of
treatment residual generated on an annual basis (not the entire volume
entering the impoundment for treatment) , was included as requiring alternative
treatment capacity For example, if a facility reported that in 1986 it used
a surface impoundment for treatment (settling) and disposal of a Third Third-
final hazardous waste but that in 1988 it was replacing the impoundment with a
settling tank, the volume of waste entering the impoundment in 1986 would not
require alternative treatment capacity because it would no longer be land
disposed in 1988. However, the volume that settled for disposal in 1986 would
still be generated in the tank in 1988 and would require alternative treatment
capacity prior to disposal. The treatment residual volume would therefore be
included in the volume of wastes requiring alternative treatment capacity
If, however, it was determined that the impoundment was a flow-through
impoundment and that only incidental settling occurred (i.e., less than 1
percent of the volume entering was settled) , then it was assumed that there
would be essentially no settling when the impoundment was replaced by a tank.
The quantities included in the CWM-Emelle data represent the volumes of
wastes shipped to CWM-Emelle for disposal by landfilling, but do not
necessarily refleet'the volumes of wastes actually landfilled. Even though a
waste stream was reported with the final handling method representing
landfill, it is possible that the waste stream was managed in a manner that
could alter its volume prior to being landfilled. CWM-Emelle has a
stabilization process and a solvent extraction/fuel blending operation on-
site. For purposes of the Third Third final rule, it was assumed that the
4-4
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volume reported being received by CWM-Emelle was the volume landfilled because
the actual volume of each waste stream landfilled could not be determined.
One exception to the above assumption involves organic sludges.
CWM-Emelle provided additional information indicating that although the
landfill handling method was reported as final disposition for some waste
streams, only the residuals were landfilled. Based on this information, some
of the organic sludge volumes were assumed not to have been land disposed.
4 1.2 Treatability Analysis
Those wastes that require alternative treatment/recovery because of the
land disposal restrictions, once identified, must be analyzed to determine the
types of alternative treatment required. This process is referred to as
treatability analysis. This section discusses the methodology used to perform
creatability analyses on the wastes identified as requiring alternative
treatment/recovery The results of the treatability analyses conducted on the
waste streams used for this rulemaking are contained in the Commercial
Treatment/Recovery Capacity Data Set.
(1) Waste Characterization
Respondents to the TSDR Survey were asked to provide a limited waste
characterization, including a waste code (or codes) and a waste description
code (A/B codes), for each waste stream being land disposed. The A/B codes
classify wastes, at a minimum, by the following general physical/chemical
categories: inorganic liquids, sludges, solids, and gases and organic
liquids, sludges, solids, and gases. The waste description codes, in some
cases, also provide qualitative information on hazardous constituents or
characteristics. The waste code and A/B code combinations were the primary
source of characterization data used to assess treatability of the wastes.
'*"•'•
A limited number of facilities, however, did not provide these codes. If
during technical review of the survey or facility follow-up, the facility was
either unwilling or unable to provide these codes, engineering judgment was
used to assign a waste description code. All available information from the
survey was used to assign the waste description codes, including the survey
responses and the facility schematic. These sources could provide information
-------
on previous management (e.g., whether the waste was a treatment residual), the
origin of the waste (e.g., mixture rule and derived from rule wastes), and how
the waste was being land disposed (e.g., no liquids in landfills)
In addition, for F and K coded wastes for which the facility did not
provide waste description codes, the waste description in 40 CFR Part 261.
as well as information contained in a report characterizing RCRA waste
streams1, was used to assign the waste to the most common physical/chemical
form. Occasionally, it was not feasible to assign the waste to the most
common form. For example, if the available information indicated that the
waste was commonly a solid but'the waste was being underground injected, in
was assumed to be a liquid rather than a solid.
P and U coded wastes for which the facility did not provide waste
description codes were generally assigned to either off-spec or discarded
products, contaminated soils, or aqueous cleanup residue, depending on the
£
volume, management, and assumed physical/chemical form of each waste.
Assumptions regarding the physical form were based on available information
from the schematic or survey, including the methods of management or other
available information on the chemical constituent such as the Condensed
Chemical Dictionary 2 For example, landfilled wastes were assumed to be
either sludges or solids, and underground injected wastes were assumed to be
liquids. If the volume of undescribed waste being land disposed was large
(i.e., greater than 50 tons for solids or 1,000 gallons for liquids), the
waste was assumed to be contaminated soil or aqueous waste derived from a
cleanup operation. This was based on the assumption that, for economic
reasons, only small volumes of off-spec products are likely to be produced,
and therefore only small volumes would be land disposed.
Characteristic hazardous wastes (i.e., D waste codes) for which the
facility did nut "provide waste description codes were generally a'ssigned a
1 Metcalf and Eddy, Inc. 1985. Technologies applicable to hazardous waste.
Briefing presented for the U.S. Environmental Protection Agency, Office of
Research and Development, Hazardous Waste Engineering Research Laboratory.
Cincinnati, Ohio.
2 Hawley, Gressner G. The Condensed Chemi^1 nictionarv. Van Nostrand
Reinhold Company, New York, New York. 1981.
4-6
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waste description based on the method of land disposal used, any information
from the schematic or other survey responses, and the characteristic
represented by the particular D code as described in 40 CFR, Part 261. For
example, pesticide wastes characteristically hazardous for their toxicity were
generally considered organic, while toxic metal wastes were considered
inorganic.
For the purposes of the TSDR Survey, certain X-codes were created to
describe hazardous waste residuals that result from the on-site management of
many individual RCRA coded wastes that are no longer individually
identifiable. One such X-code"was XLEA, which was used to describe leachate
from hazardous waste landfills. To ensure that the X-codes were not being
misused by respondents and that RCRA codes were being used when it was
reasonable to do so, an attempt was made to "un-X" X-coded wastes that were
reported as land disposed. In the case of XLEA, information from the facilitv
schematic and facility notes, as well as information on the types of wastes
entering the landfill, was used to assign RCRA codes to these wastes.
However, because by definition these wastes should no longer be individually
identifiable, very few X-coded wastes were assigned RCRA codes.
Waste characterization for the CWM-Emelle data was different from TSDR
Survey data base because CWM-Emelle supplied brief descriptions of the wastes
from their Biennial Report instead of A/B codes. The assignment of A/B codes
to each waste stream reported landfilled was based on the RCRA waste code(s)
and description provided by CWM-Emelle. When descriptions were inadequate to
assess the physical/chemical form of the waste, some standard assumptions were
required to assign the A/B codes. The first assumption was that the facility
was operating in compliance with all regulations that were in effect during
1987 These regulations include the ban on liquids in landfills and the
solvents rule, which restricted the land placement of liquid solvent wastes.
This affects the—assignment of A/B codes because it must be assume"a that any
land placed waste stream with a solvent code must either be a sludge or a
solid. Also, during 1987, the Landfilling of free liquids was banned;
therefore, if a description of the waste indicates that the volume reported
was a liquid, it was assumed to have been stabilized using CWM-Emelle's on-
site stabilization process prior to landfilling.
4-7
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For F and K coded wastes, the waste description in 40 CFR, Part 261, as
well as information contained in a report characterizing RCRA waste streams ,
was used to determine the waste's most common physical/chemical form and
assign an A/B code. F006 wastes, wastewater treatment sludges from
electroplating operations, required an additional assumption. Cyanides are
not always used in electroplating operations; therefore, cyanides are not
always present in F006 waste. From the information available on the F006
waste streams land disposed at the CWM-Emelle facility, it is impossible to
determine whether the waste streams contain cyanides. As a worst case
scenario, all F006 waste streams were assumed to contain treatable levels of
cyanides and therefore would require cyanide treatment.
(2) Treatabilitv Grouping/Assigning Alternative Treatment
As previously mentioned, EPA is required to establish treatment standards
for those wastes being restricted from land disposal. EPA has the option of
either specifying the use of a particular technology or setting a
concentration standard based on the performance of the best demonstrated fr
available technology (BOAT). For the Third Third wastes, EPA is generally
promulgating concentration standards based on the performance of BOAT;
however, for some Third Third wastes, EPA is promulgating the use of the BOAT
technology as a method of treatment.
Through use of the characterization data provided by the TSDR Survey, and
the other data (i.e., the waste code and A/B code combinations, and
consideration of the BDAT technologies identified by EPA) wastes were assessed
for treatability and assigned to treatability groups. These treatability
groups were then assigned to BDAT treatment or, in some cases, to alternative
treatment that EPA believes is capable of meeting the BDAT concentration
treatment standard. For example, if the BDAT technology was identified as
rotary kiln incineration, it was assumed that other types of incineration with
the appropria£e^££ed^ system would be able to achieve the BDAT standard. In
addition, for this analysis, reuse as fuel was also assumed to be equivalent
to incineration^(incineration and reuse as fuel have been grouped under the
3 Metcalf and Eddy, Inc. 1985. Technologies applicable to hazardous waste.
Briefing presented for the U.S. Environmental Protection Agency, Office of
Research and Development, Hazardous Waste Engineering Research Laboratory,
Cincinnati, Ohio.
4-f
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general category of combustion), except where the BDAT standard specifies
incineration as a method of treatment (e.g., P064).
Wastes with similar A/B codes that require the same BDAT were assigned
to the same treatability groups. Alternative treatment/recovery technologies
associated with each treatability group, and descriptions of each alternative
treatment/recovery technology are documented in Analysis of Required Capacity
Data for the Third Third Final Rule/
In limited cases, waste streams could not be assigned to the treatability
group representing the BDAT tre'atment because the physical/chemical form of
the wastes were incompatible with the BDAT treatment. In these cases, an
engineering analysis of each waste stream was conducted to assign the waste to
an alternative technology believed capable of achieving the BDAT treatment
standard. The results of these analyses for each waste stream are presented
in the waste code-specific discussions in Section 3 The TSDR Survey does not
*
contain data on the performance of treatment technologies; therefore, several
4 Versar 1989. Analysis of Required Capacity Data for the Third Third
Wastes Final Rule. Appendix C. Prepared for the Office of Solid Waste.
Washington, D.C.: The U.S. Environmental Protection Agency
-------
alternative sources5 and "best engineering judgment" were required to identify
potential alternatives to BOAT.
A similar analysis was conducted for waste groups (i.e., mixed wastes)
Waste groups are hazardous wastes that are described by more than one RCRA
waste code, and they present special treatability problems in that they are
often contaminated with hazardous constituents that may fall under more than
one treatability group (e.g., organics and metals) Such waste groups usually
cannot be assigned to only the BOAT technology for one specific waste type.
Instead, a treatment train that is capable of treating sequentially each waste
type in the group must be developed. Often these treatment trains can be
developed by combining BOAT treatments in sequence, or by adding pre- or
post-treatment steps to the BOAT technology Treatment trains were developed
using the references mentioned above and engineering judgment.
(3) Treatment Residuals
t
Treatment technologies generate residuals that create capacity demand.
For example, some wastes require incineration followed by stabilization of the
incinerator ash and treatment of the scrubber water followed by stabilization
of the resultant wastewater treatment sludge. Based on the TSDR Survey
responses, it was determined that RCRA permitted incinerators have adequate
5 USEPA. 1985. U.S. Environmental Protection Agency Physical-chemical
properties and categorization of RCRA wastes according to volatility. EPA-450/3-
85-007 Research Triangle Park, N.C.: U.S. Environmental Protection Agency
IT Enviroscience, Inc. 1983. Survey of industrial applications of
aqueous-phase activated-carbon adsorption for control of pollutant compounds
from manufacture of organic compounds. Prepared for U.S. Environmental
Protection Agency, Industrial Environmental Research Laboratory.
Metcalf and Eddy. Inc. 1985. Technologies applicable to hazardous waste.
Briefing presented for the U.S. Environmental Protection Agency. Office of
Research and 'Beveiepment, Hazardous Waste Engineering Research^".Laboratory,
Cincinnati, Ohio.
Versar. 1985 -Assessment of treatment technologies for hazardous waste and
their restrictive waste characteristics. Draft Final Report. Prepared for the
Office of Solid Waste. Washington, D.C.: U.S Environmental Protection Agency
USEPA. 1986. U.S. Environmental Protection Agency, Office of Solid Waste.
Best demonstrated available technology (BOAT) ba^round document for F001-F005
spent solvents. Vols. 1 3. EPA/530-SW-86-056. Washington, D.C.: U.S.
Environmental Protection Agency.
4-10
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air pollution control devices (APCD) (including scrubber water treatment at
those facilities with wet scrubbers) and that the facilities considered the
capacity of their APCDs and wastewater treatment systems when determining the
capacity of their incinerators. Therefore, no attempt was made to evaluate
capacity for treatment of scrubber waters. Wastewater treatment sludges and
incinerator ash requiring stabilization, however, were included in the
estimates of treatment residuals requiring capacity
Although the entire waste volume would require incineration, only a
portion of the original volume would require stabilization because the amount
of ash and wastewater treatment sludge generated would be less than the
original volume incinerated. .To account for these changes in the volume
within a treatment train, volume adjustment factors were developed. These
factors were developed using engineering judgment and depend on the type of
treatment and the physical/chemical form of the waste. The factors represent
that percent of the original volume exiting the technology of concern as a
residual. For example, the volume adjustment factor used to estimate the *
volume of ash generated from incineration of an organic sludge is 0.1, or 10
percent of the original volume, and the volume of scrubber water treatment
sludge is estimated at 0.01 or 1 percent of the original volume. Therefore,
if 100 gallons were incinerated, the volume adjustment factor would estimate
that 10 gallons of ash and 1 gallon of wastewater (scrubber water) treatment
sludge would be produced as residuals.
(4) Previous Management
Another important factor considered during the treatability analysis of a
waste was any previous management. Using information contained in the TSDR
Survey and the facility schematics, it was possible to evaluate the previous
management, if any, for wastes being land disposed. Whenever possible, the
previous management of land disposed wastes was evaluated in an attempt to
determine whether the waste had already been treated by the BDAT technology or
by a technology believed capable of achieving the BDAT treatment standard. If
it could be determined that the waste had been previously treated by such a
technology, the waste was assumed to meet the BDAT treatment standard. Such
wastes would therefore not be prohibited from land disposal and were
consequently not included in further analysis of the volume of wastes
requiring alternative treatment/recovery capacity.
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4.2 Determination of Available Treatment Capacity
This section presents a detailed discussion of the analytical methodology
used to determine the estimates of alternative treatment and recovery capacity
available for wastes affected by the Third Third final rule. These processes
include "combustion" in incinerators or industrial kilns, furnaces, and
boilers, and "other treatment/recovery" processes including
solidification/stabilization, solvent and liquid organic recovery for reuse,
metals recovery, acid leaching of sludges, neutralization, and wastewater
treatment for cyanides, metals, and organics. The discussion of combustion
capacity is separate from the discussion of other treatment and recovery
capacity Combustion is predominantly a single unit process system;
therefore, the combustion system analysis does not require locating and
quantifying a limiting unit within a treatment train of unit processes as in
the analysis of other treatment or recovery systems.
*
4.2.1 Determination of Combustion Capacity
(1) Introduction
The combustion data set used for the proposed rule was established to
determine the following information for incineration and reuse as fuel:
(1) the utilized capacity during the base or reference year of 1986; (2) the
maximum capacity during 1986 and any planned changes through 1992; (3) the
unused or available capacity during the periods 1986, 1987, 1988, 1989, and
1990-1992; and (4) the possible interchange of capacity between the various
hazardous waste forms (feed capabilities) for these time periods should excess
capacity exist for certain forms and shortfalls exist for others. The data
set was generated by technical review and engineering evaluation of TSDR
Survey responses and facility schematics, followed by development of the data
set and data consolidation and aggregation to arrive at national totals.
During the public comment period for the proposed Third Third rule, EPA
received several comments on available sludge/solid combustion capacity
Commenters indicated that EPA had omitted available units, included units that
may not actually be available, and incorrectly estimated capacity for some
units. Sources of suggested error included new operating parameters resulting
4-12
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from permits issued since the TSDR Survey, and new hazardous fuel blending and
burning techniques that increase capacity for reusing sludges and solids as
fuel. Since the statutory deadline for incineration permit decisions passed
in November of 1989, EPA agreed that recent permits could have affected
national incineration capacity. As a result. EPA has obtained updated
information from EPA regional and state environmental regualtory offices (and
in a few cases incineration facility's themselves) and has reevaluated
available sludge/solid combustion capacity based on these data for this final
rule. Appendix K provides details of EPA's sludge/solid combustion capacity
verification analysis.
For each fully commercial hazardous waste incinerators, maximum
sludge/solid capacity estimates were determined from the best information
available from regional and/or state regulatory agencies These updates
replace the maximum sludge capacity estimates used for the proposed rule. As
in the proposed rule, the TSDR Capacity Data Set provided 1986 baseline
utilization data used to determine available sludge/solid capacity *
EPA also reevaluated sludge and solid reuse as fuel capacity for the
final rule. However, because reuse as fuel units are usually exempt from RCRA
permitting requirements, capacity data were generally unavailable. In most
cases, EPA was only able to determine if and when a reuse as fuel unit began
burning wastes (i.e., did the unit come on-line in 1989 or 1990 as planned
according to the TSDR Survey) Except for the new facilities discussed in
Appendix K, EPA obtained utilized and maximum capacity estimates from the TSDR
Capacity Data Set for capacity estimates for units that were found to have
come on-line
Because available liquids incineration and reuse as fuel capacity greatly
exceed required capacity. EPA did not completely reevaluate available liquid
incineration fer, in some
cases, EPA uncovered information about available liquid incineration or reuse
as fuel units (e-.g., that a planned facility would be delayed beyond the
planned date reported in the TSDR Capacity Data Set when investigating
sludge/solid capacity. In these cases, the TSDR Capacity Data Set was revised
to reflect the additional information. EPA also recognizes that identified
changes in sludge/solid capacity may have affected (usually reduced) liquid
-------
capacity However, EPA does believe chat continued dependence on the TSDR
Capacity Data Set for liquid combustion capacity would have affected variance
decisions.
For this rule, capacity data from only fully commercial incinerators were
used to determine available capacity Commercial incinerators provide the
most readily available capacity, on a national level, to treat the wastes
currently being considered under the land disposal restriction rules.
The incineration capacity data compiled for this final rule do not
include two other potential categories of waste treatment capacity: limited
commercial and captive facility capacity "Limited commercial" facilities are
those that accept wastes from only a limited number of facilities not under
the same ownership-- in many cases, only from their customers and/or clients
for other products or services. "Captive facilities" are those that manage
wastes from other facilities under the same ownership. Although capacity from
(^
these types of facilities has not been included in this analysis, EPA does not
believe that available capacity from these sources would have affected any of
the variance decisions for this rule.
To determine reuse as fuel capacity, data from facilities with fully and
limited commercial industrial kilns, furnaces, or boilers were included.
During the original review of the data set, EPA discovered that most
facilities with reuse as fuel units described themselves as limited commercial
because they accept waste only from a limited number of facilities not under
the same ownership, primarily fuel blenders or waste brokers. Because fue .
blenders and waste brokers are typically fully commercial, capacity at limited
commercial reuse-as-fuel units was also considered fully commercial.
The revised combusion capacity data set was compared to estimates of
waste volumes TTTrTeTrtly being land disposed that will require comKistion
capacity to determine whether there is adequate incineration and reuse-as-fuel
capacity for alt waste forms. Combustion technologies lend themselves well to
wastes that are difficult to treat by conventional treatment technologies and
are very versatile in that they can treat the various waste forms (liquids,
sludges, solids, and gases) with some interchangeability.
4-14
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(2) Approach and Methodology for the Original Combustion Data Set Used
for the Proposed Rule
The original data sec was generated by review and engineering evaluation
of TSDR Survey responses, transfer of data derived from the questionnaires to
the computer data set, and final consolidation of all facility capacities to
arrive at national totals. In some cases TSDR responses were updated based on
follow-up investigation.
The questionnaires pertaining to incineration and reuse as fuel in the
TSDR Survey were Questionnaire B, "Incineration," and Questionnaire C,
"Reuse as Fuel." A copy of the two questionnaires can be found in the RCRA
docket for this final rule.6 the-'.questionnaires were designed not only to
provide actual utilization and maximum capacity data for each unit at the
facility, but also to provide other design and operational information to
enable the reviewer to evaluate the accuracy of the facility responses. These
other data elements were the following:
I
• Operating/downtime information;
• Percent utilization;
• Maximum practical thermal rating;
• Average heating value of the hazardous and nonhazardous waste being
treated;
• Maximum practical feed rate for each waste form;
• Planned capacity increases/decreases by time period;
• Type of solids that can be fed to the unit; and
• Waste characteristics that exclude or limit acceptance for
treatment.
The above information was used by the reviewer, using mass/he^at balances
and other methods, to evaluate the validity of the facility responses to
utilized and maximum capacity questions. If discrepancies in responses were
identified, the reviewer would attempt to resolve the discrepancies and
6 US EPA. 1987 U.S. Environmental Protection Agency, Office of Solid
Waste. National survey of hazardous waste treatment, storage, disposal, and
recycling facilities. OMB No. 2050-0070.
-------
contact the facility by telephone to verify findings. If agreeable to the
facility, the reviewer would adjust the data.
In addition, technical review of reported capacity data included the
evaluation of incinerator or reuse-as - fuel support systems such as waste feed
handling systems, air pollution control devices, scrubber water treatment
systems, and ash handling systems.
The following types of incinerators were considered in the TSDR Survey:
• Liquid injection
• Rotary (or rocking) kiln
• Rotary kiln with liquid-'inj ection
• Two-stage
• Fixed hearth
• Multiple hearth
• Fluidized bed
• Infrared
• Fume/vapor
• Pyrolytic destructor
• Other (specify)
The following types of units were considered in the Reuse as Fuel
questionnaire :
• Cement kiln
• Aggregate kiln
• Asphalt kiln
• Other kiln (specify)
• Blast furnace
• Sulfur recovery furnace
• Smelting, melting, or refining furnace
• Coke oven
• Other furnace (specify)
• Industrial boiler
• Utility boiler
• Process heater
• Other reuse as fuel (specify).
f "*•"
The computer data set used to consolidate and analyze capacity data from
Questionnaires B^ and C included the following information (brief explanation
of each data element):
1. Facility ID - The USEPA identification number for the facility
2 . Facility Name
4-16
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3. Unit No. data were gathered on a unit basis since some facilities
have more than one incinerator or kiln
4 Commercial status the two commercial categories are facilities
that (1) accept waste from the general public (full commercial) and
(2) accept waste from a limited number of facilities not under the
same ownership (limited commercial); the two noncommercial
categories are facilities that (3) accept waste from facilities
under the same ownership (captive) and (4) manage wastes generated
on-site (on-site)
5. Unit type a code for the type of incinerator or reuse as fuel
unit (as described earlier)
6. Fixed or Mobile unit (F/M)
7 Exempt (Y/N) RCRA permit status
8 Thermal Rating, MBtu/hr
9. Waste Feed Mix (Y/N)
A. liquids
B. sludges * fr
C. solids
D. gases
10 Unique (Y/N): If yes, explain.
11. Capacity 1986
A. Hazardous Waste Quantity this amount represents the quantity
of RCRA hazardous waste treated in the subject unit during
calendar year 1986. This quantity is also referred to as
utilized capacity.
B. Nonhazardous Waste Quantity this is the quantity of
nonhazardous waste that was treated in the same unit, either
concurrently or separately, during 1986
C. Hazardous Waste Maximum Quantity (Capacity) the maximum
quantity of hazardous waste that the treatment unit could have
treated during 1986.
D. AUL_Waste Maximum Quantity (Capacity) - the maximum quantity
of both hazardous and nonhazardous waste that could'have been
treated in 1986.
12. Planned changes or new units, by time period, for 1987 through
1992.
4-17
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The above daca were used co tabulate and develop the original combustion
capacity data set used for the proposed rule. This data set will be discussed
in Section 4.2.3, Development of the Treatment Capacity Data Set and Results.
The data were compiled in a computer data base for more convenient data
management. A copy of the data sheets, along with a description of their use,
can be found in the Procedures for Completing PC Data Sheets for Priority TSDR
Facilities.7
As discussed earlier in this section, revised sludge/solid combustion
capacity data are presented in Appendix K. To make the necessary comparisons
for this analysis, the original facility responses and revised estimates were
converted to one standard unit, volume in gallons. Data reported in short
tons (2,000 Ib/ton) by facilities were consistently converted to gallons by
using a conversion factor of 240 gal/ton (based on the density of water) for
all waste forms other than gases. Gases are reported in standard cubic feet
(SCF) in the initial data and were converted to tons by assuming an average
molecular weight of 29. However, the analyses were done in tt\e appropriate «
units (e.g., tons for solids) and simply converted to gallons for consistent
presentation of units. It is also assumed that the units reported as
operational in 1986 with no closure dates reported will continue to operate
through 1992.
Versar. 1988. Procedures For Completing PC Data Sheets For Priority
TSDR Facilities. Prepared for the Office of Solid Waste. Washington, D.C.:
U.S Environmental Protection Agency
4-18
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4.2.2 Determination of Other Treatment System Capacities
The capacity data set also includes data on treatment systems other than
combustion that may be able to treat Third Third final wastes to their
respective treatment standards. These technologies include solidification/
stabilization and wastewater treatment processes. Because the TSDR Survey and
other data for these treatment processes are reported on a unit process basis,
a method was developed to derive a system capacity from the unit process data.
The results of this analysis were aggregated into a hazardous waste treatment
system capacity data set for comparison with required capacity
For this final rule, capacity data from only fully commercial treatment
facilities were used to determine available capacity. These data represent
the most readily available capacity, on a national level, to treat the waste
that is currently being considered under the land disposal restrictions rule.
The capacity indicated by the commercial data set does not include information
on two other potential categories of waste, treatment capacity, limited
commercial and captive facility capacity. "Limited commercial" facilities are
those that accept wastes from only a limited number of facilities not under
the same ownership-- in many cases, only from their customers and/or clients.
"Captive facilities" are those that manage wastes from other facilities under
the same ownership. Data are not yet available for these two categories to
include in this analysis. However, EPA does not believe that available
capacity from these sources would have affected any of the variance decisions
for this rule.
(1) Unit Process Capacity
The TSDR Survey requested capacity data on a process-specific basis. A
process is defined in the TSDR Survey as one or more units of equipment acting
together to perform a single operation on a waste stream. A system is defined
in the TSDR Surrey—as one or more processes that work together tc>treat a
waste stream. Figure 4-1 presents the process codes provided for the TSDR
Survey respondent to report treatment process information.
4-19
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Figure
PROCESS CODES
These process cod.s were developed specifically for this survey Co describe the on-site hazardous waste management
operations at a facility.
TREATMENT AND RECYCLING
Incineration/thermal treatment
Liquid injection
Rotary (or rocking) kiln
Rotary kiln with a liquid
injection unit
Two stage
Fixed hearth
Multiple hearth
Fluidized bed
Infra-red
Fume/vapor
Pyroltic destructor
Other incineration/thermal
treatment
51
61
71
81
91
101
111
Reuse as fuel
1RF Cement kiln
2RF Aggregate kiln
3FLF Asphalt kiln
<.RF Other Kiln
5RF Blast furnace
6RF Sulfur recovery furnace
7RF Smelting, melting, or refining
furnace
8RT Coke oven
9RF Other industrial furnace
10RF Industrial boiler
11RF Utility boiler
12RF Process heater
13RF Other reuse as fuel unit
Fuel blending
1FB Fuel blending
Solidification
IS Cement or cements/silicate
processes
2S Pozzolanic processes
35 Asphaltic processes
<>S Thermoplastic techniques
5S Organic polymer techniques
6S Jacketing (macro-
encapsulation)
7S Other solidification
Recovery of solvents and liquid
organics for reuse
1SR Fractionation
2SR Batch still distillation
3SR Solvent extraction
4SR Thin-film evaporation
SSR Filtration ' " ~* '
SSR Phase separation
7SR Dessication
SSR Other solvent recovery
(including pretreaiment)
Recovery of metals for reuse
1MR Electrolytic
2MR Ion exchange
3MR Reverse osmosis
'•MR Solvent extraction
5MR Secondary smelting
6MR Liming
7MR Evaporation
8MR Filtration
9MR Sodium borohydnde
10MR Other metals recovery (including
pretreatment)
Waste-Hater treatment
Equalization
1HT Equalization
Cyahrde oxidation
2WT.. Alkaline Chlonnation
3WT Ozone
4WT Electrochemical
5HT Other cyanide oxidation
General oxidation (including
disinfection)
5WT Chlorination
7WT Ozonation
8WT LTV radiation
9WT Other general oxidation
Chemical precipitation
10WT Lime
11WT Sodium hydroxide
12WT Soda ash
13WT Sulfide
14WT Other chemical precipitation
Chromium reduction
15WT Sodium bisulfite
16WT Sulfur dioxide
17WT Ferrous sulfate
18WT Other chromium reduction
Complexed metals treatment (other than
chemical precipiation by pH adjustment)
19WT Complexed metals treatment
Emulsion beraking
20WT Thermal
21WT Chemical
22WT Other emulsion breaking
Adsorption
23WT Carbon adsorption
24WT Ion exchange
25WT Resin adsorption
26WT Other adsorption
Stripping
27WT Air stripping
28WT Steam stripping
29WT Other adsorption
Evaporation
30WT Thermal
31WT Solar
32WT Vapor recompression
33WT Other evaporation
Filtration
3AWT Diatomaceious earth
35WT Sand
36WT Multimedia
37WT Other filtration
Sludge dewatering
38WT Gravity thickening
39WT Vacuum filtration
<
-------
During technical review, three different interpretations by respondents
of the process capacity questions were identified, which determined the method
of system capacity analysis to be used by the reviewer
Case I: Each unit process was reported separately In such a case,
process units must be aggregated into treatment systems so that
the available capacity of the systems can be calculated from
the reported maximum and utilized process capacities.
Case II: The capacity for each process type was combined and reported as
one process by the facility, including when the same process
was conducted in several different units (tanks or surface
impoundments) found in different systems. Responses to the
tank and/or surface impoundment questionnaires were used to
obtain the utilized capacity of each tank and/or surface
impoundment using the process of concern. The maximum capacity
of these tanks and/or surface impoundments was obtained by
facility contact. The unit process data were then aggregated
into treatment systems as in Case I
Case III: The survey respondent reported the entire treatment system as
one process. The utilized and maximum capacities reported for*
the process were used to represent the entire system. If the
individual unit processes that make up the treatment system
could not be identified by examining the facility schematic and
responses to other questions in the survey, the facility was
contacted to obtain that information. The respondent's system
data were then inputted into the capacity data set.
Upon completion of technical review, the following information was
obtained and examined prior to use in the system capacity analysis:
• All processes that compose the system and the units in
which they occur were identified, and a flow diagram was
constructed.
• The amount of hazardous and nonhazardous waste that enters and
leaves the system was quantified so that a mass balance around the
system could be conducted.
• The_utilized and maximum capacities of each unit were ^.
determined.
• if surface impoundments were used in the treatment system,
it was determined whether they met minimum technological
requirements. The effect of closing, retrofitting, or
replacing the surface impoundment with a tank or new
minimum technological surface impoundment on system
capacity was determined.
4-21
-------
Also noted were any other planned changes to the system
and how they might affect the maximum capacity of the unit
and/or system.
(2) Hazardous Waste Treatment/Recovery Svstem Identification
Using the facility schematics, with revisions made as a result of
technical review, hazardous waste treatment/recovery systems and their
respective unit processes were identified. For purposes of the capacity
analysis, a hazardous waste treatment/recovery system was identified by each
hazardous waste entry point into a unit process or sequence of unit processes
The system begins at the process unit where the hazardous waste stream(s)
first enters and consists of all other treatment or recovery process units
downstream from the point of entry
The following examples demonstrate system identification. Figure 4-2
shows a simple hazardous wastewater treatment system. Hazardous waste can
enter the three-unit processes for treatment at only one point, the chemical
precipitation process. Therefore, there is only one hazardous waste treatment
system. The system consists of chemical precipitation, clarification/
settling, and sludge dewatering (filter press) processes. Note that by this
method, recycle streams and nonhazardous waste streams do not affect system
identification.
Figure 4-3 depicts three hazardous waste treatment systems. Three
hazardous waste entry points exist at three different units, which perform
three different processes. The chromium waste treatment system consists of
chromium- reduction, chemical precipitation of chromium, settling, and sludge
dewatering processes. The cyanide waste treatment system consists of a
cyanide oxidation process followed by chemical precipitation of metals, and
settling and dewatering of the resu. ;ant treatment sludge. The third is a
treatment system for a general metal-containing waste consisting of chemical
precipitation ,n£-ae£3ls, settling, and sludge dewatering. Note that the three
systems share some of the same unit processes. These three systems may be
linked together iy competing for the capacity of the shared units. If the
system capacity determination reveals that at least one of the shared units
4-22
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*>
OJ
HAZARDOUS
WASTE (HW)
CHEMICAL
PRECIPITATION
NON-HAZARDOUS
WASTE (NHW)
CLARIFICATION/
SETTLING
FILTRATE RECYCLE
DISCHARGE UNDER
NPDES PERMIT
FILTER
PRESS
FILTER CAKE
TO SECURE
LANDFILL
FIGURE 4-2. FLOW DIAGRAM OF A SIMPLE SYSTEM
-------
HW
100 GAL
HW
100 GAL
CHROMIUM
REDUCTION
(A) ]
A MAX
A UTIL
400 GAL
100 GAL
A AVAIL = 300 GAL
CYANIDE
OXIDATION
(B)
B MAX = 400 GAL
B UTIL = 100 GAL
B AVAIL = 300 GAL
HW
100 GAL
CHEMICAL
PRECIPITATION
(C)
C MAX = 400 GAL
C UTIL = 300 GAL
C AVAILs 100 GAL
CLARIFICATION/
SETTLING
(0)
D MAX = 400 GAL
D UTIL = 300 GAL
D AVAIL = 100 GAL
FILTRATE RECYCLE
240 GAL
DISCHARGE UNDER
NPDES PERMIT
FILTER
PRESS
(E)
E MAX = 75 GAL
E UTIL = 60 GAL
E AVAIL = 15 GAL
FILTER CAKE
TO SECURE
LANDFILL
60 GAL
FIGURE 4-3. FLOW DIAGRAM OF THREE SYSTEMS WITH UNIT PROCESS CAPACITIES
-------
limits the capacity of at least one of the treatment systems, then the three
systems are considered linked systems.
At first glance, Figure 4-4 appears to show two systems because there are
two hazardous waste entry points Upon closer examination, it can be seen
that the two waste streams feed into two different tanks that conduct the same
process in parallel. For purposes of capacity analysis, these two units are
considered one process, with the utilized and maximum capacities of the
"aggregated unit" equal to the sum of the utilized and maximum capacities of
each of the individual units. Therefore, Figure 4-4 depicts only one
hazardous waste treatment system.
(3) Determination, of System Capacity
To determine the capacity of a treatment system, the utilized and maximum
capacity of each unit process must be examined. Where several systems share
unit processes, such as in Figure 4-3, all the unit processes that make up
each of the potentially linked systems must be considered together for this
portion of the analysis.
The capacity determination takes a "snapshot" approach, treating batch
and continuous processes similarly by conducting a mass balance based on the
amount of waste that was treated and could be treated during the entire year.
Survey respondents reported unit capacities as the amount of hazardous waste
entering the unit in 1986, the amount of nonhazardous waste entering the unit
in 1986, the hazardous waste maximum capacity, and all waste maximum capacity.
Volumes from internal recycle streams are considered in the volumes
respondents reported for utilized and maximum unit capacities; therefore,
recycle streams are not considered separately when conducting systems
analysis.
The avail3ETe"~c"apacity for each unit was calculated by subtracting the
utilized capacity from the maximum capacity. The available capacities of
upstream units we're compared with each unit in the process string to locate
the limiting unit(s) in the system(s) The overall system capacity was based
on the restrictions imposed by the limiting unit.
4-25
-------
HW
CHROMIUM
REDUCTION
HW
CHROMIUM
REDUCTION
CHEMICAL
PRECIPITATION
CLARIFICATION/
SETTLING
DISCHARGE UNDER
NPDES PERMIT
SLUDGE TO
SECURE
LANDFILL
FIGURE 4-4. FLOW DIAGRAM OF ONE SYSTEM WITH TWO UNITS
CONDUCTING THE SAME PROCESS
-------
The above methodology assumes a 1986 baseline for hazardous and
nonhazardous wastes already being created in the system and uses only that
portion of the system's remaining capacity that the respondent claims may be
used for hazardous waste treatment. It was assumed that when a survey
respondent reported hazardous waste maximum capacity to be less than all waste
maximum capacity, the respondent had already considered how much nonhazardous
waste would be treated using the system when reporting the hazardous waste
maximum capacity for the unit.
The available capacity of a simple system is the available capacity of
the limiting unit. In Figure 4-5, B is the limiting unit because it has the
smallest available capacity If .one were to try to treat 50 gallons of
additional hazardous waste using this system, there would be a bottleneck at
unit process B because it has room for only 25 additional gallons of waste.
Therefore, the system has only 25 gallons of available hazardous waste
treatment capacity The maximum hazardous waste treatment system capacity
would be 75 gallons--50 gallons of hazardous waste capacity already utilized £
plus the additional 25 gallons of available capacity based on limiting unit B.
When more complicated systems are analyzed, care must be taken that the
total available capacities affecting a downstream unit are considered.
Referring to the unit capacities provided in Figure 4-3, if the amount of
waste being treated in units A and B were increased by 300 gallons in each
unit (i.e., if they were run at their maximum capacities), unit C would become
a bottleneck because it has only 100 gallons of available capacity In other
words, when units directly upstream of the unit of concern are in parallel,
one must add the available capacities of the upstream units before comparing
them with the available capacity of the unit of concern to determine whether
that unit limits (imposes a restriction on) the maximum capacity of the
upstream units (Example: AAvail + BAvail - 600 gal and 600 gal > CAvaiI)
%-*"
The effective available capacity of an upstream unit must be calculated
for comparison with the downstream unit's available capacity in cases where
only a portion of the waste treated in the upstream unit is treated in the
downstream unit of concern. If one refers to Figure 4-3, one must consider
the effluent stream from the clarifier being discharged under an NPDES permit
4-27
-------
NHW
HW
B
A MAX = 100
A UTIL = 50
A AVAIL = 50
B MAX = 100
B UTIL = 75
B AVAIL = 25
C MAX = 130
C UT1L = 75
C AVAIL = 55
FIGURE 4-5. FLOW DIAGRAM WITH UNIT CAPACITIES
-------
when determining the effect of using the available capacity of the clarifier
on the available capacity of the filter press That fraction of waste being
treated in the upstream unit that continues to the downstream unit is
calculated. Under the assumption that as the utilized capacities of these
units are increased, the percent of waste that is treated in both upstream and
downstream units remains constant, the calculated percent is applied to the
reported available capacity of the upstream unit before that capacity is
compared with the available capacity of the downstream unit.
In Figure 4-3, the fractien of waste (D ) going from the clarifier to the
filter press (unit E) is calculated by:
Dp - _ - _ = 0.2.
60
30°
Twenty percent of the waste treated by unit D is treated by unit E. Now the
available capacity of the clarifier affecting the filter press (Deal) is
calculated:
D.ai - (Dp) (D.vail) - (0.2) (100) - 20 gallons.
If the amount of waste being treated in the clarifier is increased to its
maximum capacity, then 20 more gallons of waste will flow to the filter press.
A comparison of the effective available capacities, however, indicates that
the filter press limits the maximum capacity reported for the clarifier:
Eav«ii < Deai or 15 gallons < 20 gallons.
Considering thje^-£-ac_£ that the filter press limits the maximum capacity of the
clarifier, the "new" available capacity of the clarifier must be compared to
the capacity of,the upstream unit, the chemical precipitation unit. The
limiting effect of the filter press on the available capacity of the clarifier
(Dnac) is quantified as follows:
-------
Eava.l I5
n = - = 75 gallons.
nac
Dp 0.2
Based on the comparison of the "new" available capacity of the clarifier with
the upstream chemical precipitation unit and the earlier comparison made
between the chemical precipitation unit and the parallel upstream units, the
filter press limits the capacities of all the other units in the process
string.
At this point, the capacity analysis switches from a unit-by-unit
analysis to a systems analysis: The effect of the limiting unit on the
system's available and maximum capacity is determined. As previously
discussed, Figure 4-3 shows three hazardous waste treatment systems. The
utilized capacity of each of these systems is the amount of waste that enters
each system for treatment. The utilized capacities for the chromium waste
treatment, cyanide waste treatment, and metals waste treatment are 100 gallons
each. The available capacity of each system, as determined by"the effect of *
the limiting unit, is 75 gallons. This quantity, which was derived above,
reflects the effluent stream that exits the systems upstream from the limiting
filter press. The maximum capacity of each system equals the utilized
capacity of the system plus the available capacity of the system. The maximum
capacities of the chromium waste, cyanide waste, and metals waste treatment
systems equal 175 gallons each.
When waste treatment systems share a limiting unit, as shown by the three
systems in Figure 4-3, they compete for the available capacity of that
limiting unit. Because of this competition for limited capacity, these linked
systems cannot all, operate at their maximum capacities, as calculated above.
A linked system can operate at its maximum capacity only if all the other
systems to which it is linked continue to operate at the utilized capacities
reported for Utgfu^^Jhe maximum capacities of each of the linked systems serve
as end points when sufficient capacity for waste volumes requiring treatment
is sought. Using the example shown in Figure 4-3 to illustrate, if additional
chromium waste is sent to the chromium treatment system, then there is that
much less additional capacity for cyanide waste and metals waste treatment.
If the chromium waste treatment system operates at maximum capacity, then no
4-30
-------
additional waste may be sent to the cyanide waste treatment system or the
metals waste treatment system.
To avoid overestimating available treatment capacity, a proportioned
system capacity is calculated for linked systems. The proportioned system
capacity is based on how much of the limiting unit's capacity was devoted to
each linked system during the TSDR Survey base year of 1986 First, the
fractional flow of hazardous waste contributed by each linked system to the
limiting process is determined. Using the systems shown in Figure 4-3:
Fractional flow.,of chrome treatment system - CRp
Fractional flow of cyanide treatment system - CNp
Fractional flow of metals treatment system - tip
CRP
0.333
CNutll + M,tll 100 + 100 + 100 300
CNp = 0.333; Mp - 0.333.
Note that Mutll is the utilized capacity of the metals treatment system,
not the utilized capacity of the chemical precipitation unit. The utilized
capacity of the chemical precipitation unit is the sura total of the utilized
capacities of all three systems.
The effect of the limiting unit on each available system capacity is
proportioned to each system based on the fractional flow determination.
Continuing the calculation to determine the proportioned available capacity
(CRpac) using the above example:
" (CRp) (Dnac) - (0.333) (75) - 25 gallons
"*•<
CNpac - (CNp) (Dnac) - 25 gallons
(Dnac) - 25 gallons.
4-31
-------
Note chat D^ac, che previously calculated "new" available capacity of unit D,
reflects the effect of the limiting unit on all three systems and accounts for
the effluent stream that exits the system before reaching the
limiting unit.
When a linked system has an unshared limiting unit upstream from the
mutually shared limiting unit of the other linked system(s), the system's
calculated proportioned available system capacity must be compared with the
available capacity of its limiting unit. If the limiting unit's available
capacity is less than the calculated proportioned available system capacity,
the final proportioned available system capacity equals the available capacity
of the unshared limiting unit.... The remainder of the calculated proportioned
available system capacity is redistributed to the remaining linked systems
based on how extensively the mutually shared limiting unit is devoted to the
remaining linked systems. In the example shown in Figure 4-3, the limiting
unit for all three systems is the shared filter press; therefore, no
comparisons are necessary .». £-
The proportioned maximum system capacity equals the utilized system
capacity plus the proportioned available system capacity The proportioned
maximum system capacities (PMC) for the systems displayed in Figure 4-3 are:
CRpuc - CR^j. + CRpac - 100 + 25 - 125 gallons
CNmc = 125 gallons
MPN; = 125 gallons.
(4) Projections of Available Capacity
The TSDR Survey requested capacity data for the baseline year 1986 and
for changes or new operations planned through 1992. Projections o^capacity
beyond 1986 were obtained from the data by engineering analysis of information
regarding new treatment/recovery systems being installed and equipment changes
being made to the systems operating in 1986 that result in changes in system
capacity
4-32
-------
For new systems, capacity analyses were conducted as described above and
the results were input into the treatment system data set for the appropriate
years. Reported equipment changes to treatment systems operating in 1986 were
examined to determine their effect on the system capacity If the change
involved the system's limiting unit or influenced the effect of a limiting
unit on the system, then capacity analyses were performed again, incorporating
the capacity changes for that year
42.3 Development of the Treatment Capacity Data Set and Results
The treatment/recovery capacity data set consists of an incineration/
reuse as fuel data set and other treatment systems data set. System capacity
data derived from data reported in the TSDR Survey, as described above, were
entered onto data entry sheets. The purpose of these forms was to standardize
information required for assessing available treatment capacity that was to be
obtained from the TSDR Survey and entered into a computer data set. The data
set is described in a report that can be found in the docket for this final
rule.8 A detailed discussion of the data entry sheets can also be found in
the RCRA docket for this final rule.9 Revised sludge/solid incineration and
reuse as fuel data are presented in Appendix K.
The following discussion presents the results of the incineration/
reuse-as - fuel data set.
(1) Incineration/Reuse - as - Fuel Data Set Results
Table 4-1 summarizes the commercial capacity for hazardous waste
incineration. This table presents the utilized, maximum, and available
capacity for incineration of liquids, sludges, solids, and gases in 1986, and
maximum and available capacity for 1987, 1988, 1989, 1990, and 1991-1992. For
this table, it is assumed that hazardous waste capacity not utilized in 1986,
as well as all» tM^-hazardous waste capacity from 1987 and beyond, >fill be
8 Versar. 1989 The commercial treatment/recovery TSDR survey data set.
Prepared for the Office of Solid Waste. Washington, D.C.: U.S. Environmental
Protection Agency
9 Versar 1988 Technical Review Procedures for Completing PC data sheets
for priority TSDR facilities. Prepared for the Office of Solid Waste
Washington, D.C.: U.S. Environmental Protection Agency
4-33
-------
available for incineration of hazardous wastes, and the impact of previous
land disposal restrictions on available capacity is not considered.
For commercial incinerators of sludges and solids, EPA determined whether
facilities reporting planned capacity additions in 1989/90 had become
operational. At the time of the proposed rule, EPA had information indicating
that Alchem-Tron in Cleveland, Ohio, had come on-line. The available capacity
for this facility was therefore included in the total 1989 available capacity
reported in Table 4-1. All other additional commercial incineration capacity
reportedly planned for 1989/90 was included in the planned 1990-1992 capacity,
leaving only verified available capacity at currently operating facilities in
the 1989 total.
Table 4-2 summarizes the commercial capacity for reusing hazardous wastes
as fuel. The table presents the utilized, maximum, and available capacity for
combustion of liquids, sludges, and solids as fuel in 1986, and maximum and
available capacity for 1987, 1988 1989-1990, and 1991-1992. ^Again, it is -
assumed that hazardous waste capacity not utilized in 1986, and all new
hazardous waste capacity from 1987 and beyond, will be available for
combustion of hazardous wastes, and the impact of previous land disposal
restrictions on available capacity is not considered.
For commercial facilities reportedly reusing hazardous sludges and solids
as fuel, EPA determined that none of the facilities reporting planned capacity
additions in 1989/90 would be operational in 1989. Due to the large number of
facilities reportedly reusing hazardous liquids as fuel, and the excess
available capacity to handle the alternative treatment of land-disposed
wastes, EPA did not include the 1989/90 planned additions to capacity in the
total 1989 available capacity. All additional to commercial capacity for
reuse as fuel reportedly planned for 1989/90 are included in the planned 1990-
1992 capacity total.
4-34
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Table 4-1 Summary of Commercial Hazardous Waste Incineration Capacity
(Million Gallons/Year)
Physical form
of waste
1986
Utilized
Capacity
May
1990
Maximum
Capacity
May
1990
Available
Capaicty3
December
1990
Maximum
Capacity
December
1990
Available
Capacity3
Liquids
Sludges/Solids
Gases
63
20
0
113
77
3
50
57
3
113
161
3
50
141
3
TOTAL
83
193
110
277
194
Source: TSDR Survey results as of May 1990.
* Projected based on maximum capacity for that year minus utilized
capacity for 1986. This considers that capacity not utilized in 1986 and all
new capacity (from 1987 and beyond) will be available for incineration of
hazardous waste being land disposed that may be affected by the land disposal
restrictions.
4-35
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Table 4-2 Summary of Commercial Capacity for Reuse of Hazardous Waste as Fuel
(Million Gallons/Year)
May May Dece'mber December
1986 1990 1990 1990 1990
Physical form Utilized Maximum Ava'ilable Maximum Available
of waste Capacity Capacity Capaicty3 Capacity Capacity3
Liquids 99 376 277 376 277
Sludges/Solids <1 24 24 48 48
TOTAL 99 400 301 424 325
Source: TSDR Survey results as of May 1990.
Projected based on maximum capacity for that year minus utilized
capacity for 1986. This considers that capacity not utilized in 1986 and all
new capacity (from 1987 and beyond) will be available for burning (reuse as
fuel) of hazardous wastes being land disposed that may be affected by the land
disposal restrictions.
4-36
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(2) Development of the Data set for Other Treatment Systems
Data entry sheets were filled out for other treatment systems, and the
data were entered into a computer data set. The data set contains data entry
fields as well as calculated fields used to perform the capacity analysis. A
more detailed explanation of the data fields contained in the data set can be
found in a report in the RCRA docket for this rule.10
The data set has four major treatment system categories, each of
which is divided into subcategories. A more detailed discussion of how and
why the categories were developed is given below. The categories and
subcategories, along with the codes used to represent them within the data
set, are listed as follows:
I. Wastewater Treatment
Process ^ Code *
Cyanide Oxidation WW, CO
Chrome Reduction WW,.CR
Organics/Metals Treatment WW, OMT
Organics/Metals Biological Treatment W, OMB
Sulfide Precipitation WW, SP
General Chemical Precipitation WW, GCP
Steam Stripping WW, SS
Air Stripping WW, AS
Biological Treatment WW, BT
Carbon Adsorption WW, CA
- General Oxidation WW, GO
Wet-Air Oxidation WW, WAO
j:-t{eutralization WWv,, N
10 Versar. 1988. Technical Review Procedures For Completing PC Data Sheets
For Priority TSDR Facilities. Prepared for the Office of Solid Waste.
Washington, D.C.: U.S. Environmental Protection Agency.
4-37
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II. Solvent Recovery
Process
Code
Thin Film Evaporation SR, TF
Fractionation/Distillation SR, FD
Solvent Extraction SR, SE
Other Solvent Recovery SR, 0
III. Metals Recovery
Process Code
High Temperature Metals Recovery MR, HT
Retorting MR, R
y
Secondary Smelting MR, SS
Other Metals Recovery MR, OMR
IV Solidification
Process Code
Solidification SL, S
The maximum, utilized, and available capacities were totaled for all
systems in the data base that fell under each category. Each category is
mutually exclusive so that the capacity of a treatment system is not
double-counted. The treatment systems were categorized by using the computer
to search each record for key unit types (process codes) that would identify
the appropriate_categorv under which the system should be placed."^For
example, records indicating systems with unit types identified by process
codes 2WT, 3WT, 4WT, or 5WT, and 10WT through 15WT were categorized under
cyanide oxidation. These categories are used because the BDAT program has
identified them as treatment methods that may be effective in attaining the
treatment standards established under the solvents and dioxins, California
list, First Third, Second Third and Third Third final rules.
4-38
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(3) Treatment Capacity Data Set Results
Only a subset of the treatment systems that compose the treatment
capacity data set was required by the Third Third promulgated wastes These
treatment categories have been identified under the BDAT program as being
effective in attaining the applicable treatment standards. Under each
category, only commercial treatment•systems were aggregated to establish a
national supply of available treatment capacity that can be used to meet the
demand created by the Land Disposal Restriction Rules.
Table 4-3 presents the maximum, utilized, and available capacities of
commercial treatment systems (pther than combustion) of concern for the
baseline year 1986 and capacity projections through 1992. When making these
projections, the 1986 utilized capacities of these treatment systems were
assumed to remain constant for the subsequent years. Where a linked system
exists, the proportioned system capacity for the linked system is used to
avoid overestimating available capacity. For commercial treatment systems
that closed between 1986 and 1988 or will close in 1989 or 199-0, the utilized!1
capacity of that system remained in the analysis under the assumption that the
waste volumes the system was treating will require commercial capacity
elsewhere. Keeping the utilized capacity of the closed system in the analysis
results in reducing the available commercial capacity for that category The
data in this table were summarized from a report on commercial treatment
capacity.n
1989 data included in the available capacity analysis section of the
Second Third final rule were based on facility projections made in 1987 For
each rule, EPA contacts facilities to verify critical projected capacities
reported in the TSDR Survey Since promulgation of the Second Third final
rule, EPA has contacted some facilities that anticipated additional available
capacity for 1989. Based on the information provided by facility contacts,
EPA has determined that several facilities did not come on-line as^early as
projected. As a result, 1989 data have been adjusted to reflect this new
11 Versar. 1989. The Commercial Treatment/Recovery TSDR Survey Data Set.
Prepared for the Office of Solid Waste. Washington, D.C.: U.S. Environmental
Protection Agency
4-39
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Table 4 - 3 Summary of Commecc i al_ Treatment System Capacities (Million Gallons/Year)11
1986
Technology Description
ALkalin* chlorination
ALkalln* chlorlnation
Maximum
Utilized Capacity
1 .
• .
Aval lable
Capacity
2
20
1987
Max Imum
Capac i ty
3
27
Available
Capac 1 ty
2
20
1988
Maximum
Capaci ty
3
27
Aval lable
Capacity
2
20
1989
Max imum
Capac i ty
3
29
-1990 1991-
Aval lable Maximum
Capacity Capacity
2 3
22 28
1992
Aval labl
Capaci ty
2
22
followed by chemical
precipitation
Biological treatment 75
Biological treatment CBI
followed by chemical
precipi tatlon
Biological treatment 31
followed by carbon
adsorption
Carbon adsorption 5
Carbon adsorption followed 6
by chemical precipitation
Chromium reduction followed 7
by carbon adsorption
followed by chemical
precipication
Cneraical precipitation 115
Cyanide oxidation followed 2
by chemical precipitation
ironjium reducation 148
followed by chemical
precipitation
actionation/distillation 85
88
CBI
37
7
33
31
224
2
292
370
13
CBI
2
28
25
109
<1
145
285
88
CBI
37
7
33
31
224
2
292
366
13
CBI
2
28
25
108
<1
145
281
122
CBI
37
7
42
31
224
70
290
369
47
CBI
2
37
25
109
68
142
284
138
CBI
37
19
106
32
244
70
339
376
63
CBI
14
101
25
129
68
191
291
138
CBI
37
19
74
32
244
70
342
375
63
CBI
14
68
26
129
68
195
290
• Numbers may not add exactly because of rounding. Technologies with utilized maximum and available capacity numbers that have been revised since the Second Third Final
le due to updated information.
-------
Table 4-3 (continued)
Technology Deacrlption Utilized
General chemical oxidation 42/
followed by chromium
reduction followed by
chemical precipitation
High temperature metals 34
recovery
Neutralization 25
Retorting <1
Secondary smelting 49
Solvent extraction 1
Stabilization (cement and 141
pozzolonic )
Steam (tripping 1
Sulfide precipitation 70
Thin film evaporation 43
Treatment of reectivea 1
followed by chromium
reduction fallowed by
chemical precipitation
det air oxidation 0
rfat air oxidation followed 0
by carbon adsorption
•Jet air oxidation followed 0
by chemical precipitation
•Jet air oxidation followed 0
by chromium reduction
1986 1987 1988 1989-1990 1991-1992
Maximum Available Maximum Available Maximum Available Maximum Available Maximum Available
Capacity Capacity Capacity Capacity Capacity Capacity Capacity Capacity Capacity Capacity
71 28 71 28 71 28 71 28 70 28
67 34 67 34 67 34 67 34 67 34
143 117 143 117 61 36 182 157 182 157
<1 <1 <1 <1 <1 <1
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information. Five of the technologies required for the Third Third final rule
were affected by this new information. These technologies include: 1) carbon
adsorption followed by chemical precipitation, 2) neutralization, 3) secondary
smelting 4) stabilization; and 5) alkaline chlorination followed by chemical
precipitation. The capacity analysis incorporating the information obtained
from the facility contacts is presented in Appendix J for alkaline
chlorination followed by chemical precipitation. Details of the facility
contacts are provided in the phone logs (Appendix J). Technologies affected
by additional information include chemical precipitation, chromium reduction
and chemical precipitation, and wet-air oxidation.
In addition to the available capacity revisions mentioned above, EPA also
made revisions based on a redefinition of three technologies required for the
Third Third proposed rule: 1) chemical oxidation followed by chemical
precipitation; 2) biological treatment followed by chemical precipitation; and
3) chemical precipitation. In the Second Third final rule, the BOAT treatment
for several waste codes specified general chemical oxidation and chromium
reduction/chemical precipitation as a required treatment train. As a result,
general chemical oxidation and chemical precipitation and general chemical
oxidation and chromium reduction/chemical precipitation were analyzed
separately For the Third Third rule, however, there are no waste codes that
require general chemical oxidation and chromium reduction/chemical
precipitation. Therefore the distinction between the two technologies is not
necessary for the Third Third final rule.
For multi-source leachate wastewater, EPA proposed concentration
standards based on wet-air oxidation followed by carbon adsorption, or
biological treatment followed by carbon adsorption for organics and chemical
precipitation for inorganics. For the final rule, EPA is promulgating
concentration standards based on biological treatment followed by chemical
precipitation, or wet-air oxidation followed by carbon adsorption followed by
chemical precfptT£trron for organics and inorganics. Hence, a new"^treatment
process, biological treatment followed by chemical precipitation, is added to
the capacity analysis in the final rule.
Finally, for chemical precipitation the capacity numbers reported in this
rule include the utilized, maximum, and available capacity for both chemical
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precipitation and sulfide precipitation. For the Second Third rule, these
technologies were analyzed separately Because this distinction has no
significant impact on the capacity analysis for the Third Third final rule,
however, EPA has consolidated chemical precipitation and sulfide precipitation
into one category, chemical precipitation.
4•3 Capacity Analysis (Comparison of Required and Available Treatment
Capacity)
As previously described, EPA is responsible for determining whether
sufficient capacity exists to meet the requirements of the land disposal
restrictions. This involves the comparison of required and available
capacity Available treatment capacity can be categorized by facility status
as follows:
• On-site (private capacity) facilities that manage only
waste generated on-site.
• Captive capacity facilities that manage only waste from
other facilities under the same ownership.
• Limited commercial capacity facilities that manage waste
from a limited number of facilities not under the same
ownership.
• Commercial capacity facilities that manage waste from
any facility
The data set contains information on commercial capacity (also limited
commercial capacity for reuse as fuel) from baseline year 1986 and information
on planned changes to 1986 management methods and new processes to be
installed from 1987 through 1992. The methodology for determining the amount
of available treatment capacity was described in Section 4.2. Information on
captive capacity was not incorporated into the analysis for this proposed rule
because EPA doesnpt believe that this capacity would have affected the
variance decisions.
Required capacity consists of wastes previously land disposed that will
require treatment to meet a treatment standard prior to being land disposed.
These volumes of waste were identified and underwent treatability analysis, as
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described in Section 4.1. The result of the treatability analysis was the
assignment of waste volumes to treatability subgroups.
The comparison of required and available capacity was performed on a
facility-by-facility basis. This was done to match treatability subgroups
with available capacity of applicable treatment/recovery systems. Available
on-site treatment capacity was matched only to volumes that were previously
land disposed on-site and were determined to require alternative treatment.
If the appropriate treatment/recovery technology was not available on-site, or
if adequate available capacity was not present to manage the waste, then the
remaining volume of waste requiring alternative treatment was aggregated into
a national demand for commerciarl capacity The final aggregate of national
demand was then compared with the final estimates of national commercial
capacity to match treatability subgroups with appropriate treatment
technologies. This methodology was used by EPA to make final determinations
concerning variances.
4-44
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APPENDIX A
MULTI-SOURCE LEACHATE
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APPENDIX A
MULTI-SOURCE LEACHATE
A.I INTRODUCTION
The Hazardous and Solid Waste Amendments (HSWA) of 1984 mandated that
EPA promulgate regulations restricting the land disposal of hazardous wastes.
The land disposal restrictions are effective immediately upon promulgation.
However, the Agency can grant a national variance from the statutory date to
specific wastes if there is insufficient treatment or recovery capacity
available for these wastes. Both the capacity of available treatment or
recovery technologies and the., quantity of restricted wastes currently sent to
land disposal are used to determine whether variances should be granted to
multi-source leachate. This ana-lysis was designed to determine whether
adequate capacity exists to treat multi-source leachate that will become
restricted from land disposal as a result of the Third Third Rule. The
analysis focuses on primary data sources to determine the actual volumes of
multi-source leachate or residuals from the treatment of multi-source leachate
currently going to land disposal and to evaluate whether there is enough
available capacity to treat these wastes.
I
Multi-source leachate is defined as leachate derived from the disposal
of more than one listed or characteristic hazardous waste. Leachate from
characteristic waste is considered multi-source if it exhibits more than one
characteristic. In the Third Third of the land disposal restrictions, such
leachate will be prohibited from land disposal. Residues from treating such
leachate, as well as residues such as soil and ground water that are
contaminated by such leachate, are also subject to land disposal prohibition
under this rule. Leachate deriving from a single source must meet the
standard developed for the waste code from which it is derived and is
therefore not subject to the standards developed for multi-source leachate.
In cases where other restricted wastes not initially present in the leachate
are mixed with the multi-source leachate, any standards applicable to those
other restricted wastes continue to apply
EPA originally imposed a land disposal ban on multi-source leachate
under the First Third of the land disposal restrictions (LDRs) Under the
land ban, multi-source leachate would have to be treated to satisfy all the
standards applicable to the original wastes from which the leachate is derived
(see 53 FR 31146-150 (Aug. 17, 1988)) EPA revisited the issue of multi-
source leachate treatability to address concerns rai-sed by the hazardous waste
management industry, and rescheduled promulgation of a land disposal ban for
multi-source "leachate to the Third Third of the LDRs in order to fully study
the most appropriate section 3004(m) treatment standards for multi-source
leachate (see 54 FR 8264 (January 27, 1989)).
Multi-source leachate is generated primarily at landfills where a
variety of wastes have been land disposed and leachate is eventually created.
This leachate is derived from multiple sources that may no longer be
identified individually. The management of multi-source leachate varies
depending on the age of the generating facility, its regulatory status, the
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physical/chemical composition of the multi-source leachate, the volumes of
leachate generated, and the waste treatment processes used at a particular
facility In general, multi-source leachate can be expected to be generated
at facilities containing landfills which have received a large number of
wastes over time.
The remainder of this Appendix discusses the data bases and the
methodology used in this analysis, highlights the major caveats and
limitations of the analysis, and presents the results of the capacity analysis
of multi-source leachate.
A. 2 DATA SOURCES
This section documents the data sources reviewed for the multi-source
leachate capacity analysis. -These include the TSDR Survey and the TSDR
Capacity Data Set, the Generator"Survey, data submitted by the hazardous waste
management industry, and other data sources. Each are discussed below We
present in the last subsection the data actually used in the analysis.
A.2.1 TSDR Survey and TSDR Capacity Data Set
The TSDR Survey was conducted by EPA in 1986 to collect information o
the management practices at hazardous waste treatment, storage, disposal, an
recycling (TSDR) facilities. The TSDR Capacity Data Set was created from
selected responses to the TSDR Survey The TSDR Capacity Data Set focuses on
the treatment and disposal capacity and on the land disposal volumes of
hazardous wastes. The TSDR Capacity Data Set provides data on disposal
methods at TSDR facilities, such as landfills and surface impoundments, and
the waste volumes associated with each disposal practice at both commercial
and non-commercial facilities.
EPA used the following specific information from the TSDR Survey in the
capacity analysis for multi-source leachate:
The quantity of multi-source leachate generated on-site;
The quantity of multi-source leachate received from off-site;
The quantity of multi-source leachate placed (i.e., treated,
stored, or disposed) in land disposal units (i.e., waste piles,
surface impoundments, landfills, land treatment units, and
underground injection wells); and
The commercial status of the facility.
From the TSDR Capacity Data Set, EPA retrieved waste stream data for
facilities rejujttisg multi-source leachate from hazardous waste landfills
(coded as XLEA) or waste descriptor code B16 (identifying leachate which could
be single source or multi- source), as well as other useful data from both
commercial and non-commercial facilities. EPA used this information to
estimate the quantity of multi-source leachate reported as being generated and
land placed.
A-2
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The Agency also identified all landfills and surface impoundments
(including storage, treatment, and disposal surface impoundments) that did not
report XLEA or B16 (descriptor code for leachate), because there is a
reasonable belief that these facilities may have generated leachate and
zherefore would require further analysis.
In order to show the flow of waste within facilities that manage
hazardous waste, facilities were asked to complete two types of schematics in
the TSDR Survey: (1) a general facility-wide schematic or flow diagram
showing the hazardous waste management activities and operations the facility
has and how they relate to one another; and (2) detailed schematics of the
treatment and recycling operations identified in the general facility-wide
schematic, showing how individual units operate within the system (such as
tanks, surface impoundments, incinerators, and boilers) and how the processes
in these systems relate to one another
The information available -from these schematics includes:
Each treatment or recycling operation available on-site;
The types of processes used to treat and dispose of the wastes:
Number of tanks and surface impoundments in which these processes
occur;
The points in the treatment/recycling/disposal operations in whLch
reagents or chemical additives enter a process; *
The points in the operation in which wastes and/or treatment
residuals enter or exit a process;
Whether wastes are rendered non-hazardous;
The physical form of the waste throughout the processes (e.g.,
dewatered sludge);
The types of hazardous wastes entering the facility from off-site
and points at which residuals that are not managed on-site are
sent off-site.
The origination of the wastes; and
The types of systems where discharges are sent.
A. 2.2 Generator Survey
The Generator Survey was designed to be used in conjunction with the
TSDR Survey This data base contains information on capacity as well as
generated waste streams. All facilities were required to complete
Questionnaire GA, "General Facility Information," and Questionnaire GB,
"Hazardous Waste Characterization." Facilities that completed the TSDR Survey
were only required to submit Questionnaires GA and GB.
From Questionnaire GB, EPA extracted information on Questions 1 through
27 We only requested responses for generators who reported "XLEA" as the
RCRA waste code or reported "B16" (leachate) as the waste descriptor code.
Responses to Questions 1 through 19 provide information on:
The sources of leachate generation;
The quantities of waste generated on-site during 1985 and 1986;
A-3
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The quantities of waste disposed on-site;
The quantities of waste managed on-site;
The general sequences of management operations the leachate went
through on-site during 1986;
The quantities of waste discharged to POTWs or discharged under
NPDES permits; and
The quantities of waste shipped off-site for treatment(s)
performed.
This information was used to identify waste management practices for
leachates.
Questions 20 through 27 provide information on the physical and chemical
characteristics of the leachate. Responses to Questions 20 through 27
provided such information as .metals content and the range in concentration of
other hazardous constituents. This information is used to determine leachate
treatability categories.
A.2.3 Leachate Treatability Study Plan
industry representatives, including Chemical Waste Managemenr
itrf»m*»nr r*f MnTT"h Am*»rirj5 (UM^JA *) Rr*rn*m incr Fprric: Tnrhicf-Ti'ac ^
A team of
(CWM)/Waste Management of North America (WMNA), Browning Ferris Industries
(BFI)/CECOS, DuPont, and Dow Chemical, have provided EPA with information on
treatment of leachate. As part of this effort, the industry representatives
have put together a study plan on leachate. The five tasks comprising the
study plan are:
Task 1 - Characterization of leachate;
Task 2 Full-scale performance evaluation;
Task 3 Bench-scale treatment plant operation;
Task 4 Stabilization of treatment residues and leachate; and
Task 5 - Documentation and reporting.
Of these five tasks, only Task 1 has been completed and submitted to EPA
by all four industry participants. Because of the large amount of
information, these data have been summarized into a more usable format. In
conjunction with the leachate treatability study, the Leachate Treatability
Group surveyed treatment and disposal firms to determine the volumes of
leachate-derived solids produced. These data were submitted to EPA through
Dupont by GSX Chemical Services, Mill Service, Inc., US Ecology. Envirosafe
Management Services, Inc., Dow Chemical, and Casmalia Resources.
A.2.4 Other Data Sources
EPA reviewed documents from the court case Chemical Waste Management,
Inc. (CWM) vs. U.S. EPA and comments from previous land disposal restrictions
rules. However, these data were of limited use in this analysis.
A. 2.5 Data Sources Used in the Analysis
A-4
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The main source of information for the leachate capacity analysis was
derived from the TSDR Capacity Data Set and the TSDR Survey, especially the
facility schematics. Data from the Generator Survey and from the hazardous
waste management industry were also used by EPA.
The information from the Leachate Treatability Study Plan included
little or no data on total quantities treated at the facilities or the
quantity of residuals generated. Also, the summarized data do not provide
information on physical characteristics of the leachate and its treatment
residuals. The leachates are often blended with other waste streams prior to
treatment in a wastewater treatment plant, so that concentrations may drop
significantly after blending with other wastes going to wastewater treatment.
Because of the nature of these study plans, the information was not used in
the capacity analysis. However, EPA did use data submitted by the Leachate
Treatability Group on the voKunes of leachate-derived solids and sludges
generated and land disposed.
The other data sources examined by EPA did not provide specific
information on the generation and management of multi-source leachate that is
needed for this analysis.
A. 3 METHODOLOGY A. £
The objective of this analysis was to determine whether adequate
alternative treatment capacity exists for the volumes of multi-source leachate
that will become subject to the land disposal restrictions. This section
describes how EPA used the data sources described in section A.2 to determine
the volumes of multi-source leachate requiring alternative treatment or
recovery, and to determine whether the available capacity to treat these
wastes is sufficient.
A. 3.1 Determination of Volumes of Multi-Source Leachate Requiring
Alternative Treatment Capacity
The first step in determining whether there is adequate treatment or
recovery capacity for the volumes of multi-source leachate affected by the
land disposal restrictions is to estimate these volumes.
Respondents to the TSDR Survey were asked to identify the quantity of
multi-source leachate (coded as XLEA) going to land disposal units on-site,
being sent to land disposal units off-site, or being received from other
facilities. These data constituted the baseline of EPA's estimates of the
quantity of multi-source leachate actually being land placed.
EPA bel"i«ved -that the volumes of multi-source leachate lanoT*placed could
be larger than the volumes reported in the TSDR Survey Therefore, the Agency
proceeded to identify all the facilities that could generate and potentially
land place mult-i-source leachate, but did not report doing so in the TSDR
Capacity Data Set. This was accomplished using the following steps:
(1) Identifying facilities reporting generation of XLEA in the TSDR
A-5
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Capacity Data Set but no land placement of XLEA;
(2) Identifying facilities reporting descriptor code B16 (leachate)
but no land placement of XLEA;
(3) Identifying facilities reporting generation of XLEA in the
Generator Survey but no land placement of XLEA;
(4) Identifying facilities for which reported volumes of leachate
generated vary significantly between the TSDR Capacity Data Set
and the Generator Survey;
(5) Identifying facilities with landfills or disposal surface
impoundments and "no leachate volumes reported; and
(6) Developing a list of facilities requiring further analysis based
on the previous five steps.
EPA cross-checked the facilities identified in Step 6 with facilities
for which additional data had been submitted by industry, and with a list of
all the commercial landfills and the largest non-commercial Landfills in th*
country The Agency identified 52 facilities that are likely to account for
most of the multi-source leachate generated and land placed in the United
States.
EPA examined facility schematics submitted as part of the TSDR Survey to
determine the actual volumes of multi-source leachate likely to be land
disposed at these facilities. As discussed in Section A.2.1, these schematics
identify all the waste treatment or recycling operations that exist at each
facility and enable the tracking of the generation and management of multi-
source leachate. The Agency used the facility schematics to estimate the
volumes of multi-source leachate residuals land placed at these facilities.
A.3.2 Multi-Source Leachate Categories
The volumes of multi-source leachate that are currently land placed will
require alternative treatment once they become restricted from land disposal
as a result of the rule. The land disposal restrictions apply to two broad
categories of multi-source leachate: wastewaters and nonwastewaters. Within
each of these categories, wastes can be organic, inorganic or mixed. During
the analysis, EPA identified multi-source leachate volumes for only three of
these catego&i***—»
Mixed organic/inorganic wastewaters;
Mixed organic/inorganic nonwastewaters; and
• Inorganic nonwastewaters.
EPA assigned wastes to these categories using the physical/chemical
characteristics of these wastes reported in the Generator survey, descriptor
codes for the wastes reported in the TSDR Survey, information provided as part
A-6
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of the facility schematics, and supplementary data provided by the hazardous
waste management industry
A.3.3 Determination of Treatability Groups
In the proposed rule, EPA proposed two options for the development of
treatment standards for multi-source leachate. Under the first option, EPA
would continue the application of the carry-through principle under which
multi-source leachate must meet the standards established for all the waste
codes from which it is derived.
Under the second option, EPA would establish one set of wastewater
standards and one set of nonwastewater standards for raulti-source leachate;
these standards would also apply to residuals derived from the storage,
treatment or disposal of multi-source leachate.
In the final rule, EPA has.selected the second option. EPA is
promulgating one set of wastewater and one set of nonwastewater treatment
standards. For muLci-source leachate in the form of wastewaters, EPA is
promulgating treatment standards based primarily on wet air oxidation followed
by carbon adsorption followed by chemical precipitation, or biological
treatment followed by chemical precipitation for organic and inorganic
constituents. For multi-source leachate in the form of nonwastewaters, EPA is
proposing a treatment standard based on incineration for orgsnic constituents
and on stabilization for wastes containing inorganic constituents.
A.3.4 Assignment of Waste Volumes to Leachate Categories
EPA used the methodology outlined in Section A.3.1 to assign volumes of
multi-source leachate currently land placed to the six leachate categories
discussed in Section A.3.2. Again, volumes were identified for only three of
these categories. Waste volumes were assigned based on the waste information
provided in the Generator and TSDR surveys, the facility schematics, and
additional data submitted to the Agency by the hazardous waste management
industry In cases where significant volumes could not be readily assigned
using the available information, EPA contacted certain facilities directly to
confirm their current management practices for multi-source leachate. In a
few cases where no additional data could be obtained from primary sources, EPA
used its best engineering judgement to determine the most appropriate category
of multi-source leachate residuals.
A.3.5 Determination of Available Capacity
EPA used the TSDR Capacity Data Set and other capacity data to determine
how much capacity was available to treat the multi-source leacha-te subject to
the land dispbfaTTestrictions. EPA estimated the capacity available to treat
multi-source leachate by computing the capacity available for each of the
treatment technologies used for multi-source leachate prior to the land
disposal restrictions, and by subtracting the capacity required to treat other
wastes subject to the land ban that are listed as California List, Solvents
and Dioxins, First Third, Second Third, and other Third Third wastes (see
Section 2.1.2).
A-7
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A.3.6 Determination of Variances
Finally. EPA determined whether variances would be granted for multi
source leachate in each of the leachate categories by comparing the volumes of
multi-source leachate requiring alternative treatment capacity with the
available capacity in each treatment category In cases where there is
insufficient alternative capacity, the Agency is granting a two-year variance
for multi-source leachate. In cases where there is enough treatment capacity,
the Agency is not granting a two-year variance for multi-source leachate.
A. 4 CAVEATS AND LIMITATIONS
While EPA used all the primary data sources readily available in
analyzing the need for and availability of capacity for treatment of multi
source leachate, the Agency is concerned about data limitations.
This analysis is based on the available information from facilities chat
provided complete information on leachate generation and management. Thus,
the analysis did not address volumes of multi-source leachate wastewater
treatment residuals that may be generated and subsequently land disposed but
that were not reported. The Agency is also concerned that the volumes of
multi-source leachate generation and management reported in the TSDR Survey *
and in the Generator Survey may be smaller than the actual volumes of multi
source leachate currently generated and managed. The TSDR Survey and the
Generator Survey only collected data from active regulated facilities. Multi
source leachate can be generated at closed or unregulated facilities. The
volumes of such leachate were not taken into account in this analysis.
However, the Agency believes that the general pattern of management of
leachate found at the facilities with complete information is representative
of the other facilities.
Also, EPA used engineering judgement to determine whether volumes of
multi-source leachate reported as land placed at some of the facilities for
which schematics were examined contained primarily organic constituents,
inorganic constituents, or a mixture of organics and inorganics. While there
is some uncertainty associated with these assignments, EPA believes that, in
general, they are reasonably accurate.
A.5 SUMMARY OF RESULTS
This section summarizes the key results of the multi-source leachate
capacity analysis.
A. 5.1 ^t^tti^ource Leachate Generation "^*
EPA extracted information from both the TSDR Survey and the Generator
Survey on the quantity of multi-source leachate generated. The information
collected from both data sets is summarized below.
A.5.1.1 TSDR/Generator Surveys
A-8
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The TSDR Capacity Data Set reports volumes of multi-source leachate
generated on-site in two ways. The first method assigns the quantity of waste
associated with more than one RCRA waste code (i.e., waste streams containing
multi-source leachate coded as XLEA and at least one more RCRA waste code) co
each waste code wichin the waste stream. Using this "non-partitioned" method,
the total quantity of waste associated with multi-coded waste streams would be
counted aeainst each contributing waste code. Conversely, the second method
would partition waste streams by the number of waste codes in the waste
stream. For example, if 100,000 gallons of waste were associated with four
waste codes. 25,000 gallons would be attributed to each waste code
In the analysis performed for the proposed rule, twenty one facilities
reported generating multi-source leachate in the TSDR Survey Under the first
approach, multi-source leachate generation at these facilities totals
91.818.900 gallons. Under the .second approach, the quantity of multi-source
leachate is 90,640,200 gallons. As these numbers show, the choice of an
approach for assigning waste volumes does not have a significant impact on
multi-source leachate because most waste streams containing multi-source
leachate do not contain other RCRA codes.
Data from the Generator Survey used in the proposed rule indicated that
seven facilities generated 7,090,938 gallons of XLEA other than B16 t
(leachate) Approximately 4 million gallons was listed as XLEA-B20 and was
generated by a Land Reclamation facility. In addition, 18 facilities reported
generating 133,551,120 gallons of XLEA-B16. Thus, a total of 25 facilities
generated 140,642,058 gallons of multi-source leachate.
For purposes of comparison, EPA also extracted information on facilities
that generated leachate, as described by B16, associated with a waste code
other than XLEA. The Generator Survey indicates that 17 facilities reported
19 such streams, for a total of 62,082,734 gallons. This last group of
leachate wastes are assumed to be single source because they can be traced to
their original waste code. Therefore, they are not included in this analysis.
While performing the multi-source leachate capacity analysis for the
proposed rule, EPA recognized that considerable inconsistencies exist in how
different facilities reported their leachate generation and management. In
addition, several commenters stated that EPA underestimated the volumes of
leachate currently being land disposed.
To address these potential problem areas and to ensure that EPA's
efforts represent a reasonable quantification of the multi-source leachate
universe, EPA performed an expanded capacity analysis for this final rule.
Three steps were'-fraken: ^
(1) For facilities with land-disposed multi-source leachate volumes in
the proposed rule, EPA re-analyzed Survey data and schematics to
confirm volumes used and to identify any volumes that should have
been included.
(2) For facilities with multi-source leachate generation data but for
which no or uncertain volumes were land disposed, EPA re-analyzed
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Survey data and schematics and made engineering assumptions where
possible to address areas of uncertainty.
(3) For facilities with on-site landfills that did not report leachate
generation, EPA raised leachate generation and management
questions by phone. A small set of landfills of this type were
contacted.
A detailed discussion of this analysis is provided on a facility basis
in Attachments A, B, and C to this Appendix.
A. 5. 1.2 Total Leachate Generation
EPA supplemented the data 'from the Surveys with data from the facility
schematics and with additional data received from the hazardous waste
management industry The total quantity of multi-source leachate generation
reported from all available data sources is about 315 million gallons per
vear This quantity constitutes a lower bound on the quantity of multi-source
leachate actually generated.
A.5.2 Multi-Source Leachate Management ^ £.
As mentioned in Section A.3.2, EPA used data from the TSDR and Generator
Surveys, as well as data submitted by the hazardous waste management industry
to characterize the management of multi-source leachate. Understanding the
fate of multi-source leachate after it has been generated is a critical step
in determining the volumes of multi-source leachate currently land placed.
The management of multi-source leachate depends primarily on the
physical form of the leachate and its chemical composition. Facility
schematics indicate that the primary management practices for multi-source
leachate are disposal of the wastewaters under a National Pollutant Discharge
Elimination System (NPDES) permit or discharge to a. publicly owned treatment
works (POTW) The remaining volumes are land placed and are subject to the
LDRs.
Based on data submitted in the TSDR and Generator Surveys, including the
facility schematics and additional data submitted by industry, EPA estimates
that at least 56.9 million gallons of multi-source leachate are land placed
annually (this includes surface disposal and deep-well volumes) This is
approximately an 18 percent increase over the volume reported in the proposed
rule (48.2 million gallons). These volumes will require alternative treatment
or recovery c^pectey as a result of the LDRs. They are examined in more
detail in the next section.
A.5.3 Volumes Requiring Alternative Treatment or Recovery Capacity
EPA made BOAT determinations for two categories of multi-source
leachate: wastewaters and nonwastewaters. Multi-source leachate containing
both organic and inorganic constituents must meet the standards set for both
sets of constituents.
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EPA determined that the majority of all multi-source leachate wastewater
contains both organic and inorganic constituents. For these wastewaters,
therefore, EPA is promulgating treatment-standards primarily based on
biological treatment followed by chemical precipitation or wet air oxidation
followed by carbon adsorption followed by chemical precipitation.
Table A-l presents the volumes of multi-source leachate that are
currently land placed. The Table shows that 73 percent of the multi-source
leachate that is land disposed goes to surface disposal (41 million gallons)
Approximately 15 million gallons of wastewater goes to deep-well injection.
Table A-2 presents the volumes of multi-source leachate that require
alternative treatment or recovery capacity These volumes differ from the
Table A-2 volumes because the'y -include residuals generated during the
treatment of leachate that still'may require further treatment. For example,
ash from an incinerator that handles nonwastewater multi-source leachate will
require stabilization.
A. 5.4 Determination of Variances
Table A-3 presents the capacity available for treating jnulti-source £
leachate. The available capacity is shown for the BOAT technologies
recommended for the treatment of multi-source leachate.
EPA compared the volumes of multi-source leachate requiring alternative
treatment or recovery capacity presented in Section A.5.3 with the available
capacity for the appropriate technologies presented in Table A-3. Table A-&
shows the results of this comparison for multi-source leachate that is surface
disposed and Table A-5 shows the results of this comparison for multi-source
leachate that is deep-well injected.
EPA analyzed the alternative treatment or recovery capacity for two
categories of multi-source leachate: wastewaters and nonwastewaters.
Treatment standards for wastewaters are based primarily on biological
treatment or wet air oxidation and carbon adsorption for organic constituents,
and chemical precipitation for inorganic constituents. Given that there are
very low volumes of surface-disposed multi-source leachate wastewaters and
because there is adequate capacity to treat these wastes using the above
treatment technologies, EPA is not granting a national capacity variance for
surface-disposed multi-source leachate wastewaters.
Concentration standards for nonwastewaters are based primarily on
f. r -^, j
incineration •rwr-'-wastes containing organic constituents and on stabilization
for wastes containing inorganic constituents. EPA is granting a two-year
variance for surface-disposed multi-source leachate nonwastewaters.
The determination of variances for surface-disposed nonwastewaters was
based on the analysis of a limited number of facilities with complete
information on generation and management of leachate. In addition to the
volumes included in the analysis, volumes of multi-source leachate and
residuals from management of leachate (e.g., wastewater treatment residuals)
A-ll
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are generated. However, chese volumes do not affect, the national capacity
variances since the limited data available from other facilities indicated a
similar pattern of management of leachate: wastewaters are managed at
wastewater treatment facilities and non-wastewaters (e.g., residuals) are land
disposed. For these additional facilities, the information available was not
adequate for inclusion in the quantitative analysis, but there was often
sufficient information to determine the type of management for multi-source
leachate. EPA chose to use only data from facilities with adequate
information po establish a firm basis for the evaluation of variances.
The analysis of the quantitative data indicates a need for a variance
for sludge/solid residuals needing incineration. The general information from
other facilities clearly indicates that additional quantities of sludge/solid
residuals are being generated'and land disposed. However, these volumes are
already in the variance category..
EPA is estimating that multi-source leachate containing both organic and
inorganic constituents are currently deep-well injected. The Agency is
proposing a treatment standard for multi-source leachate wastewaters based
primarily on biological treatment followed by chemical precipitation, or wet-
air oxidation followed by carbon adsorption followed by chemical precipitation
for wastes containing organic and inorganic constituents Because there is *
insufficient capacity to treat wastewaters based on these treatment
technologies, EPA is proposing to grant a two-year variance for multi-source
leachate that is deep-well injected.
A-12
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Table A-l
VOLUMES OF MULTI-SOURCE LEACHATE LAND DISPOSED
Multi-Source Surface Deep Well
Leachate Category Disposal Disposal Total
Wastewaters 800,000 15,100,000 15,900,000
Nonwastewaters 41,000,000 0 41,000,000
TOTAL VOLUME .41,800,000 15,100,000 56,900,000
A-13
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Table A-2
VOLUMES OF MULTI-SOURCE LEACHATE REQUIRING
ALTERNATIVE TREATMENT OR RECOVERY CAPACITY
Mulci-Source Surface Deep Well
Leachate Category Disposal Disposal Total
Wastewaters 800,000 15,100,000 15,900,000
Nonwastewaters 45,810,000 300,000 46,110,000
TOTAL VOLUME 46,610,000 15,400,000 62,010,000
A-14
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Table A-3
AVAILABLE CAPACITY FOR TECHNOLOGIES
RECOMMENDED FOR TREATING MULTI-SOURCE LEACHATE
Multi- Source
Leachate Category
BOAT
Technology
Available
Capacity
(million gals/year)
Organic/Inorganic
Wastewaters
Wet Air Oxidation followed
by Carbon Adsorption followed
by Chemical Precipitation
or
Biological Treatment followed
by Chemical Precipitation
13.9
Organic/Inorganic
Wastewaters
Combustion of Sludges/
Solids followed by
Stabilization
21.9
Inorganic Nonwastewaters
Stabilization
478
A-15
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Table A-4
REQUIRED ALTERNATIVE COMMERCIAL TREATMENT/RECYCLING
CAPACITY FOR SURFACE-DISPOSED MULTI-SOURCE LEACHATE
(million gallons/yr)
Available Required
Technology Capacity Capacity Variance
Organic/Inorganic Wastevaters
Wet Air Oxidation followed
by Carbon Adsorption followed 0
by Chemical Precipitation
or <1 NO
Biological Treatment followed
by Chemical Precipitation 13 9
Organic/Inorganic Nonwastewaters
Combustion of
Sludges/Solids followed 21.9 41 YES
by Stabilization
InorEanic Nonwastewaters
Stabilization 478 4.8 NO
A-16
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Table A-5
REQUIRED ALTERNATIVE COMMERCIAL TREATMENT/RECYCLING
CAPACITY FOR DEEP-WELL DISPOSED MULTI-SOURCE LEACHATE
(million gallons/yr)
Available Required
Technology Capacity Capacity Variance
Organic/Inorganic Wastewater
Wet Air Oxidation followed
by Carbon Adsorption followed 0
by Chemical Precipitation
or 15.1 YES
Biological Treatment followed
by Chemical Precipitation 13.1
A-17
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A.5.5 Attachments
Attachment A summarizes the data used in this analysis by facility
Exhibit A-l presents the volumes of multi-source leachate surface-disposed as
well as volumes for which there was generation information but where surface-
disposed volumes did not exist or could not be identified. Exhibit A-2
presents the volumes of multi-source leachate deep-well-disposed.
Attachment B presents EPA's detailed analysis of each facility examined
which reported generating or disposing of multi-source leachate. The analysis
is presented in three sections. Section B-l discusses facilities with
surface-disposed volumes. Section B-2 discusses facilities with deep-well
volumes. Section B-3 discusse"s- facilities for which no land disposed volumes
of multi-source leachate were''identified.
Attachment C presents phone logs of conversations with facilities chat
took place during the analysis.
A-18
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ATTACHMENT A
PRESENTATION OF DATA
SUMMARY OF DATA
-------
EXHIBIT B.1
MULTI-SOURCE LEACHATE (F039) oe-May-90
SURFACE-DISPOSED VOLUMES (GAL/YEAR) o/:i3 PM
THIRD THIRD FINAL RULE
EPA ID
FACILITY NAME
TOTAL
LEACHATE
GENERATED
INORGANIC
NONWASTEWATER
POTENTIALLY
ORG. & INORG.
WASTEWATER
POTENTIALLY
ORG. & INORG.
NONWASTEWATER
ALD000622464 >
CAD000060012
CAD053049490
ILD01 0284248
ILD074411745
LAD000618256
MID980617435
NJD002385730
NYD000818419
NYD002080034
NYD060545209
NYD080336241
OHD087433744
OKD065383376
PAD000429589
PAD000443705
PAD004835146
PAD059087072
PRD980594618
SCD070375985
TXD000835249
TXD069452340
WVD005005509
Chemlbal Waste Management
IT Corp, Panoche Facility
Stauffer Chemical
Chem Waste Mgt - CID landfill
ESL Inc.
Cecos International
Dow Chemical. Salzburg Landfill
DuPont Chambers Works
Ciba-Geigy Corp
GE Watertord
Al Tech Specialty Steel
Cecos International Inc.
Cecos International Inc.
USPCI
GROWS, Inc
Western Berks Refuse Authority LF
Mill Service, Yukon Plant
Mill Service, Inc.
Union Carbide Caribe, Inc
GSX Services of South Carolina
Gulf Coast Waste Disposal
Texas Ecologists, Inc.
Union (Carbide Agric. Prod.
Casmalia Resources
Dow - Michigan Division WWTP
Browning Ferris
Envirosafe - Ohio
Envlrosafe - Idaho
GSX - Ohio
485,690
24,024,000
7,929,120
7,810.899
304,100
160.800
69,888,000
2,966,000
250.000
5,228.880
6,976.080
4.750,000
4,194,000
11.257,125
3,244.730
22,000.000
27,118,800
1.825,000
282,960
312,000
890.000
1,009,500
4,320,000
7,500,000
100,000
48.000
240,000
!•
"»*
485,690
312,000
2,860,800
500,000
5.572,776
10,000
411,360
160.800
20.640,000
1,604,160
5,714.400
300,000
168,000
200,000
20.000
129.360
200.000
29,280
1,200
53,193
258,480
50,000
1,440,000
150.000
247,440
3.360
499,200
-------
EXHIBIT B.1
MULTI-SOURCE LEACHATE (F039)
SURFACE-DISPOSED VOLUMES (GAL/YEAR)
THIRD THIRD FINAL RULE
06-May-90
07:13 PM
EPA ID
FACILITY NAME
TOTAL
LEACHATE
GENERATED
INORGANIC
NONWASTEWATER
POTENTIALLY
ORG. & INORG.
WASTEWATER
POTENTIALLY
ORG. & INORG
NONWASTEWATER
The following (acifilies reoorted no surface-disposed volumes.
ALD004019048
CAD0691 30995
MDD000797365
MID005068507
MID048090633
MID980568711
MOD068521228
OHD068111327
PRD090028101
TXD055141378
WID0761 71008
WID098547854
^ ,
Monsanto Co. Anniston Facility
Hewlett-Packard Co.
BFI
Sundstrand Heat Transfer, Inc
Wayne Disposal Inc Site #2
Ford Motor Co., Allen Park
B.H.S.. Inc
Evergreen Landfill
Merck, Sharp & Dohme, Quimica de
Rollins Environmental Services
Land Reclamation ltd
Metro LF and Dev. Project
102,766
1,741,000
508.200
2.600,000
1,500.000
155,000
175,680
34,853.520
12,096,000
4,000.000
7.878.000
•
TOTALS: 280.437.850
288.000
797.690
41.223.809
DEEP-WELL TOTAL: 34,643.667
TOTAL F039 GENERATION: | 315,081.517 |
Data Sources: TSDR and.Generator Surveys and Data Submitted by Industry
-------
EXHIBIT B.2
MULTI-SOURCE LEACHATE (F039)
DEEP-WELL DISPOSED VOLUMES (GAL/YEAR)
THIRD THIRD FINAL RULE
06-May-90
07.13PM
]
EPA ID
FACILITY NAME
TOTAL
LEACHATE
GENERATED
POTENTIALLY
ORG. & INORG.
WASTEWATER
LAD000618298
LAD01 03951 27
CBI*
Cecos International Inc.
Rollins Environmental Services
Gulf Coast Waste Disposal Auth.
TOTALS:
3.250,000
17,210,880
1,500,000
12,682,787
3,250,000
3,341,520
1,500,000
7,020,160
34,643,667
15,111,680
"Data from CBI facilities have been aggregated with those from several non-CBI
facilities in order to protect the confidential nature of the information.
Data Sources: TSDR and Generator Surveys and Data Submitted by Industry
-------
ATTACHMENT B
PRESENTATION OF DATA
ANALYSIS OF FACILITY DATA
-------
SECTION B-l
Facilities with Surface-Disposed Multi-Source Leachate
This Section presents the information on facilities reporting both the
generation and the surface disposal of multi-source leachate, along with the
rationale for including the volumes of multi-source leachate requiring
alternative treatment capacity in the analysis.
ALD00622464 Chemical Waste Management
Evaluation of the generation and management of multi-source leachate at
this facility involved analysis of the TSDR and Generator Surveys.
Information in the TSDR Survey.', including its schematic, were classified as
Confidential Business Information-(CBI) for this facility. Data in the
Generator Survey, not classified as CBI, indicated that 485,000 gallons of
multi-source leachate are generated. The Generator Survey also reported that
the entire volume generated was land disposed on-site. The presence of both
organic and inorganic constituents is indicated by the data, and the listed
volume of 100 percent water content was used to classify the waste as
wastewater. Thus, 485.000 gallons were assigned as organic/inorganic ^
wastewater that is surface disposed. " *
CAD000060012 IT Corp., Panoche Facility
Evaluation of survey data showed that approximately 24 million gallons
of multi-source leachate are generated. The survey data did not clearly
identify leachate treatment or generation of leachate treatment residuals.
The facility's Generator Survey response did, however, report the on-site
management of leachate in a solar evaporator unit. Based on the TSDR Survey
for this facility, it was determined that two solar evaporators generate 5960
tons of sludge/solid residuals each. These residuals are derived from the
treatment of a liquid stream that included multi-source leachate. EPA assumed
that these sludge/solid residuals (2,860,800) were surface-disposed and are,
therefore, an organic/inorganic nonwastewater leachate volume requiring
alternative treatment.
CAD053049490 Stauffer Chemical
Evaluation of survey data showed that approximately 8 million gallons of
multi- source \Sfrgh.g.E_f- are generated. The survey data indicated th«.t a portion
of the leachate is treated by chemical precipitation in an exempt wastewater
treatment unit (i.e., tanks) After treatment, liquid wastes are discharged
under an NPDES permit. Residuals from this treatment, along with the
remainder of the leachate volume, undergo further treatment in a surface
impoundment. The facility indicated that treatment in the surface impoundment
would be replaced in the future by a wastewater treatment system. EPA assumed
that leachate treatment residuals are generated at this facility, regardless
of which wastewater system is in place. In order to approximate the quantity
A-24
-------
of these residuals, EPA used a formula provided by Envirosafe Management
Services, Inc.1 EPA estimated that approximately 500,000 gallons on
organic/inorganic nonwastewaters derived from leachate treatment will require
alternative treatment capacity
ILD010284248 Chemical Waste Management CID Landfill
The survey data indicated that approximately 7.8 million gallons of
multi-source leachate are generated at this facility Both organic and
inorganic constituents are present in the leachate. The survey data show that
several treatment technologies are applied to the entire leachate volume.
After treatment, liquid wastes are discharged to a POTW under an NPDES permit.
Waste treatment sludges, which" "'amount to approximately 5.6 million gallons,
are land disposed in an on-site landfill. The volume land disposed is
included in this capacity analysis as a multi-source leachate treatment
residual requiring alternative treatment.
ILD074411745 ESL Inc.
According to survey data, this facility generated approximately 300,000
gallons of multi-source leachate in 1986 The survey data indicated that the
leachate is treated on-site, then discharged to a POTW under a NPDES permit:
The facility provided no information on treatment residuals. EPA assumed that
residuals are generated and undergo surface disposal. EPA estimates that
10.000 gallons of sludge are generated through the treatment of leachate at
this facility
LAD000618256 Cecos International, Inc.
This facility currently manages its leachate through deep-well
injection, and is discussed in more detail in Section B-2. Upon review of the
TSDR Survey for this facility, however, EPA determined that approximately
^00,000 gallons of dewatered sludge and filter cartridges are derived from the
treatment of leachate and other wastewaters prior to deep-well injection.
These wastes are sent off-site for disposal, and are assumed to require
alternative treatment capacity for organic/inorganic nonwastewater leachate.
'In a letter to Barbara McGuiness of DuPont, Chambers Works (this letter
was subsequently forwarded to EPA and is included in the Public Docket for
this rule), Envirosafe provided a formula for calculating sludge generation
rates that uses a factor of 275 Ibs. of sludge generated per 1,000 gallons
leachate treated. EPA used this factor to approximate the amount of sludge
generated through leachate treatment when this informational was unavailable.
A-25
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MID980617435 Dow Chemicals Salzburg Landfill
The survey data indicated that 670 tons (160,800 gallons) of leachate-
contaminated soils are disposed in an on-site hazardous waste landfill. The
survey data also indicated that 9.5 million gallons of leachate are generated
from the landfill and accumulated in tanks regulated under the 90-day rule,
and are sent off-site to a wastewater treatment plant operating under an NPDES
permit. The only surface-disposed volume included for this facility was the
160,800 gallons of multi-source leachate contaminated soil reported in the
survey.
NJD002385730 DuPont Chambers Works
The facility schematic from the TSDR Survey indicated that approximately
70 million gallons of waste is contaminated with multi-source leachate and
must be treated. DuPont has submitted data indicating that it generates 240
wet tons/day (approximately 20 million gallons/year) of primary and secondary
sludge. This sludge is currently being landfilled on-site. In the future,
leachate and groundwater will be segregated, and secondary sludges will be
incinerated until an on-site carbon regeneration furnace is on-line. For thij.
analysis, the waste volume being land disposed (20,640,000 gallons) has been
included as organic/inorganic nonwastewater leachate. EPA received a letter
from this facility confirming that both primary and secondary sludges derived
from the treatment of multi-source leachate would continue to be surface-
disposed after May 8, 1990
NYD000818419 Ciba-Geigy Corp
The survey data indicated that approximately 3 million gallons of multi
source leachate is generated by this facility. The survey data also indicated
that all generated leachate is sent off-site to a wastewater pre-treatment
.acility Using the TSDR Survey response for this facility, EPA determined
that the leachate was sent to another Ciba-Geigy facility (EPA ID
NYD098334618) for pre-treatment. Residual from this process were indicated as
6684 tons (1,604,160 gallons) per year This residual volume was included in
the analysis as organic/inorganic nonwastewater leachate.
NYD002080034 GE Waterford ^
The TSDR Survey schematic for this facility indicated that 1,815 gallons
per minute (approximately 954 million gallons per year) of leachate from the
on-site landfill~is sent to an on-site wastewater treatment system. The
survey response, however, indicated that only 250,000 gallons of leachate were
generated. EPA used the information in the schematic for this analysis. From
the wastewater treatment system schematic, it was determined that 23,810 tons
(approximately 5.7 million gallons) of dewatered sludge are sent to a
landfill. Because this volume was derived from the treatment of at least some
A-26
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multi-source leachate, it was included in this analysis as organic/inorganic
nonwastewaters requiring alternative treatment.
NYD0605A5209 Al Tech Specialty Steel
The survey data indicated that approximately five million gallons of
multi-source leachate are generated at this facility. The survey data
indicated that the leachate from an on-site landfill is sent to a wastewater
treatment system where the wastewater is subjected to chromium reduction,
chemical precipitation, and vacuum filtration. The resulting dewatered sludge
is disposed in an on-site landfill, and the effluent is discharged under an
NPDES permit. The dewatered sludge is reported by the facility as being non-
hazardous. EPA assumed, however, that the treatment train used may not meet
all BOAT standards for multi-source leachate. EPA estimated that 500,000
gallons of sludge may require alternative treatment.
NYD080336241 Cecos International Inc.
The survey data indicated that approximately seven million gallons of
multi-source leachate are generated by this facility These wastes are £
treated on-site and the effluent sent to a POTW. Additional information
submitted by Cecos/BFI indicated that approximately 168,000 gallons of filter-
pressed bio-sludge from wastewater treatment is sent off-site for regeneration
and land disposal. This waste volume has been included in the analysis.
OHD087433744 Cecos International, Inc.
The survey data indicated that approximately 5 million gallons of raulti
source leachate are generated at this facility The data, however, provided
no information of the management of these wastes. Upon contacting the
facility, EPA determined that roughly 5 percent of this volume (250,000
gallons) is sent off-site to a deep-well facility The remainder is sent off-
site to various wastewater treatment systems. EPA assumed that these off-site
systems generate residuals that may require alternative treatment. EPA
estimates that 200,000 gallons of organic/inorganic nonwastewaters derived
from the treatment of this facility's leachate may require alternative
treatment capacity
OKD065438376 USPCI
f ^-*"
The survey data indicated that approximately four million gallons of
multi-source leachate is generated by this facility The facility stabilizes
on-site wastewater treatment sludges. This could possibly meet the treatment
standard for inorganic nonwastewaters, however, this would not meet the
treatment standard for organic wastewaters. EPA assumed, therefore that the
treatment of this leachate volume in a wastewater treatment system would
generate roughly 20,000 gallons of sludge requiring alternative treatment.
EPA recognizes that the current treatment system used at this facility may
A-27
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meet BOAT standards. THe affect of using the 20,000 gallon approximation,
however, will not affect the outcome of the capacity analysis.
PAD000429589 Grows, Inc.
The survey data indicated that approximately 11 million gallons of
multi-source leachate are generated by this facility The survey data also
indicated that 539 tons (approximately 130,000 gallons) of filter cake from
the wastewater treatment plant is sent to an off-site landfill without
treatment. This filter cake may require treatment as a nonwastewater prior to
disposal and, therefore, has been included in this analysis. The remaining
effluent is discharged under an NPDES permit and is, therefore, not included
in this analysis.
PAD000443705 Western Berks Refuse Authority
The survey data indicated that approximately three million gallons of
multi-source leachate are generated by an on-site landfill. The survey data
identified that the generated leachate is sent by tank truck to an off-site
hazardous waste treatment plant. EPA assumed this off-site facility generates
treatment residuals that will require alternative treatment. AEPA estimates J.
this volume to be roughly 200,000 gallons.
PAD004835146 Mill Servica Yukon Plant
The survey data indicated that approximately 22 million gallons of
multi-source leachate are generated by this facility. The survey data also
indicated that the multi-source leachate is discharged to a POTW after
Treatment. Data recently submitted to EPA by the facility indicate that 200
tons (48,000 gallons) of metal hydroxide treatment residuals are generated and
disposed. In the analysis, 48,000 gallons of inorganic nonwastewater multi-
source leachate treatment residuals were identified as being surface-disposed
at this facility.
PAD059087072 Mill Service, Inc.
The survey data indicated that approximately 27 million gallons of
multi-source leachate are generated by an on-site surface impoundment. The
leachate is treated on-site, with treatment effluent discharged under a NPDES
permit, and treatment sludges returned to an on-site surface impoundment.
This facility~sopp3rted updated information to EPA indicating that 1,000 tons
(240.000 gallons) of metal hydroxide sludges are generated and land disposed.
These treatment residuals were included in the analysis as inorganic
nonwastewaters.-
PRD980594618 Union Carbide Caribe, Inc.
A-28
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The survey data indicated chat approximately two million gallons of
leachate were generated by this facility The leachate is treated on-site
with the treated effluent being discharged under an NPDES permit. No leachate
residual volumes were reported land disposed by the facility Upon review of
the TSDR Survey for this facility, however, EPA determined that 29,280 gallons
of dewatered sludge carrying the same waste codes as the multi-source leachate
were returned to the landfill. Although the facility indicates that the
sludge is non-hazardous, EPA believes that the sludge may not meet all BOAT
standards for multi-source leachate. This volume, therefore, has been
included in the analysis.
SCD070375985 GSX Services of South Carolina
The survey data indicated that approximately 280,000 gallons of leachate
were generated, and 1,200 gallons land disposed on-site. The survey data
indicated that on-site treatment is available. It was assumed that the 1,200
gallons of waste are leachate treatment residuals, and have been included in
the analysis.
TXD000835249 Gulf Coast Waste Disposal ft
The survey data indicated that approximately 312,000 gallons of multi
source leachate are sent to on-site land treatment. The survey data also
indicated that this practice was to have stopped in 1988. Because it is
uncertain if this practice has stopped, the 312,000 gallons of leachate in the
form of organic/inorganic wastewater have been included in this analysis.
TXD069452340 Texas Ecologists, Inc.
The survey data indicated that 890,000 gallons of multi-source leachate
were generated from an on-site landfill. U.S. Ecology submitted data
indicating that this Texas facility generates solid residuals from the
treatment of leachate and contaminated groundwater. An estimated 48,000
gallons of leachate treatment residuals are generated on an annual basis. The
company is currently working on a "no migration" petition for two Class I
injection wells with the intent of deep-well disposing of site-generated
leachates and groundwater. For this analysis, however, the leachate treatment
residual volumes have been included.
WD005005509 _^JInjLon Carbide Agricultural Production Company **•*
The survey data indicated that approximately one million gallons of
multi-source leachate were generated. The survey data also indicated that
leachate is treated in a wastewater system prior to discharge under an NPDES
permit. Approximately 258,000 gallons of hazardous wastewater treatment
sludge is disposed either in a landfill or off-site in a surface impoundment.
Although this volume resulted from biological treatment, it could not be
A-29
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determined if all BOAT standards could be met. This volume, therefore, has
been included in the analysis.
Casmalia Resources
Casmalia Resources submitted data on leachate generation. The facility
recently lost the use of its surface impoundments and plans on replacing them
with a chemical fixation system. The amount of leachate to be stabilized is
approximately one million gallons per year. EPA assumed that this treatment
would not meet all BDAT standards for multi-source leachate. Assuming the
waste could be treated in a wastewater treatment system, EPA added 50,000
gallons of treatment residuals to the analysis.
Dow Chemical Company. Michigan Division
Dow Chemical submitted data indicating that its Michigan Division
Wastewater Treatment Plant generates both primary and secondary solids from
the treatment of multi-source leachate. Approximately three million gallons
of primary solids are generated from clarification of wastewater treatment
plant's influent stream. Approximately one million gallons of secondary
solids are generated from wasting of activated sludge from the^'aeration basin*
Primary solids are treated on-site by incineration. Secondary solids are land
disposed. This volume of secondary solids, therefore, has been included in
the capacity analysis.
Browning Ferris Industries
Information submitted as part of the Leachate Treatability Study Plan
(see section A.2.3) indicated that 150,000 gallons of leachate treatment
residuals are generated by BFI. Although this information was not connected
to a particular facility, the Study Plan data have been accepted by EPA and
the volume is included in the analysis.
Envirosafe Services of Ohio, Inc.
Envirosafe Services of Ohio, Inc. submitted data on the generation of
leachate treatment residuals. The facility projected generating 1,031 tons of
leachate treatment sludge (247,440 gallons) in 1990. Although these treatment
residuals are currently being sent off-site, no information was submitted on
the off-site management of these treatment residuals. Therefore, >Jihey have
been included in the analysis.
Envirosafe Services of Idaho, Inc.
A-30
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multi-sourcfic leachate, it was included in this analysis as organic/inorganic
nonwastewati'rs requiring alternative treatment.
NYD060545209- Al Tech Specialty Steel
The survey data indicated that approximately five million gallons of
multi-source leachate are generated at this facility. The survey data
indicated that the leachate from an on-site landfill is sent to a wastewater
treatment system where the wastewater is subjected to chromium reduction,
chemical precipitation, and vacuum filtration. The resulting dewatered sludge
is disposed in an on-site landfill, and the effluent is discharged under an
NPDES permit. The dewatered sludge is reported by the facility as being non-
hazardous. EPA assumed, howevfer.r, that the treatment train used may not meet
all BDAT standards for multi-source leachate. EPA estimated that 500,000
gallons of sludge may require alternative treatment.
NYD080336241 Cecos International Inc.
The survey data indicated that approximately seven million gallons of c
multi-source leachate are generated by this facility. These wastes are
treated on-site and the effluent sent to a POTW. Additional information
submitted by Cecos/BFI indicated that approximately 168,000 gallons of filter-
pressed bio-sludge from wastewater treatment is sent off-site for regeneration
and land disposal. This waste volume has been included in the analysis.
OHD0874337AA Cecos International, Inc.
The survey data indicated that approximately 5 million gallons of multi-
source leachate are generated at this facility. The data, however, provided
no information of the management of these wastes. Upon contacting the
facility, EPA determined that roughly 5 percent of this volume (250,000
gallons) is sent off-site to a deep-well facility The remainder is sent off-
site to various wastewater treatment systems. EPA assumed that these off-site
systems generate residuals that may require alternative treatment. EPA
estimates that 200,000 gallons of organic/inorganic nonwastewaters derived
from the treatment of this facility's leachate may require alternative
treatment
OKD0654383
The survey data indicated that approximately four million gallons of
multi-source leachate is generated by this facility. The facility stabilizes
on-site wastewater treatment sludges. This could possibly meet the treatment
standard for inorganic nonwastewaters, however, this would not meet the
treatment standard for organic wastewaters EPA assumed, therefore that the
treatment of this leachate volume in a wastewater treatment system would
generate roughly 20,000 gallons of sludge requiring alternative treatment.
EPA recognizes that the current treatment system used at this facility may
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meet BOAT standards. THe affect of using the 20,000 gallon approximation,
however, will not affect the outcome of the capacity analysis.
PAD000429589 Grows, Inc.
The survey data indicated that approximately 11 million gallons of
multi-source leachate are generated by this facility. The survey data also
indicated that 539 tons (approximately 130,000 gallons) of filter cake from
the wastewater treatment plant is sent to an off-site landfill without
treatment. This filter cake may require treatment as a nonwastewater prior to
disposal and, therefore, has been included in this analysis. The remaining
effluent is discharged under an NPDES permit and is, therefore, not included
in this analysis.
PAD000443705 Western Berks Refuse Authority
The survey data indicated that approximately three million gallons of
multi-source leachate are generated by an on-site landfill. The survey data
identified that the generated leachate is sent by tank truck to an off-site
hazardous waste treatment plant. EPA assumed this off-site facility generates
treatment residuals that will require alternative treatment. ^.EPA estimates *
this volume to be roughly 200,000 gallons.
PAD004835146 Mill Service Yukon Plant
The survey data indicated that approximately 22 million gallons of
multi-source leachate are generated by this facility. The survey data also
indicated that the multi-source leachate is discharged to a POTW after
treatment. Data recently submitted to EPA by the facility indicate that 200
tons (48,000 gallons) of metal hydroxide treatment residuals are generated and
disposed. In the analysis, 48,000 gallons of inorganic nonwastewater multi
source leachate treatment residuals were identified as being surface-disposed
at this facility
PAD059087072 Mill Service, Inc.
The survey data indicated that approximately 27 million gallons of
multi-source leachate are generated by an on-site surface impoundment. The
leachate is treated on-site, with treatment effluent discharged under a NPDES
permit, and treatment sludges returned to an on-site surface impoundment.
This facility-»s«ppi*ed updated information to EPA indicating that"**!, 000 tons
(240,000 gallons) of metal hydroxide sludges are generated and land disposed.
These treatment residuals were included in the analysis as inorganic
nonwastewaters.-
PRD980594618 Union Carbide Caribe, Inc.
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The survey data indicated that approximately two million gallons of
leachate w^gjrf^.generated by this facility. The leachate is treated on-site
with the twlced effluent being discharged under an NPDES permit. No leachate
residual vtffumes were reported land disposed by the facility. Upon review of
the TSDR Survey for this facility, however, EPA determined that 29,280 gallons
of dewatered sludge carrying the same waste codes as the multi-source leachate
were returned to the landfill. Although the facility indicates that the
sludge is non-hazardous, EPA believes that the sludge may not meet all BDAT
standards for multi-source leachate. This volume, therefore, has been
included in the analysis.
SCD070375985 GSX Services of South Carolina
The survey data indicate*-that approximately 280,000 gallons of leachate
were generated, and 1,200 gallons"land disposed on-site. The survey data
indicated that on-site treatment is available. It was assumed that the 1,200
gallons of waste are leachate treatment residuals, and have been included in
the analysis.
TXD000835249 Gulf Coast Waste Disposal M l^_
t- •'
The survey data indicated that approximately 312,000 gallons of multi-'
source leachate are sent to on-site land treatment. The survey data also
indicated that this practice was to have stopped in 1988. Because it is
uncertain if this practice has stopped, the 312,000 gallons of leachate in the
form of organic/inorganic wastewater have been included in this analysis.
TXD069452340 Texas Ecologists, Inc.
The survey data indicated that 890,000 gallons of multi-source leachate
were generated from an on-site landfill. U.S. Ecology submitted data
indicating that this Texas facility generates solid residuals from the
treatment of leachate and contaminated groundwater. An estimated 48,000
gallons of leachate treatment residuals are generated on an annual basis. The
company is currently working on a "no migration" petition for two Class I
injection wells with the intent of deep-well disposing of site-generated
leachates anjb gcoundwater. For this analysis, however, the leachate treatment
residual vttBHIM&have been included.
Carbide Agricultural Production Company "V-
The survey data indicated that approximately one million gallons of
multi-source leachate were generated. The survey data also indicated that
leachate is treated in a wastewater system prior to discharge under an NPDES
permit. Approximately 258,000 gallons of hazardous wastewater treatment
sludge is disposed either in a landfill or off-site in a surface impoundment.
Although this volume resulted from biological treatment, it could not be
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determined if all BOAT standards could be met. This volume, therefore, has
been included in the analysis.
Casmalia Resources
Casmalia Resources submitted data on leachate generation. The facility
recently lost the use of its surface impoundments and plans on replacing them
with a chemical fixation system. The amount of leachate to be stabilized is
approximately one million gallons per year EPA assumed that this treatment
would not meet all BDAT standards for multi-source leachate. Assuming the
waste could be treated in a wastewater treatment system, EPA added 50,000
gallons of treatment residuals to the analysis.
;.»-
Dow Chemical Company. Michigan Division
Dow Chemical submitted data indicating that its Michigan Division
Wastewater Treatment Plant generates both primary and secondary solids from
the treatment of multi-source leachate. Approximately three million gallons
of primary solids are generated from clarification of wastewater treatment
plant's influent stream. Approximately one million gallons o&. secondary |[-
solids are generated from wasting, of activated sludge from the aeration basin.
Primary solids are treated on-site by incineration. Secondary solids are land
disposed. This volume of secondary solids, therefore, has been included in-
the capacity analysis.
Browning Ferris Industries
Information submitted as part of the Leachate Treatability Study Plan
(see section A.2.3) indicated that 150,000 gallons of leachate treatment
residuals are generated by BFI. Although this information was not connected
to a particular facility, the Study Plan data have been accepted by EPA and
the volume is included in the analysis.
Envirosafe Services of Ohio, Inc.
Envirosafe Services of Ohio, Inc. submitted data on the generation of
leachate treatment residuals. The facility projected generating 1,031 tons of
leachate treatment sludge (247,440 gallons) in 1990. Although these treatment
residuals are currently being sent off-site, no information was submitted on
the off-site management of these treatment residuals. Therefore, they have
been included in the analysis.
Envirosafe Services of Idaho, Inc.
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Envirosafe Services of Idaho, Inc., submitted data on its projected
estimates of leachate treatment residuals. The facility projected generating
14 tons of leachate treatment sludges (3,360 gallons) for 1990. The treatment
sludges were originally placed in an evaporation impoundment meeting minimum
technology requirements. This volume has been included in the analysis.
GSX Chemical Services of Ohio, Inc.
GSX Chemical Services of Ohio, Inc. submitted data indicating that it
generates approximately 40 tons per week (499,200 gallons per year) of filter
cake residuals from the treatment of multi-source leachate. The filter cake
residuals are currently being surface-disposed. Their waste volumes,
therefore, have been included in this analysis.
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Section B-2
Facilities With Deep-Well Injected Multi-Source Leachate
This Section presents the analysis of facilities reporting both the
generation and the deep-well disposal of multi-source leachate. For each of
these facilities, a paragraph is included explaining the rationale for
including volumes of multi-source leachate requiring alternative treatment
capacity in the analysis.
LAD000618298 Cecos International, Inc.
The survey data indicated that approximately 3.25 million gallons of
multi-source leachate are sent off-site for disposal to another facility
containing a deep-well injection unit. Therefore, this volume was identified
as being deep-well disposed.
LAD010395127 Rollins Environmental Services
According to the survey data, approximately 17 million gallons of multi
source leachate were generated at this facility. The survey data only
reported the disposal of approximately 3 million gallons of leachate. Because
the facility notes indicated that the leachate is sent to deep-well disposal^
and because of the uncertainty of any other on-site management practices for
leachate, only the reported 3 million gallons of leachate being land disposed
was assigned to deep-well disposal.
Gulf Coast Waste Disposal Authority (GCWDA)
During the comment response to the Third Third proposed rule, GCWDA
submitted data indicating that they are managing 1.5 to 1.8 million gallons of
multi-source leachate through deep-well injection. 1.5 million gallons have
been required to the required capacity estimate for deep-well disposal.
CBI Information
A portion of the deep-well injected volumes were classified as
confidential business information. In order to respect the CBI facilities'
requests that information remain confidential, EPA has aggregated their data
with that from several non-CBI facilities. Detailed descriptions of these CBI
and non-CBP:'data are not included in this discussion.
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Section B-3
Facilities Reporting No Land Disposed Multi-Source Leachate
This section presents the available data for facilities that reported
generation of multi-source leachate but which, for various reasons, do not
result in land disposal. The following facility profiles identify the reasons
for not including volumes of multi-source Leachate requiring alternative
treatment capacity at these facilities.
ALD004019048 Monsanto Co. Anniston Facility
Evaluation of survey data showed that 103,000 gallons of multi-source
leachate were generated at this, facility. Survey notes indicate that multi-
source leachate undergoes biological treatment. The survey reported that
treatment residuals leaving the'treatment unit are delisted. Therefore, no
volumes of multi-source leachate were identified as being land disposed at
this facility
CAD069130995 Hewlett-Packard Co.
Evaluation of survey data showed multi-source leachate being treated by
a groundwater treatment system. The survey data indicated that approximately
1.74 million gallons of leachate were treated by air stripping. Non-hazardous
waste effluent is being discharged under an NPDES permit. No multi-source
leachate were indicated as being land disposed at this facility and no
nonwastewater treatment residuals were reported generated.
MDD000797365 BFI
The survey data identified approximately 500,000 gallons of multi-source
leachate generated at this facility. The only on-site leachate management
practices identified were accumulation and storage in tanks. Because of the
uncertainty of leachate management and solid treatment residual generation, no
leachate waste volumes were identified as requiring alternative treatment for
this facility in the analysis.
MID0050685i';_. •
Investigation of the survey data indicated that approximately 735
million gal'foji^Afc^contaminated ground water were treated in an dM-site
wastewater treatment system. The survey data indicated that the leachate
resulted from the contamination of ground water by leaking on-site tanks.
These tanks contained only F002 wastes. The contaminated ground water
resulting from leaking tanks containing only a single RCRA waste were
considered single-source leachate. Consequently, because the waste did not
fit the definition of multi-source leachate, this volume was not included in
the analysis.
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MID048090633 Wayne Disposal Inc. Site # 2
The survey data identified approximately three million gallons of multi-
source leachate generated by this facility The survey data also indicated
that the multi-source leachate is sent off-site to a POTW for treatment.
Because POTWs are not subject to RCRA Subtitle C requirements, this volume is
not included irr the analysis.
MID980568711 Ford Motor Company. Allen Park
The survey data identified approximately two million gallons of multi-
source leachate generated. This multi-source leachate was reported discharged
to a POTW without prior treatment. Because POTWs are not subject to RCRA
Subtitle C requirements, this volume is not included in the analysis.
MOD068521228 B.H.S., Inc.
The survey data indicated that 155,000 gallons of multi-source leachate
is generated at this facility. The survey data also indicate^ that between *
1986 and 1987, leachate would be either treated by solar evaporation or sent.
off-site to a POTW. and that beginning in 1988 all leachate would be sent off-
site to a POTW. Because POTWs are not regulated under Subtitle C or RCRA,
this volume was not included in the analysis.
OHD068111327 Evergreen Landfill
The survey data indicated that 175,680 gallons of leachate are generated
from an on-site landfill. The survey data also indicated that the leachate is
discharged to a POTW after treatment, however, only accumulation in tanks was
identified as an on-site management practice. No volumes from this facility
were included in the analysis.
PRD090028101 Merck, Sharp & Dohme, Quimica de Puerto Rico
The survey data indicated that approximately 35 million gallons of
multi-sourc» leachate are generated from an on-site landfill at this facility.
The survey/daca identified only F005, XASB, and non-hazardous wastes as being
land dispos»d>. Since the leachate generated by -the landfill is not multi
source but si«sl*-*ource, the waste volume was not included in tht analysis.
TXD055141378 - Rollins Environmental Services
The survey data indicated that approximately 12 million gallons of
multi-source leachate were generated by this facility. The survey data
identified the following treatment processes for multi-source leachate:
storage in tanks followed by on-site treatment, including activated sludges,
A-34
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lime precipitation, flocculation, and gravity thickening. Effluent from
treatment is either discharged under an NPDES permit or recycled to
incineration scrubbing. Treatment residuals are stabilized and disposed in an
on-site landfill. Because of the uncertainty of the waste's composition, it
was believed possible that the stabilized treatment residuals could meet BOAT
standards, and, therefore, their waste volumes were not included in the
analysis.
WID0761710Q8 Land Reclamation Ltd.
The survey data indicated that approximately four million gallons of
multi-source leachate are generated. The survey data also indicated that the
leachate was discharged to a POTW without prior treatment.
t-
WID09854785A Metro Landfill and Development Project
The survey data indicated that approximately eight million gallons of
multi-source leachate are generated. The survey data also indicated that the
leachate is accumulated in tanks then discharged to a POTW without prior
treatment.
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ATTACHMENT C
PHONE LOGS
A-36
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The phone logs provided here outline discussions with facilities that
were contacted due to uncertainty regarding multi-source leachate generation
and management at the particular facility.
4/30/90 Midwest Steel Co. IND016584641
• When aske'd about multi-source leachate management at the facility, the
contact responded that the landfill was a mono-fill, so the leachate is
single-source.
4/30/90 USPCI, Grassy Mountain, Utah UTD991301748
• Lon Griffith indicated that a total of approximately 45 gallons per day
of multi-source leachate are generated at the facility's three RCRA
landfill cells.
• As of May 8, 1990, however, a treatment system will be in place that
will meet the multi-source leachate concentration standards.
• All leachate will be managed on-site.
I
4/30/90 Petroleum Waste, Inc. (under new ownership) CAD980675276
• Marianna Buoni indicated that only 2 litres of leachate are generated
per month at the facility.
• This volume was determined to be insignificant.
4/30/90 Cecos International, Strasburg, Colorado COD991300484
• Lillian DePrimo indicated that this was a new landfill that won't begin
accepting waste until July 1990.
• No leachate generated at this facility.
4/30/90 Cecos International, Zion, Illinois ILD980700728
• Robert Fister was faxed several questions regarding leachate generation
and management.
• The r*«ponse was not received in time to be added to the analysis.
5/1/90 (JgBUS International, tfilliamsburg. Ohio- ^OHD087433744
• Ron Letter indicated that the leachate volume reported in the survey are
approximately correct.
• Leachate is managed at several off-site facilities. Roughly 5 to 10
percent is managed through deep-well injection. The remainder is sent
to off-site wastewater treatment plants or to off-site POTW discharge.
A-37
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ATTACHHENT D
MULTI-SOURCE LEACHATE CLARIFICATION
LETTER SUBMITTED BY DuPONT
March 22, 1990
A-38
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E. I. ou PONT DE NEMOURS & COMPANY
IMCIMIPOIUTU
WILMINGTON. DELAWARE 19898
CHEMICALS AND PIGMENTS DEPARTMENT MaTCh 22 1990
Ms. Jo Ann Bassi
U.S. EPA
Office of Solid Waste
Washington, D.C. 20460
>-
Dear Ms. Bassi:
In September of 1989, I wrote to you to describe the efforts
Du Pont has underway at Chambers Works to manage residuals from
treatment of leachate and contaminated groundwater after May of
1990. In that letter, I described a scheme which would segregate
groundwater and leachate and divert those waste streams to the
secondary treatment phase of the wastewater treatment plant; the. -
secondary sludge could then be thermally treated, either on-site *r
off-site.
This scheme would be a stop-gap measure to allow Chambers Works
to meet the land disposal restrictions standards in May of 1990.
Over the longer term, we will be implementing thermal treatment for
all Chambers Works solids residuals. Once this thermal treatment is
in place, segregation of groundwater and leachate to secondary will
no longer be necessary.
As you know, EPA has proposed to grant a two-year national
capacity variance to solids residuals from treatment of groundwater
and leachate. When this capacity variance is finalized, the
substantial expenditures (estimated to be above $3 million) and
disruption associated with segregating groundwater will be
unnecessary.
In light of these substantially changed circumstances, we have
deferred further work on segregation to secondary treatment.
Because thijfF r«pr«sents a change from the position described in my
September l^|t«r, I thought it necessary to inform you and your
colleagues. :':' __ "^
Sincerely,
Barbara J. McGuinness
Regulatory Affairs
Consultant
BJM:gct
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APPENDIX B
MIXED RADIOACTIVE WASTES CAPACITY ANALYSIS
-------
APPENDIX B
MIXED RADIOACTIVE WASTE CAPACITY ANALYSIS
Mixed radioactive wastes are radioactive and are contaminated with RCRA
hazardous wastes. Consequently, these wastes are subject to dual regulation;
EPA standards apply- to the RCRA hazardous portion and Nuclear Regulatory
Commission (NRC) or Department of Energy (DOE) requirements apply to the
radioactive portion.
The treatment standards promulgated as part of this Third Third Land
t-
Disposal Restriction (LDR) rule^apply to RCRA wastes mixed with radioactive
wastes. EPA, therefore, has undertaken an analysis of the generation and
available alternative treatment capacity for mixed radioactive wastes in an
effort to determine the need for a National Capacity Variance from the LDRs.
This appendix outlines the analysis of mixed radioactive wastes that was
performed, including the methodology used for evaluating the^generation and |u
capacity information. It also presents the results of the analysis and
explains why EPA is granting a two-year national capacity variance to all
surface-disposed mixed radioactive wastes.
This Appendix is essentially the same as that submitted for the Third
Third proposed rule. Minor changes have been made corresponding to changes in
the best demonstrated available technology (BOAT) for certain mixed
radioactive wastes that have been made since the proposed rule. These changes
had no effect on the capacity determinations for mixed radioactive wastes. As
proposed, the final mle grants a two-year national capacity variance to all
mixed radioactive wastes.
One commenter to the proposed rule requested that EPA clarify whether
naturally-occurring radioactive materials (NORM) that are mixed with RCRA
hazardous wastes are also being granted a national capacity variance. EPA
responded Cd-this comment by stating that NORM wastes do not fal^under the
definition of mixed RCRA/radioactive wastes as described in section B.I.I. As
proposed, the national capacity variance would not have been granted to these
wastes. EPA recognized, however, that insufficient alternative treatment
capacity exists to handle RCRA hazardous wastes that are also radioactive. In
this final rule, therefore, EPA is granting a two-year national capacity
variance to RCRA hazardous wastes that are mixed with NORM wastes.
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B.1 Background
B.L.I Definition of Mixed Radioactive Waste
EPA has defined a mixed 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). Because the radioactive and RCRA
hazardous components of mixed radioactive wastes are often inseparable, mixed
radioactive wastes are subject to dual regulation. Atomic Energy Act
requirements apply to the radioactive portion of mixed radioactive wastes, and
the Department of Energy (DOE) ;-or the Nuclear Regulatory Commission (NRC) is
responsible for promulgating and enforcing the requirements. RCRA standards
apply to the hazardous components of these wastes, and EPA is responsible for
promulgating and enforcing the standards.
B.I.2 Status of Mixed Radioactive Wastes in the LDR Program •
Radioactive wastes that are mixed with spent solvents, dioxins, or
California list wastes are subject to the land disposal restrictions already
promulgated for those hazardous wastes. EPA determined that radioactive
wastes that are mixed with First Third and Second Third wastes will be
included in the Third Third rulemaking (40 CFR 268.12(c)). Thus, today's
proposal addresses radioactive wastes that contain First Third, Second Third,
and Third Third wastes.
B.I.3 Distinctions Based on Radioactivity
Radioactive wastes are often separated into groups according to their
relative radioactivity (EPA, March 1987). These divisions include high-level
wastes (HLW). tcansuranic (TRU) wastes, and low-level wastes (LQft.. The
processing of nuclear reactor fuels generates two types of HLW: One resulting
from dissolving^ naval reactor fuel elements to recover enriched uranium; the
other resulting from dissolving nuclear reactor fuel elements to recover
uranium. HLW are generated in a liquid fora, and most HLW have hazardous
chemical characteristics (e.g., corrosivity and toxicity). HLW may also
B-3
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contain listed RCRA hazardous wastes. The primary hazard normally associated
with HLW, however, is their intense radioactivity
TRU wastes contain alpha-emitting transuranic isotopes with half-lives
greater than 20 years. They also contain more than 100 nanocuries per gram of
waste. TRU wastes are generated during the processing, shaping, and handling
of plutonium-containing materials. TRU wastes can be solid (e.g., gloves,
rags, and tools) or liquid and may contain listed or characteristic RCRA
hazardous wastes..
LLW result from more varied processes than either HLW or TRU wastes.
LLW are generated during a variety of activities, and several RCRA waste codes
are potential LLW contaminants; Among the most significant LLW contaminants
are organic chemicals, including-'liquid scintillation cocktails, and lead
metals used for containers and shielding.
Regardless of the type of radioactive constituents that mixed
radioactive wastes contain (i.e., high-level, low-level, or TRU), these wastes
are currently subject to RCRA hazardous waste regulations, including
applicable land disposal restrictions.
B.I.4 Types of Mixed Radioactive Waste Generators
For the purpose of the Third Third capacity analysis, mixed radioactive
waste generators were separated into two groups: DOE facilities and non-DOE
facilities. DOE facilities generate the largest quantities of mixed
radioactive wastes of all groups. For this reason, the capacity analysis
focused primarily on DOE facilities.
Most non-DOE facilities that generate mixed radioactive wastes are
commercial operations. Federal agencies other than DOE, including the
Department of Agriculture and the National Institutes of Health, generate
mixed radioactive wastes that are similar to those generated by other non-DOE
facilities. In general, non-DOE facilities can be grouped into the following
•'-' _ ~^*
categories: • •-"• - -
• Nuclear power plants (e.g., boiling water and pressurized water
reaxtors) ;
• Medical institutions (e.g., research and clinical activities);
• Academic institutions (e.g, non-medical research); and
-------
« Industrial facilities (e.g., pharmaceutical, sealed source, and
irradiator manufacturers, biotechnical manufacturers, spent fuel
storage facilities, and waste processors)
B.2 Information and Data Sources
In support of this capacity analysis, EPA collected the available
information on the generation, characterization, and management of mixed
radioactive wastes.
B.2.1 Department of En«rgy Data
EPA recognized that a large amount of radioactive wastes generated at
DOE facilities are contaminated with RCRA hazardous wastes. In cooperation
with EPA, DOE provided data to EPA outlining the generation, treatment, and
disposal of mixed radioactive wastes at DOE facilities. DOE provided these
data in a series of tables for 21 DOE facilities. The data included volumeTof
waste streams generated annually and in storage, current treatment capacity,
and planned treatment. The majority of the capacity analysis for mixed
radioactive wastes was based on these data.
B.2.2 Information on Non-DOE Mixed Radioactive Waste
In an effort to obtain as much information as possible on the
characterization, generation, and management of non-DOE mixed radioactive
wastes, EPA investigated several potential sources of information. These
included hazardous waste management and generation surveys, summary reports on
mixed radioactive waste generation and management, available state surveys and
interstate-compact surveys and reports, as well as phone contacts with several
state, regional, and federal government officials and industry
representati¥%*p^Attachment B-l to this appendix outlines thes^sources of
information in more detail.
Although,EPA believes that the information collected for this analysis
is the best available, EPA recognizes that the information on the quantities
of mixed radioactive wastes generated and managed at non-DOE facilities could
B-5
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be improved. Consequently, in the proposed Third Third rule the Agency
requested comments by interested parties on the current generation and
management of mixed radioactive wastes. Commenters submitted information char
supports the national capacity variance for mixed radioactive wastes.
B.3 Methodology for Analyzing DOE Data
After analyzing available information, EPA believes that the DOE data
set represented the most accurate information on mixed radioactive wastes
available. EPA also determined that the quantities of mixed radioactive
wastes generated at DOE facilities constitute a significant portion of all
mixed radioactive wastes gene" raped. For these reasons, the capacity analysis
focused primarily on the data provided by DOE. The following sections
describe the methodology and assumptions used in the capacity analysis.
B.3 1 DOE Generation of Mixed Radioactive Waste
*
To estimate the quantity of DOE mixed radioactive wastes, DOE annual
generation rates were combined with the quantities of untreated wastes
currently in storage at DOE facilities (i.e., estimated inventory at the end
of 1989). The annually- generated volumes and volumes in storage were combined
because EPA assumed that all untreated wastes constitute a demand for
treatment .
EPA used DOE estimates of these combined quantities. The DOE
methodology for developing these numbers involved estimating the total
inventory as of July 1989 and adding one half of the annual generation rate to
estimate the total volume of each waste stream requiring treatment at the end
of 1989
*.
B.3.2"Facility-by-Facility Analysis of DOE Mixed Radioactive
Analysis of the data provided by DOE involved grouping waste streams
according to the applicable best demonstrated available technology (BOAT) at
each DOE facility A key issue in this analysis was how to address several of
B-6
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the DOE waste screams that contained more than one RCRA waste code, many with
different- BDATs. To prevent double-counting of waste quantities when grouping
the wastes by treatability group, the streams were divided by assigning an
equal portion of the quantities to each waste code (i.e., straight
proportionality) For example, DOE may have provided a single volume (e.g.,
20,000 gallons) for a stream called "wastewater treatment sludge," which
contains D001, D008-, D009, and D011. Using straight proportionality, each
waste code would be assigned 5,000 gallons. Although this procedure may not
be the most precise way of assigning volumes, EPA believes that the conclusion
of this analysis would remain the same if another, more complex method was
used. --r - .^
B.3.3 DOE Treatment Capacity
Estimates of RCRA treatment capacity were developed using DOE-supplied
data on each of the treatment units located at the various facilities. EPA. •
determined whether the given treatment was a BOAT or BOAT equivalent for the
particular wastes treated in that unit. DOE also provided considerable data
on planned treatment units and their capacities. Because these units will not
be operational until after 1992, they were not included in the capacity
analysis for determining the need for a national variance.
B.3 4 Net Capacity at each DOE Facility
The estimates of mixed radioactive waste generation outlined above were
compared to the available on-site treatment capacity to determine the net
treatment capacity at each DOE facility for each treatment technology
B.3.5 Net DOE Treatment Capacity
To determine the net DOE treatment capacity for each treatability group
across all DOE facilities, aggregates of the quantities of wastes requiring a
particular treatment were subtracted from the available capacity for that
treatment.
B-7
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B.4 Results of DOE Analysis
Analysis of the mixed radioactive waste generation data supplied by DOE
shows that approximately 363 million gallons of radioactive waste mixed with
First Third; Second Third, and Third Third RCRA wastes are affected by this
proposed rule. A variety of waste types and RCRA waste codes are generated,
and several treatability groups were identified. The results of the DOE data
analysis are provided in a series of tables included in Attachment B-2 of this
appendix. The following discussion outlines the major findings of the
analysis and explains the Attachment B-2 tables in more detail.
The DOE data included 3~Q different First, Second, and Third Third RCRA
waste codes. As Section B.3 discussed, the methodology used to analyze these
data involved arranging the DOE wastes requiring the same BOAT into
treatability groups. Tables B-2(a) through B-2(m) in Attachment B-2 provide
facility-specific information on the volumes requiring treatment and the on-
site treatment capacity for each treatability group. The on-"site treatment P~
capacity is based on treatment unit data provided by DOE for each site. In
most cases, the capacity provided represents the "maximum" capacity of the
unit. The "maximum" capacity is the capacity of the unit before subtracting
any capacity currently being used. "Available" capacity refers to the amount
of treatment capacity that a unit offers beyond any treatment that is
currently taking place.
B.4.1 Stabilization
Table B-2(a) lists the on-site stabilization treatment capacity and the
quantity requiring stabilization as treatment for each of the DOE facilities.
In the proposed rule, EPA estimated that approximately 77 7 million gallons of
DOE mixed radioactive wastes require stabilization treatment capacity
Because a prtT"g1jf19, _*\f this volume requires the new BOAT of vitrification,
approximately 14.1 million gallons have been reassigned from stabilization to
vitrification. ^For this final rule, EPA estimates that 63.6 million gallons
of mixed radioactive wastes will require stabilization. This volume accounts
for approximately 40 percent of the non-soil and debris mixed radioactive
wastes generated at DOE facilities that are affected by this rule. EPA has
B-8
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determined that DOE mixed radioactive wastes requiring stabilization include
those containing D005, D006, D007. D008. and D011 nonwastewaters.
EPA determined that 14.4 million gallons of DOE mixed radioactive wastes
contain lead (D008). This quantity is about 8.5 percent of all non-soil and
debris mixed radioactive wastes generated by DOE that are affected by this
rule.
• Based on brief waste descriptions, EPA determined that at least
155,000 gallons of solid lead generated by DOE require surface
deactivation followed by encapsulation, which is discussed in
f-
Section B.4.2.
• EPA was unable to determine whether lead was in a solid, elemental
form for 2.2 million .gallons of mixed radioactive wastes and
assigned this volume to the stabilization BOAT.
*
• EPA determined that -12 million gallons of mixed radioactive wastes
containing lead do not fall into the new BOAT category This
volume was also assigned to stabilization.
A large amount of D009 (mercury) mixed radioactive wastes have been
assigned to the stabilization treatability group. Although stabilization is
not BOAT for D009 mixed radioactive wastes, a large amount of the D009 are
within wastes that contain other metals for which stabilization is BOAT.
Consequently the entire volumes of these streams were assigned to
stabilization.
EPA determined that approximately 2.8 million gallons of stabilization
capacity that is RCRA BDAT is available at DOE facilities. A stabilization
capacity shortfall, therefore, exists for mixed radioactive wastes at DOE
facilities. _
B-9
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B.4.2 Macroencapsulation of Radioactive Lead Solids as a Method of
Treatment.
EPA currently assumes that LDR treatment standards and technologies that
apply to non-radioactive hazardous waste also apply to the hazardous waste
portion of mixed radioactive waste. In a few cases, however, EPA has
determined that special treatment technologies may be required for mixed
radioactive wastes because of the unique properties of the waste. One such
case is solid lead (i.e., elemental lead) that has been radiologically
contaminated. These wastes are commonly associated with lead shielding,
f-
"pigs," bricks, etc. In the;^proposed rule, EPA used surface deactivation
followed by encapsulation as BOAT for this waste. In the final rule, this
BDAR has been changed to "macroencapsulation of radioactive lead solids as a
method of treatment." Analysis of the DOE data regarding lead wastes showed
that at least 150,000 gallons of mixed radioactive wastes in the form of solid
lead require this treatment, as shown in Table B-2(b). ... t
DOE data indicated that solid lead mixed radioactive wastes were
encapsulated at only one facility. The data, however, did not indicate that
the waste first underwent surface deactivation at this facility. In addition,
the DOE data did not identify any available capacity for this treatment. Even
if BOAT treatment is being applied at that one facility, a capacity shortfall
for surface deactivation followed by encapsulation currently exists at DOE
facilities
B.4.3 Combustion
Table B-2(c) provides the results of the analysis of DOE mixed
radioactive wastes requiring combustion capacity. Data provided by DOE listed
wastes containing the following waste codes that require combustion as
treatment: D001, D012, D013, D014, D015, D016, D017, P068, U002^U019, U022,
U213. U220, U2f5'6^ and U239 wastewaters and nonwastewaters. In addition,
volumes for wastes for which the waste codes were described only as "P's" and
"U's" were assigned to the combustion treatability group.
Analysis of the DOE data showed that 1.6 million gallons of First Third,
Second Third, and Third Third mixed radioactive wastes generated at DOE
B-10
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facilities require combustion capacity. This quantity is about one percent of
the non-soil and debris mixed radioactive wastes generated at DOE facilities
affected by this rule.
On-site combustion capacity at DOE facilities is listed as zero gallons
in all cases in Table B-2(c) Unlike the other tables, which list the
"maximum" capacity for on-site treatment units, the combustion capacities
listed in this table represent "available1' capacity. Although DOE does have
operational combustion facilities, EPA has assigned their capacity to mixed
radioactive wastes other than those containing First Third, Second Third, or
Third Third wastes. For the^purposes of the capacity analysis for the Third
Third rule, therefore, available DOE combustion capacity for those radioactive
mixed wastes affected by this rule is zero.
B.4.4 Incineration as a Method of Treatment
In the proposed rule, EPA has proposed incineration with ash IT
stabilization as BOAT for mixed radioactive wastes in the form of hydraulic
oils containing mercury (D009). In the final rule, this BOAT has been changed
to "incineration as a method of treatment." During analysis of the DOE data,
the generation of these wastes could not be distinguished from the generation
of other D009 mixed radioactive wastes. Specific generation numbers,
therefore, could not be developed. No incineration/ash stabilization
treatment capacity was identified, so a capacity shortfall for this technology
currently exists at DOE facilities.
B.4.5 Neutralization
Table B-2(d) provides data mixed radioactive wastes requiring
neutralization as treatment at DOE facilities. Mixed radioactive wastes
exhibiting the^Characteristic of corrosivity (D002) were identified in the DOE
data. These wastes require neutralization as BDAT. Analysis of the DOE data
showed that 26^.2 million gallons of DOE mixed radioactive wastes require
neutralization. This quantity accounts for 15 percent of all non-soil and
debris mixed radioactive wastes generated by DOE affected by this rule.
B-ll
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The DOE data did not contain any specific capacity information for
neutralization. The data, however, indicated that several D002-containing
waste streams are currently being neutralized. In these cases, EPA has used
the annual generation rate as the annual treatment capacity. Although this is
an indirect method of estimating treatment capacity, this method does not
affect the outcome of this capacity analysis. Even with the treatment
capacities assigned in this way, a DOE capacity shortfall of nearly 26 million
gallons was calculated.
B.4.6 Vitrification
Table B-2(e) addresses vitrification. DOE mixed radioactive wastes
requiring vitrification include D004 and D010 nonwastewaters. In addition,
EPA is promulgating "vitrification of high-level radioactive waste as a method
of treatment" for high-level radioactive mixed wastes generated during the
reprocessing of fuel rods. This second category was not included in the
proposed rule, but has been added to the final rule based on data submitted by
DOE. These wastes are generated at six DOE facilities, in a combined amount
of 14 million gallons. Although the DOE data included information on planned
vitrification facilities, no operational vitrification capacity was determined
to be available. Thus, there is a DOE capacity shortfall for this technology
B.4.7 Alkaline Chlorination
Table B-2(f) provides data on DOE mixed radioactive wastes that require
alkaline chlorination. Approximately 800,000 gallons of non-explosive D003
wastes (reactive characteristic) were identified as requiring this treatment.
This quantity accounts for 0.5 percent of non-soil and debris DOE mixed
radioactive wastes affected by this rule.
No alkatfcug .ohlorination capacity is available at DOE facilities Thus,
there is a DOE capacity shortfall.
B-12
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B.4.8 Treacment of Reaccives
Table B-2(g) provides data on DOE mixed radioactive wastes requiring
treatment of reactives. Analysis of DOE data identified explosive D003 wastes
(reactive characteristic) in this category These wastes were reported as
generated at .only one DOE facility, which indicated that 5,000 gallons require
treatment. No treatment of reactives capacity was identified during the
analysis. Thus, there is a DOE capacity shortfall this technology
B.4.9 Chemical Precipitation
Table B-2(h) provides data,,on DOE mixed radioactive wastes requiring
chemical precipitation. Approximately 12,000 gallons of mixed radioactive
wastes require chemical precipitation capacity, including D004, D005, D006,
D008, D009, D010, and D011 wastewaters.
No chemical precipitation treatment capacity was identified in the
analysis of DOE data. There is a capacity shortfall for chemical IF
precipitation currently exists at DOE facilities.
B.4.10 Sulfide Precipitation
Sulfide precipitation is BOAT for mixed radioactive wastes containing
mercury (D009) Table B-2(i) provides information on D009 mixed radioactive
wastewaters at DOE facilities. Approximately 51.6 million gallons of D009
mixed radioactive wastes were identified, accounting for approximately 30
percent of all non-soil and debris DOE mixed radioactive wastes. No sulfide
precipitation treatment capacity was identified, so a DOE capacity shortfall
currently exists.
B.4.H Amalgamation as a Method of Treatment
"*-*
Originally proposed as "amalgamation with zinc," EPA is promulgating
"amalgamation as a method of treatment" in this final rule for mixed
radioactive wastes containing elemental mercury (D009 or U151). It was
difficult to determine, from the DOE data, the quantity of DOE wastes that
B-13
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require this treatment. Table B-2(j) provides information on screams that
could be identified.
Amalgamation capacity was not identified in the DOE data, so a DOE
shortfall in capacity currently exists.
B.4.12 Metals Recovery
Table B-2(k) provides data on DOE mixed radioactive wastes requiring
metals recovery as treatment. Approximately 200,000 gallons of P015 wastes
(beryllium dust) require meta^ls recovery treatment at DOE facilities. This
figure accounts for less tharf one percent of all non-soil and debris DOE mixed
radioactive wastes affected by this rule.
EPA's analysis of DOE data identified no metals recovery capacity
Therefore, there is a capacity shortfall for this technology.
B.4.13 Chromium Reduction followed by Chemical Precipitation w~
Table B-2(l) provides data on DOE mixed radioactive wastes for which'
chromium reduction followed by chemical precipitation is the required
treatment. Analysis of the DOE data identified 1,650 gallons of D007
wastewaters as the only DOE mixed radioactive wastes requiring this treatment.
This waste was generated at only one facility. The analysis, however,
identified no chromium reduction or chemical precipitation treatment capacity
Thus, there is a DOE capacity shortfall for chromium reduction followed by
chemical precipitation.
B.4.14 Alkaline Chlorination Followed by Chemical Precipitation
Tablei,B>2(m) provides data on DOE mixed radioactive wastes for which
alkaline chlorination followed by chemical precipitation is the -^quired
treatment. The following DOE wastes require this treatment: F006 wastewaters
and F007, F008, and F009 nonwastewaters and wastewaters. Approximately
500,000 gallons of mixed radioactive wastes require this treatment. This
volume accounts for approximately 0.3 percent of the non-soil and debris DOE
mixed radioactive wastes affected by this rule.
-------
No alkaline chlorination or chemical precipitation treatment capacity is
available ac DOE facilities. Consequently, there is a capacity shortfall for
this technology.
B.4.15 Alkaline Chlorination Followed by Stabilization of Metals
Alkaline chlorination followed by stabilization of metals is BOAT for
mixed radioactive wastes containing F006 nonwastewaters. Table B-2(n)
provides information on these wastes, and shows that 8 million gallons are
generated at DOE facilities. ^This quantity accounts for 5 percent of all non-
soil and debris DOE mixed radiba^tive wastes affected by this propose ruie.
No capacity for this treatment was identified, so there is currently a DOE
capacity shortfall for alkaline chlorination followed by stabilization of
metals.
I
B.4.16 Soil and Debris *
Through analysis of DOE data, EPA has determined that there are 193
million gallons of soil and debris contaminated with mixed radioactive waste
at DOE facilities. This volume accounts for 53 percent of all DOE mixed
radioactive wastes that may be affected by this rule. Table B-2(o) provides
information on these soil and debris wastes.
Over 98 percent of the soil and debris volume contains "unknown" or
"various" RCRA hazardous wastes. The types of RCRA hazardous wastes listed
for the less than two percent that were characterized included D006, D008,
D009, and D011. One facility listed almost three million gallons of soil and
debris contaminated with D008.
EPA how added a subcategory to debris called "inorganic solid debris."
Mixed radioactive waste in this form have been included in the capacity
analysis fnr g'fcW mH debris. >•
There is no DOE treatment capacity for soil and debris contaminated with
mixed radioactive wastes.
B-15
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B.4.17 Other DOE Wastes
Several wastes identified within the DOE data could not be placed in a
particular treatability group. These "other" wastes amounted to 3.3 million
gallons, or one percent of all DOE mixed radioactive wastes affected by this
rule. Approximately 87,000 gallons of these miscellaneous wastes listed
"various" or "unknown" waste codes, and could not be classified in any
particular treatability group. Two wastes, amounting to 3,210,030 gallons,
were classified as containing "D's," "P's," and "U's." Approximately 2.3
million gallons of this total was identified as high-level fuel process
wastes. The other one million-. gallons were designated as calcinated wastes.
Because of the incomplete classification of these wastes and their unique
physical form, these mixed radioactive wastes were not assigned to a
particular treatability group. Excluding these wastes from the analysis does
not affect the need for a variance, as these volumes would only add to the
capacity shortfalls that have already been identified.
*
B.4.18 DOE Planned Treatment Capacity
Although there are currently DOE capacity shortfalls for all
treatability groups, a considerable number of treatment units are either
planned or under construction at DOE facilities. When operational, these
units will provide significant treatment capacity for a number of treatability
groups. Because these units will not be available in May 1990, however, they
were not considered in the Third Third capacity analysis.
At least 20 different treatment units are expected to come on line at
DOE facilities between 1992 and 2012. These units will include several
incinerators (including controlled air, rotary kiln, and plasma arc),
so lidificataj&tfr units , vitrification and glass/ceramic process units, grout
operations-?£*om« with pre-processing such as sorting and shredding) , and other
treatment unif^JUlfik as evaporators and leaching systems. These^reatment
units will provide significant treatment capacity for mixed radioactive wastes
generated at DOE facilities in the future.
B-16
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B.5 Analysis of Non-DOE Mixed Radioactive Waste Generation
Several types of non-DOE facilities generate mixed radioactive wastes.
In this analysis, EPA used the best available information on the quantities
and characteristics of mixed radioactive wastes generated at non-DOE
facilities. Information used for this capacity analysis include data
developed as part of EPA's Generator Survey, state and interstate compact
surveys and reports, a study developed for the Office of Technology Assessment
of the U.S. Congress, a study developed for the Nuclear Management Resources
Council, and a series of reports developed by Brookhaven National Laboratory
for the Nuclear Regulatory Commission. These data sources vary in detail and
none of them provide national estimates of non-DOE mixed radioactive waste
generation.
To derive non-DOE mixed radioactive waste generation information that
could be compared or combined with DOE data to determine the total demand for
alternative capacity, EPA had to develop:
(1) Rough estimates of the quantities of non-DOE mixed radioactive
wastes generated; and
(2) The types of RCRA hazardous waste codes found in these wastes.
Ideally, the non-DOE mixed radioactive waste generation rates would be linked
to specific RCRA waste codes. With this level of detail, EPA could allocate
non-DOE mixed radioactive wastes to treatability groups and combine this
information with similar data for DOE facilities. In analyzing the available
information, however, EPA found that, in most cases, the information
characterizing non-DOE mixed radioactive wastes was not sufficiently detailed
to perform such an analysis. As described below, several data sources list
"mixed waste? as a single category, while others provide a single, overall
generation ra«»-•rivble listing several potential hazardous contaminants. Thus,
in many cases, EPA could not directly calculate generation rates by RCRA waste
code.
The following discussion outlines the most relevant information.
Attachment B-l provides complete citations for these data sources. The volume
B-17
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analysis and characterization of these wastes were performed simultaneously.
as these pieces of information were usually presented together
EPA's Survey of Hazardous Waste Generators provided limited data on the
quantities of mixed radioactive wastes generated in 1986 It did not,
however, provide generation information by RCRA waste code. The available
Generator Survey information identifies 47 facilities that reported generating
mixed radioactive wastes Nine of these were DOE facilities, which were not
considered in the non-DOE analysis. The remaining 38 facilities were
universities, medical institutions, industrial facilities, and waste
processors. These non-DOE facilities reported generating a total of 307,626
gallons of mixed radioactive waste. An unknown portion of these wastes are
subject to this Third Third rule.
The 1987 Annual Survey Report developed by the State of Illinois
Department of Nuclear Safety included information on two categories of mixed
radioactive wastes:
(1) Liquid scintillation fluids. The report indicates that Illinois
generators shipped 1,444 cubic feet (10,776 gallons) of liquid
scintillation fluids. How these shipped wastes were managed is
discussed in Section B.6.
(2) "Hazardous chemicals." The report indicated that a total of 1,762
cubic feet (about 13,149 gallons) of hazardous chemicals is being
stored by Illinois generators due to technical or regulatory
concerns. The report states that "hazardous chemicals" may be
mixed radioactive wastes. No characterization data were available
beyond this classification. In addition, one generator indicated
that -53,774 cubic feet (401,299) gallons) of radioactive waste
contaminated with hazardous chemicals were being stored for future
shipment or alternative treatment.
-»*«
In addition to the 1987 Illinois report, EPA analyzed information from
the 1988 Illinois LLW Generator Survey. This survey reported that 2,774.3
cubic feet (20,704 gallons) of mixed radioactive wastes were being stored due
to technical or regulatory constraints on disposal. A total of 2,372.2 cubic
feet (17,705 gallons) or about 85 percent of all mixed radioactive wastes in
B-18
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this section of the survey were contaminated with RCRA solvents, for which
land disposal restrictions are already in place. Only 3.000 gallons of the
total, therefore, are affected by this Third Third rule. Potential RCRA
hazardous wastes found in these mixed radioactive wastes included
scintillation fluids (potentially D001) , acidic liquids (potentially D002),
and lead (potentially D008).
The Northwest Interstate Compact on Low-Level Radioactive Waste
Management performed surveys in 1988 and 1989 to obtain information on mixed
radioactive wastes. The 1988 survey indicated an annual mixed radioactive
waste generation rate of 16,173.5 cubic feet (120,698 gallons) for states in
the Compact. Of this total, -15, jOOO cubic feet (111,940 gallons) were reported
as one-time generation by a single generator. The 1989 survey indicated an
annual generation rate of 184 cubic feet (1,373 gallons). Discounting the
15,000 cubic feet generated at the one facility in 1988, the total amount
generated fell by over 80 percent between the 1988 and 1989 surveys.
The Northwest Compact report identified the following potential First %r
Third, Second Third, and Third Third mixed radioactive wastes:
• Chromium waste (potentially D006);
• Lead mixtures (potentially D008);
• Organic corrosives (potentially D002);
• Scintillation fluids (potentially D001); and
• Exchange resins (potentially contain EP toxicity metals)
An informal LLW report by the Massachusetts Association of Radioactive
Waste Generators (cited in Jennrich, March 1989) reports that Massachusetts
annually generates 2932 cubic feet (21,881 gallons) of scintillation
materials, which are potentially affected by this Third Third rule.
The 1988 Connecticut Low-Level Waste Management Plan also contains some
information on mixed radioactive wastes. The 1987 Survey reported the in-
state generation of 1906.4 cubic feet (14,277 gallons) of liquid scintillation
wastes and approximately 20 gallons of lead-contaminated mixed radioactive
wastes.
B-19
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The 1986 Generator Survey conducted by the Northeast Interstate Low
Level Radioactive Waste Commission indicated that mixed radioactive wastes
constitute four percent of the" regional waste stream. The report stated that
4,757 cubic feet (35,500 gallons) were shipped from the region for disposal.
New York and the Midwest Compact surveys addressed mixed radioactive
waste generation that would occur during or after 1993. New York generators
indicated that 4-, 535 cubic feet (32,488 gallons) of mixed radioactive waste
would be generated'in 1993. The Midwest Compact states indicated that 8,372
cubic feet (62,477 gallons) would be generated between January 1993 and
December 1995, which is slightly more than 20,000 gallons per year
The above discussion outlines the best available data from the state and
interstate compact surveys and-.reports. Additional surveys were analyzed (see
Attachment B-l), but the information included in those documents was of
limited use in this capacity analysis.
In addition to the survey data discussed above, EPA also evaluated
information provided in two summary reports, one performed for the Office of
Technical Assessment of the U.S. Congress (Jennrich, March, -"1989. referred to
as the OTA report) and the other for the Nuclear Management and Resource
Council (Jennrich, June 1989, referred to as the NUMARC report) The reports
were useful in identifying the types of wastes generated at non-DOE
facilities. Both reports, however, indicated that the data included do not
represent national estimates of national mixed radioactive waste generation.
The OTA report, which included information from the NUMARC report,
develop seven groups of mixed radioactive wastes based on the hazardous
constituents involved:
• Liquid scintillation cocktails or fluids;
• Organic chemicals/trash;
• Lead and lead decontamination solutions;
• Waste oil/oily trash;
• CFC/CFC concentrates; -^
• Aqueous corrosive liquids; and
• Chromate/cadmium wastes.
B-20
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Of chese seven, only four are potentially affected-by this rule: liquid
scintillation fluids are potentially D001 wastes; lead and lead
decontamination solutions are potentially D008; aqueous corrosive liquids are
potentially D002; and chromates and cadmium are potentially D007 and D006,
respectively The other three categories are either not currently RCRA
hazardous wastes (waste oil) or are wastes for which the LDRs currently are
already in effect (solvents)
In addition to the four categories listed above, investigation of the
NUMARC report also identified reactive chemicals as potential D003 mixed
radioactive wastes. Information on the quantities of these wastes generated,
however, were not available ."""=• -.-,
In an effort to roughly estimate the non-DOE mixed radioactive waste
generated annually, EPA used an analysis of mixed radioactive wastes performed
by Brookhaven National Laboratory for the Nuclear Regulatory Commission which
indicated that approximately three percent of all low-level radioactive wastes
are potentially contaminated with RCRA hazardous wastes. Applying this ?
percentage to the approximately 13.4 million gallons of LLW generated in 1986
(Jennrich, March 1989), roughly 400,000 gallons of mixed radioactive wastes
were generated in that year.
Although this figure provides an approximation of the amount of non-DOE
mixed radioactive wastes generated annually, several other factors had to be
considered during the analysis of non-DOE mixed radioactive waste generation
in support of this rule. First, this figure accounts for all mixed
radioactive wastes, including solvents, dioxins, and California list wastes,
for which land disposal restrictions are already in place. EPA has determined
that the mixed radioactive wastes already subject to the LDRs constitute a
significant portion of all non-DOE mixed radioactive wastes.
A second factor that is not reflected in the approximation is the
quantity of mixed radioactive wastes in storage at non-DOE facilities. If
untreated, chese_wastes constitute a demand for tre_atment capacity. EPA's
review of available information sources indicates that there are significant
quantities of mixed radioactive wastes in storage at non-DOE facilities.
As a result of the analysis of available information on the generation
of non-DOE mixed radioactive wastes, EPA has reached several conclusions:
B-21
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(1) There is a lack of quantifiable information on the
generation and management of mixed radioactive wastes at
non-DOE facilities. EPA has based this analysis on what it
considers to be the best information available. EPA
recognizes, however, that these information sources are both
limited in content and limited to only a sample of the total
non-DOE mixed radioactive waste universe. In the proposed
rule, the Agency solicited any additional information on the
generation and management of non-DOE mixed radioactive
wastes. No additional data were submitted, but several
• f-
commenters suppcc-ted the proposed national capacity variance
for mixed radioactive wastes and confirmed that a lack of
commercial treatment and disposal capacity currently exists
(2) The volumes of mixed radioactive wastes generated at non-DOE
facilities are relatively small compared to thos* generated
at DOE facilities. The rough estimate of 400,000 gallons of
mixed radioactive wastes generated annually (based on the
Brookhaven estimate that three percent of all LLW is also
mixed radioactive waste) is known to include mixed
radioactive wastes that are not affected by this rule. EPA
has determined, however, that significant quantities of
mixed radioactive wastes are in storage at non-DOE
facilities requiring treatment. Even if the actual quantity
of mixed radioactive wastes was five times the 400,000
gallon estimate, this quantity would still be less than one
percent of the DOE-generated mixed radioactive wastes that
are affected by this rule. Non-DOE mixed radioactive
wastes, therefore, are expected to have no significant
impact on the capacity analysis performed on mixed ^
radioactive wastes at DOE facilities.
(3) The types of mixed radioactive wastes generated at non-DOE
facilities are also generated at DOE facilities. Upon
analysis of available non-DOE information, no additional
B-22
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RCRA waste codes were identified that were not already
identified in the DOE data. Non-DOE mixed radioactive waste
types, therefore, are not expected to affect the capacity
analysis performed on the DOE data (i.e., no additional
treatability groups for mixed radioactive wastes had to be
established)
B.6 Analysis of Non-DOE Treatment Capacity
EPA has taken several steps to identify available non-DOE treatment
capacity for mixed radioactive wastes. In support of the capacity analysis
for the First Third Rule, EPA analyzed information from the 1986 Survey of
Hazardous Waste Treatment, Storage, Disposal and Recovery Facilities (TSDR
Survey) EPA's review of process.-specific TSDR Survey questionnaire responses
identified no existing or planned commercial treatment, recovery, or disposal
systems for mixed radioactive wastes. To supplement information in the TSDRw"
Survey, EPA investigated several other sources of information, which were
discussed in section B.5. As described below, the various sources generally
indicated that a shortfall of available treatment capacity for mixed
radioactive wastes exists around the nation.
B.6.1 Identification of non-DOE Treatment Capacity
In order to identify available non-DOE treatment capacity, EPA
investigated available non-DOE information to determine how the different
types of mixed radioactive wastes are currently managed.
One of the primary types of mixed radioactive wastes affected by the
Third Third rule is scintillation waste. Scintillation fluids usually meet
the RCRA ignitability characteristic (D001) and are therefore Third Thirds
wastes. Combustion is the BOAT technology for D001 wastes. Investigation of
the TSDR Survey identified no RCRA-permitted combustion facilities that accept
mixed radioactive wastes. Because many scintillation fluids contain
radionuclides with relatively short half-lives, EPA believes that a large
amount of these materials are stored for decay and then managed as non-
radioactive hazardous wastes. This conclusion is based on information in the
B-23
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OTA report, and is supported by several of the state and interstate reports.
Although the scintillation fluids, such as toluene and xylene , may eventually
be incinerated as non- radioactive wastes, no combustion facilities handling
mixed radioactive wastes have been identified.
Analysis of the state and interstate reports and other data sources
identified no available treatment capacity for any other RCRA mixed
radioactive wastes subject to the Third Third rule. The data sources
contained evidence of capacity shortfalls, as discussed below
The 1987 Illinois LLW Annual Survey Report indicated that every LLW
generator possessing "hazardous chemicals" reported storing these wastes.
Although data characterizing "th^se wastes were not available, EPA assumed that
"hazardous chemicals" may contain First Third, Second Third, or Third Third
RCRA wastes. Generators reported storing at least 400,000 gallons of
potential mixed radioactive wastes because of regulatory or technical
constraints or for future shipment or alternative management. None of these
wastes are currently being treated. •" Ir
The 1989 Northwest Compact Region Survey, the 1988 Connecticut Low-Level
Radioactive Waste Management Plan, the Northeast Interstate Low-Level
Radioactive Waste Commission's Regional Waste Management Plan (August 1989),
and the Pennsylvania/ Appalachian States Compact Low-Level Waste Management
Survey (1987) also indicate a lack of available treatment capacity for mixed
radioactive wastes. The Northeast Interstate Low-Level Radioactive Waste
Commission's Regional Waste Management Plan, for example, indicated that mixed
radioactive waste generators are concerned about the storage limitations
imposed by the land disposal restrictions because there are no disposal or
treatment facilities within the Compact region.
The OTA report, which incorporates data from the state and interstate
surveys, the NUMARC report, and an informal survey of generators, processors,
and brokers., also did not identify significant treatment capacity for First
Third, Secofid Third, or Third Third wastes. -^
-*-*^*-~— «^
e^ OTA report noted that the majority of contaminated solid
and elemental lead (potentially D008) is currently stored.
The report did indicate that some lead decontamination
solutions are currently being solidified, which could
B-24
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represent BOAT if determined not to be EP Toxic for lead.
EPA, however, has not identified any non'-DOE stabilization
capacity The Agency welcomes any information on
stabilization capacity for D008 wastes.
• The OTA report also stated that aqueous corrosive liquids,
which are potentially D002 mixed radioactive wastes, are
currently being stored in lieu of any ongoing treatment.
EPA has not identified any non-DOE neutralization capacity
for D002 wastes. ,.
L^r
• Chromate and cadmium wastes are the only remaining potential Third
Third mixed radioactive wastes identified in the OTA report. No
available treatment capacity for chromate- or cadmium-containing
mixed radioactive wastes was identified in the reports. (These
wastes are potentially D006 and D007 mixed radioactive wastes. Ir
According to the NUMARC report, nuclear power plants are potential
generators of these wastes. These wastes, however, were not
reported as mixed radioactive wastes in any of the other
information sources.)
In an effort to identify additional data sources that might contain
information on mixed radioactive waste treatment capacity, EPA contacted mixed
radioactive waste experts associated with federal, state, and interstate
organizations. Attachment B-3 to this appendix describes these phone
contacts. These individuals were asked to identify any relevant data sources
on the generation of and treatment or recovery capacity for mixed radioactive
wastes. Alk information sources that were obtained as a result of these
conversations are listed in Attachment B-l and were incorporated into this
analysis. A ma^orrcy of the individuals contacted indicated thats^they knew of
no available commercial treatment or recovery capacity for mixed radioactive
wastes. Other respondents, however, identified four existing and one planned
facility that they thought may be treating mixed radioactive wastes. Upon
reinvestigation of the TSDR data set, EPA concluded that none of these
B-25
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facilities have BOAT creacmenc capacity that affect the capacity analysis for
the Third Third rule.
B.6.2 Summary of Non-DOE Treatment Capacity
EPA believes that the information developed for this capacity analysis
constitutes the best available data on the generation and treatment of mixed
radioactive wastes at non-DOE facilities. EPA recognized that the information
on non-DOE facilities was limited and the proposed rule solicited comments by
interested parties on the generation and management of non-DOE mixed
radioactive wastes. Commentejs addressing non-DOE mixed radioactive wastes
supported the national capacity...variance for these wastes.
EPA has not identified any non-DOE treatment capacity for non-DOE mixed
radioactive wastes affected by this rule:
• Combustion is the BDAT for D001 wastes which may be found in
scintillation fluids. No non-DOE combustion capacity was %-
identified in this capacity analysis.
• Stabilization is the BDAT for D006 (cadmium), D007
(chromium), and most D008 (lead) nonwastewaters. No non-DOE
stabilization capacity was identified in this capacity
analysis.
• Macroencapsulation is the BDAT for solid (i.e., elemental) lead
(D008). This BDAT is unique to solid lead mixed radioactive
wastes, which are often in the form of shielding, lead "pigs," or
bricks. These waste are known to be generated at non-DOE
facilities. No surface contamination/ encapsulation treatment
capacity, however, was identified in this analysis.
Chemical Precipitation is the BDAT for D006 and D008
wastewaters. No non-DOE chemical precipitation capacity was
identified.
B-26
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• Chromium Reduction followed by Chemical Precipitation is the BOAT
for D007 (chromium) wastewaters. No non-DOE chromium reduction
followed by chemical precipitation treatment capacity was
identified in this analysis.
• Neutralization is the BOAT for D006 and D008 wastewaters.
No non-DOE neutralization treatment capacity was identified
in this capacity analysis.
In addition to the treatability groups discussed above, EPA has
identified two other treatment: technologies that are unique to mixed
radioactive wastes -- amalgamation (for elemental mercury) and incineration as
amethod of treatment (for hydraulic oils containing mercury) -- which were
discussed in sections B.4.4 and B;. 4.10. No non-DOE treatment capacity for
these technologies was identified.
Although no additional First Third, Second Third, or Third Third wastef-
codes have been identified specifically, a large amount of uncharacterized
mixed radioactive wastes are generated at non-DOE facilities. (See Section
B.5.) These uncharacterized mixed radioactive wastes may contain RCRA wasi=
codes not identified above. Because no RCRA treatment capacity is available
for mixed radioactive wastes, any generation of First Third, Second Third, or
Third Third wastes not identified here would face a capacity shortfall.
B.7 National Capacity Variance for Mixed Radioactive Wastes
Based on the analysis discussed above, EPA has determined that there is
currently insufficient BOAT or equivalent treatment capacity for mixed
radioactive-wastes at both DOE and non-DOE facilities. Because a treatment
capacity shortfall was identified for every mixed radioactive waste
treatability groug^EPA is proposing to grant a national capacity^variance for
all mixed radioactive wastes. The waste codes that have been identified in
this analysis are arranged in treatability groups according to BOAT or the
equivalent in Table B.I, which also summarizes the treatment capacity
shortfalls
B-27
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Table B.I
Summary of National Capacity Variance for Mixed Radioactive Waste
(millions of gallons/year)
3DAT or
EQUIVALENT
RCRA WASTE
CODE(S)
QUANTITY
REQUIRING
TREATMENT
MAXIMUM
TREATMENT
Stabilization
Surface Oeactivation
Followed by Encapsulation
Combustion
Incineration
Followed by Ash
Stabilization
Neutralization
Vitrification
0005 nonwaitewaters
D006 nonwastewaters
0007 nonwastewaters
D008 nonwaitewaters
D011 nonwastewaters
0008 (solid)
0001
-0012
0013
Otj.it
D015
0016
0017
P068
U002
U019
U022
U213
U220
U226
U239
DO 09 (hydraulic oils)
0002
0004 nonwaitewaters
0010 nonwaitewaters
High-level mixed wastes
53.6
<0.2
1.6
<0. 1
26 2
14
28
0.2 ^
0
Alkaline Qhlorination
0003
0.8
Treatment of Reactive*
0003
<0.1
Chemical Precipitation
Sulfide Precipitation
Amalgamation with Zinc
Metals Recovery
Chromium Reduction
Followed by Chemical
Precipitation .;•
Alkaline Chlorination
Followed by Chemical
Precipitation la
Alkaline Chlorination
Followed by Stabilization
of Metals
Soil and Debris
Other
0004 wastewaters <0.1
0005 waitewatars
0006 waatewaters
D008 waitewaters
0010 waitewatert
0011 waitewateri
0009 51.6
0009 (elemental) <0.1
P015 0 2
D007 waitewaters <0.1
F007 0.5
F008
F009
F006 waitewaters
F006 nonwaitewaters 8.1
various 193
varioui /unknown 3.3
3
0
0
3
0
0
v<
0
0
0
Combuition capacity expressed in terms of "available" capacity
B-28
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No information was available for mixed radioactive wastes that are
disposed of in deep wells. For this reason, EPA is not proposing to grant a
national capacity variance for these wastes.
B-29
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ATTACHMENT B-l
SOURCES OF INFORMATION ON NON-DOE MIXED RADIOACTIVE WASTES
B-30
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This attachment describes the sources of information on non-DOE wastes
gathered and analyzed by EPA as part of the capacity analysis. The attachment
is organized in the following sections: EPA national surveys, overview
reports, state and interstate compact surveys and reports, and telephone
contacts
NATIONAL SURVEYS
In an effort to develop information on the universe of hazardous waste
management in the United States, EPA developed two comprehensive national
surveys. >-
TSDR Survey
The General Facility Information questionnaire requested information on
types and commercial status of mixed radioactive waste management, volumes
treated in 1986, the maximum quantity of mixed radioactive wastes that could-
have been treated in 1986, and when treatment would discontinue at each
facility. No specific waste code or waste stream information was requested,
but some waste codes were determined through the use of facility notes and
facility contacts. The TSDR survey was used to identify any operating
facilities that treat or recover mixed radioactive wastes, and to investigate
operations at facilities that could potentially handle mixed radioactive
wastes.
Generator Survey
The Generator Survey Questionnaires contain very general references to
mixed radioactive wastes. Specifically, Questionnaire GA (General Facility
Information) asks three basic questions: (1) Did the facility generate mixed
radioactive vatf*^. .on-site; (2) What quantity was generated; and~T3) How are
these mixed radioactive wastes managed. Although the Generator Survey data
set is currently incomplete, only 47 facilities have been identified as
indicating that they generate mixed radioactive wastes. Several of these were
DOE facilities and several were research universities. Although these
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facilities reported mixed radioactive waste generation quantities, EPA is of
the opinion that these facilities represent only a small sample of the mixed
radioactive waste-generating community. This conclusion is based on
information contained in the overview reports listed below, which indicate
that hundreds of facilities are potential generators of mixed radioactive
wastes. For example, over 100 nuclear power plants are potential generators
of mixed radioactive wastes. Use of information in the Generator Survey is
discussed within the text of this appendix.
B-32
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OVERVIEW REPORTS
In response to increased concern over Che responsible management of
mixed radioactive wastes, several national trade associations and government
agencies undertook studies to examine the generation and management of mixed
radioactive wastes. These studies are outlined below.
• Jennrich, E.A., Rogers and Associates Engineering Corporation,
Management Practices and Disposal Concepts for Low-Level Radioactive
Mixed W-aste. Congress of the United States, Office of Technology
f-
Assessment, Washington,^ D. C., March 1989
This report is perhaps the most comprehensive analysis of low-level
mixed radioactive wastes completed to date. It identifies generators,
processes, and RCRA hazardous wastes. The report, however, provides no
national estimates of mixed radioactive waste generation. The data ware
developed through reviewing existing information, contacting national
associations, and where necessary, surveying a sample of LLW generators,
processors, and brokers. The purpose of the study was to identify
current management practices and to develop a common understanding of
mixed radioactive waste management system performance goals and disposal
system design features. The information in this document was useful for
identifying processes and management practices at non-DOE facilities.
Generation rate information was also useful for determining the relative
magnitudes of different types of mixed radioactive wastes generated at
the various types of facilities.
• Jennrich, E.A., Rogers and Associates Engineering Corporation, The
Management of Mixed Waste in the Nuclear Power Industry, prepared for
Nuclfear Management and Resources Council (NUMARC), Washington, D.C.,
June, IW9*
This analysis provided conservative (i.e., upper bound) estimates of
mixed radioactive waste generation at nuclear power plants. The
document carefully notes that its estimates of mixed radioactive waste
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multi-source leachate, it was included in this analysis as organic/inorganic
nonwastewaters requiring alternative treatment.
NYD060545209 Al Tech Specialty Steel
The survey data indicated that approximately five million gallons of
multi-source leachate are generated at this facility. The survey data
indicated that the leachate from an on-site landfill is sent to a wastewater
treatment system where the wastewater is subjected to chromium reduction,
chemical precipitation, and vacuum filtration. The resulting dewatered sludge
is disposed in an on-site landfill, and the effluent is discharged under an
NPDES permit. The dewatered sludge is reported by the facility as being non-
hazardous. EPA assumed, however, that the treatment train used may not meet
all BDAT standards for multi-s.purce leachate. EPA estimated that 500,000
gallons of sludge may require alternative treatment.
NYD080336241 Cecos International Inc.
The survey data indicated that approximately seven million gallons of
multi-source leachate are generated by this facility. These wastes are
treated on-site and the effluent sent to a POTW. Additional fnformation fr
submitted by Cecos/BFI indicated-that approximately 168,000 gallons of filter-
pressed bio-sludge from wastewater treatment is sent off-site for regeneration
and land disposal. This waste volume has been included in the analysis.
OHD087433744 Cecos International, Inc.
The survey data indicated that approximately 5 million gallons of multi
source leachate are generated at this facility. The data, however, provided
no information of the management of these wastes. Upon contacting the
facility, EPA determined that roughly 5 percent of this volume (250,000
gallons) is sent off-site to a deep-well facility The remainder is sent off-
site to various wastewater treatment systems. EPA assumed that these off-site
systems generate residuals that may require alternative treatment. EPA
estimates that 200,000 gallons of organic/inorganic nonwastewaters derived
from the treatment- of this facility's leachate may require alternative
treatment capacity .-
OKD065438376 USPCI
_^ "^>
The survey"^data indicated that approximately four million gallons of
multi-source leachate is generated by this facility. The facility stabilizes
on-site wastewater treatment sludges. This could possibly meet the treatment
standard for inorganic nonwastewaters, however, this would not meet the
treatment standard for organic wastewaters. EPA assumed, therefore that the
treatment of this leachate volume in a wastewater treatment system would
generate roughly 20,000 gallons of sludge requiring alternative treatment.
EPA recognizes that the current treatment system used at this facility may
A-27
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meet BOAT standards. THe affect of using the 20,000 gallon approximation,
however, will not affect the outcome of the capacity analysis.
PAD000429589 Grows, Inc.
The survey data indicated that approximately 11 million gallons of
multi-source leachate are generated by this facility. The survey data also
indicated that 539 tons (approximately 130,000 gallons) of filter cake from
the wastewater treatment plant is sent to an off-site landfill without
treatment. This filter cake may require treatment as a nonwastewater prior to
disposal and, therefore, has been included in this analysis. The remaining
effluent is discharged under an NPDES permit and is, therefore, not included
in this analysis.
PAD000443705 Western Berks Refuse Authority
The survey data indicated that approximately three million gallons of
multi-source leachate are generared by an on-site landfill. The survey data
identified that the generated leachate is sent by tank truck to an off-site
hazardous waste treatment plant. EPA assumed this off-site fa'cility generates
treatment residuals that will require alternative treatment. EPA estimates
this volume to be roughly 200,000 gallons.
PAD004835146 Mill Service Yukon Plant
The survey data indicated that approximately 22 million gallons of
multi-source leachate are generated by this facility. The survey data also
indicated that the multi-source leachate is discharged to a POTW after
treatment. Data recently submitted to EPA by the facility indicate that 200
tons (48,000 gallons) of metal hydroxide treatment residuals are generated and
disposed. In the analysis, 48,000 gallons of inorganic nonwastewater multi
source leachate treatment residuals were identified as being surface-disposed
at this facility.
PAD059087072 Mill Service, Inc.
The survey data indicated that approximately 27 million gallons of
multi-source leachate are generated by an on-site surface impoundment. The
leachate is trea£ed_on-site. with treatment effluent discharged under a NPDES
permit, and treatment sludges returned to an on-site surface impoundment.
This facility supplied updated information to EPA indicating that 1,000 tons
(240,000 gallons) of metal hydroxide sludges are generated and land disposed.
These treatment residuals were included in the analysis as inorganic
nonwastewaters .
PRD980594618 Union Carbide Caribe, Inc.
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The survey data indicated that approximately two million gallons of
leachate were generated by this facility. The leachate is treated on-site
with the treated effluent being discharged under an NPDES permit. No leachate
residual volumes were reported land disposed by the facility. Upon review of
the TSDR Survey for this facility, however, EPA determined that 29,280 gallons
of dewatered sludge carrying the same waste codes as the multi-source leachate
were returned to the landfill. Although the facility indicates that the
sludge is non-hazardous, EPA believes that the sludge may not meet all BOAT
standards for multi-source leachate. This volume, therefore, has been
included in the analysis.
SCD070375985 GSX Services of South Carolina
f-
The survey data indicate-d that approximately 280,000 gallons of leachate
were generated, and 1,200 gallons"land disposed on-site. The survey data
indicated that on-site treatment is available. It was assumed that the 1,200
gallons of waste are leachate treatment residuals, and have been included in
the analysis.
TXD000835249 Gulf Coast Waste Disposal ^ 4
The survey data indicated that approximately 312,000 gallons of multi
source leachate are sent to on-site land treatment. The survey data also
indicated that this practice was to have stopped in 1988. Because it is
uncertain if this practice has stopped, the 312,000 gallons of leachate in the
form of organic/inorganic wastewater have been included in this analysis.
TXD069452340 Texas Ecologists, Inc.
The survey data indicated that 890,000 gallons of multi-source leachate
were generated from an on-site landfill. U.S. Ecology submitted data
indicating that this Texas facility generates solid residuals from the
treatment of leachate and contaminated groundwater. An estimated 48,000
gallons of leachate treatment residuals are generated on an annual basis. The
company is currently working on a "no migration" petition for two Class I
injection wells with the intent of deep-well disposing of site-generated
leachates and groundwater. For this analysis, however, the leachate treatment
residual volumes have been included.
WVD005005509 ^-.-Bnion Carbide Agricultural Production Company "^
The survey data indicated that approximately one million gallons of
multi-source leachate were generated. The survey data also indicated that
leachate is treated in a wastewater system prior to discharge under an NPDES
permit. Approximately 258,000 gallons of hazardous wastewater treatment
sludge is disposed either in a landfill or off-site in a surface impoundment.
Although this volume resulted from biological treatment, it could not be
A-29
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determined if all BDAT standards could be met. This volume, therefore, has
been included in the analysis.
Casmalia Resources
Casmalia Resources submitted data on leachate generation. The facility
recently lost the use of its surface impoundments and plans on replacing them
with a chemical fixation system. The amount of leachate to be stabilized is
approximately one million gallons per year. EPA assumed that this treatment
would not meet all BDAT standards for multi-source leachate. Assuming the
waste could be treated in a wastewater treatment system, EPA added 50,000
gallons of treatment residuals to the analysis.
Dow Chemical Company, Michigan"Division
Dow Chemical submitted data indicating that its Michigan Division
Wastewater Treatment Plant generates both primary and secondary solids from
the treatment of multi-source leachate. Approximately three million gallons
of primary solids are generated from clarification of wastewater treatment
plant's influent stream. Approximately one million gallons of secondary
solids are generated from wasting of activated sludge from the..aeration basinj-
Primary solids are treated on-sit.e by incineration. Secondary solids are land
disposed. This volume of secondary solids, therefore, has been included in
the capacity analysis.
Browning Ferris Industries
Information submitted as part of the Leachate Treatability Study Plan
(see section A.2.3) indicated that 150,000 gallons of leachate treatment
residuals are generated by BFI. Although this information was not connected
to a particular facility, the Study Plan data have been accepted by EPA and
the volume is included in the analysis.
Envirosafe Services of Ohio, Inc.
Envirosafe Services of Ohio, Inc. submitted data on the generation of
leachate treatment residuals. The facility projected generating 1,031 tons of
leachate treatment sludge (247,440 gallons) in 1990. Although these treatment
residuals are-currently being sent off-site, no information was submitted on
the off-site, management of these treatment residuals. Therefore, ^they have
been included iff-fire-analysis .
Envirosafe Services of Idaho, Inc.
A-30
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Envirosafe Services of Idaho, Inc., submitted data on its projected
estimates of leachate treatment residuals. The facility projected generating
14 tons of leachate treatment sludges (3,360 gallons) for 1990. The treatment
sludges were originally placed in an evaporation impoundment meeting minimum
technology requirements. This volume has been included in the analysis.
GSX Chemical Services of Ohio, Inc.
GSX Chemical Services of Ohio, Inc. submitted data indicating that it
generates approximately 40 tons per week (499,200 gallons per year) of filter
cake residuals from the treatment of multi-source leachate. The filter cake
residuals are currently being surface-disposed. Their waste volumes,
therefore, have been included^in this analysis.
A-31
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Section B-2
Facilities With Deep-Well Injected Multi-Source Leachate
This Section presents the analysis of facilities reporting both the
generation and the deep-well disposal of multi-source leachate. For each of
these facilities, a paragraph is included explaining the rationale for
including volumes of multi-source leachate requiring alternative treatment
capacity in the analysis.
LAD000618298 Cecos International, Inc.
The survey data indicated that approximately 3.25 million gallons of
multi-source leachate are sentT off-site for disposal to another facility
containing a deep-well inj ectfori- unit. Therefore, this volume was identified
as being deep-well disposed.
LAD010395127 Rollins Environmental Services
According to the survey data, approximately 17 million gallons of multi
source leachate were generated at this facility. The survey data only «
reported the disposal of approximately 3 million gallons of leachate. Because
the facility notes indicated that the leachate is sent to deep-well disposal,
and because of the uncertainty of any other on-site management practices for
leachate, only the reported 3 million gallons of leachate being land disposed
was assigned to deep-well disposal.
Gulf Coast Waste Disposal Authority (GCWDA)
During the comment response to the Third Third proposed rule, GCWDA
submitted data indicating that they are managing 1.5 to 1.8 million gallons of
multi-source leachate through deep-well injection. 1.5 million gallons have
been required to the required capacity estimate for deep-well disposal.
CBI Information
A portion of the deep-well injected volumes were classified as
confidential business information. In order to respect the CBI facilities'
requests thjtfe information remain confidential, EPA has aggregated their data
with that from several non-CBI facilities. Detailed descriptions of these CBI
and non-CBI- data are not included in this discussion.
A-32
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Section B-3
Facilities Reporting No Land Disposed Multi-Source Leachate
This section presents the available data for facilities chat reported
generation of multi-source leachate but which, for various reasons, do not
result in land disposal. The following facility profiles identify the reasons
for not including volumes of multi-source leachate requiring alternative
treatment capacity at these facilities.
ALD004019048 Monsanto Co. Anniston Facility
Evaluation of survey data showed that 103,000 gallons of multi-source
Leachate were generated at this facility. Survey notes indicate that multi-
source leachate undergoes biological treatment. The survey reported that
treatment residuals leaving the treatment unit are delisted. Therefore, no
volumes of multi-source leachate" were identified as being land disposed at
this facility
CAD069130995 Hewlett-Packard Co.
Evaluation of survey data showed multi-source leachate being treated by
a groundwater treatment system. The survey data indicated that approximately
1.74 million gallons of leachate. were treated by air stripping. Non-hazardous
waste effluent is being discharged under an NPDES permit. No multi-source
leachate were indicated as being land disposed at this facility and no
nonwastewater treatment residuals were reported generated.
MDD000797365 BFI
The survey data identified approximately 500,000 gallons of multi-source
leachate generated at this facility. The only on-site leachate management
practices identified were accumulation and storage in tanks. Because of the
uncertainty of leachate management and solid treatment residual generation, no
leachate waste volumes were identified as requiring alternative treatment for
this facility in the analysis.
MID005068507 Sundstrand Heat Transfer, Inc.
Investigation of the survey data indicated that approximately 735
million gallons of contaminated ground water were treated in an on-site
wastewater treatment system. The survey data indicated that the^eachate
resulted from" cne^ffCntamination of ground water by leaking on-site-tanks.
These tanks contained only F002 wastes. The contaminated ground water
resulting from leaking tanks containing only a single RCRA waste were
considered single-source leachate. Consequently, because the waste did not
fit the definition of multi-source leachate, this volume was not included in
the analysis.
A-33
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MID048090633 Uayne Disposal Inc, Site # 2
The survey data identified approximately three million gallons of multi -
source leachate generated by this facility The survey data also indicated
that the multi-source leachate is sent off-site to a POTW for treatment.
Because POTWs are not subject to RCRA Subtitle C requirements, this volume is
not included in the analysis.
MID980568711 Ford Motor Company, Allen Park
The survey data identified approximately two million gallons of multi-
source leachate generated. This multi-source leachate was reported discharged
to a POTW without prior treatment. Because POTWs are not subject to RCRA
Subtitle C requirements, this^volume is not included in the analysis.
MOD068521228 B.H.S., Inc.
The survey data indicated that 155,000 gallons of multi-source leachate
is generated at this facility. The survey data also indicated that between
1986 and 1987, leachate would be either treated by solar evaporation or sent
off-site to a POTW, and that beginning in 1988 all leachate would be sent ofF-
site to a POTW. Because POTWs are not regulated under Subtitle C or RCRA,
this volume was not included in the analysis.
OHD068111327 Evergreen Landfill
The survey data indicated that 175,680 gallons of leachate are generated
from an on-site landfill. The survey data also indicated that the leachate is
discharged to a POTW after treatment, however, only accumulation in tanks was
identified as an on-site management practice. No volumes from this facility
were included in the analysis.
PRD090028101 Merck, Sharp & Dohme, Quimica de Puerto Rico
The survey data indicated that approximately 35 million gallons of
multi-source leachate are generated from an on-site landfill at this facility
The survey daca identified only F005, XASB, and non-hazardous wastes as being
land disposed. Since the leachate generated by-the landfill is not multi
source but. single-source, the waste volume was not included in the analysis.
-^K^^^K. "^?
TXD055141378 Rollins Environmental Services
The survey data indicated that approximately 12 million gallons of
multi-source leachate were generated by this facility. The survey data
identified the following treatment processes for multi-source leachate:
storage in tanks followed by on-site treatment, including activated sludges,
A-34
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Lime precipitation, flocculation, and gravity thickening. Effluent from
treatment is either discharged under an NPDES permit or recycled to
incineration scrubbing. Treatment residuals are stabilized and disposed in an
on-site landfill. Because of the uncertainty of the waste's composition, it
was believed possible that the stabilized treatment residuals could meet BDAT
standards, and, therefore, their waste volumes were not included in the
analysis.
WID076171008 Land Reclamation Ltd.
The survey data indicated that approximately four million gallons of
multi-source leachate are generated. The survey data also indicated that the
leachate was discharged to a POTW without prior treatment.
WID0985A7854 Metro Landfill and Development Project
The survey data indicated that approximately eight million gallons of
multi-source leachate are generated. The survey data also indicated that the
leachate is accumulated in tanks then discharged to a POTW without prior
treatment. *
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ATTACHMENT C
PHONE LOGS
A-36
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The phone Logs provided here outline discussions with facilities that
were contacted due to uncertainty regarding multi-source leachate generation
and management at the particular facility.
4/30/90 Midwest Steel Co. IND016584641
• When asked about multi-source leachate management at the facility, the
contact responded that the landfill was a mono-fill, so the leachate is
single-source.
4/30/90 USPCI, Grassy Mountain, Utah UTD991301748
• Lon Griffith indicated that a total of approximately 45 gallons per day
of multi-source leachate-are generated at the facility's three RCRA
landfill cells. -• ..^
• As of May 8, 1990, however; a treatment system will be in place that
will meet the raulti-source leachate concentration standards.
• All leachate will be managed on-site.
4/30/90 Petroleum Waste, Inc. (under new ownership) _ CAD9806752J6
• Marianna Buoni indicated that only 2 litres of leachate are generated
per month at the facility.
• This volume was determined to be insignificant.
4/30/90 Cecos International, Strasburg, Colorado COD991300484
• Lillian DePrimo indicated that this was a new landfill that won't begin
accepting waste until July 1990
• No leachate generated at this facility.
4/30/90 Cecos International, Zion, Illinois ILD980700728
• Robert Fister was faxed several questions regarding leachate generation
and management.
• The response was not received in time to be added to the analysis.
5/1/90 Cecos International, Williamsburg, Ohio- OHD087433744
Ron Lotter indicated that the leachate volume reported in the survey are
approximately correct.
Leachate is managed at several off-site facilities. Roughly 5 to 10
percent is managed through deep-well injection. The remainder is sent
to off-site wastewater treatment plants or to off-site POTW discharge.
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ATTACHMENT D
MULTI-SOURCE LEACHATE CLARIFICATION
LETTER SUBMITTED BY DuPONT
March 22, 1990
A-38
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E. I. DU PONT DE NEMOURS & COMPANY
INCOWWUTU
WILMINGTON. DELAWARE 19898
CHEMICALS AND PIGMENTS DEPARTMENT March 22 1990
Ms. Jo Ann Bassi
U.S. EPA
Office of Solid Waste
Washington, D.C. 20460
Dear Ms. Bassi: "' -••_•_
In September of 1989, I wrote to you to describe the efforts
Du Pont has underway at Chambers Works to manage residuals from
treatment of leachate and contaminated groundwater after May of
1990. In that letter, I described a scheme which would segregate
groundwater and leachate and divert those waste streams to the
secondary treatment phase of the wastewater treatment plant; the fr
secondary sludge could then be thermally treated, either on-site or
off-site.
This scheme would be a stop-gap measure to allow Chambers Works
to meet the land disposal restrictions standards in May of 1990.
Over the longer term, we will be implementing thermal treatment for
all Chambers Works solids residuals. Once this thermal treatment is
in place, segregation of groundwater and leachate to secondary will
no longer be necessary.
As you know, EPA has proposed to grant a two-year national
capacity variance to solids residuals from treatment of groundwater
and leachate. When this capacity variance is finalized, the
substantial expenditures (estimated to be above $3 million) and
disruption associated with segregating groundwater will be
unnecessary.
In light of these substantially changed circumstances, we have
deferred further work on segregation to secondary treatment.
Because this represents a change from the position described in my
September letter, I thought it necessary to inform you and your
colleagues. • •-"" —
Sincerely,
Barbara J. McGuinness
Regulatory Affairs
Consultant
BJMrgct
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APPENDIX B
MIXED RADIOACTIVE WASTES CAPACITY ANALYSIS
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APPENDIX B
MIXED RADIOACTIVE WASTE CAPACITY ANALYSIS
Mixed radioactive wastes are radioactive and are contaminated with RCRA
hazardous wastes. Consequently, these wastes are subject to dual regulation;
EPA standards apply to the RCRA hazardous portion and Nuclear Regulatory
Commission (NRC) or Department of Energy (DOE) requirements apply to the
radioactive portion.
The treatment standards promulgated as part of this Third Third Land
Disposal Restriction (LDR) rule apply to RCRA wastes mixed with radioactive
f-
wastes. EPA, therefore, has undertaken an analysis of the generation and
available alternative treatment' capacity for mixed radioactive wastes in an
effort to determine the need for a National Capacity Variance from the LDRs.
This appendix outlines the analysis of mixed radioactive wastes that was
performed, including the methodology used for evaluating the generation and
capacity information. It also presents the results of the analysis and g_
explains why EPA is granting a two-year national capacity variance to all
surface-disposed mixed radioactive wastes.
This Appendix is essentially the same as that submitted for the Third
Third proposed rule. Minor changes have been made corresponding to changes in
the best demonstrated available technology (BOAT) for certain mixed
radioactive wastes that have been made since the proposed rule. These changes
had no effect on the capacity determinations for mixed radioactive wastes. As
proposed, the final rule grants a two-year national capacity variance to all
mixed radioactive wastes.
One commenter to the proposed rule requested that EPA clarify whether
naturally-occurring radioactive materials (NORM) that are mixed with RCRA
hazardous wastes are also being granted a national capacity variance. EPA
responded to this comment by stating that NORM wastes do not fall under the
definition of mixed RCRA/radioactive wastes as described in section B.I.I. As
s»"<'
proposed, the"~na"tTonal capacity variance would not have been granted to these
wastes. EPA recognized, however, that insufficient alternative treatment
capacity exists^to handle RCRA hazardous wastes that are also radioactive. In
this final rule, therefore, EPA is granting a two-year national capacity
variance to RCRA hazardous wastes that are mixed with NORM wastes.
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B.I Background
B.L.I Definition of Mixed Radioactive waste
EPA has defined a mixed radioactive waste as any matrix containing a
RCRA hazardous waste and a radioactive waste subject to the Atomic Energy Act
(53 FR 370^5, 37046, September 23, L988). Because the radioactive and RCRA
hazardous components of mixed radioactive wastes are often inseparable, mixed
radioactive wastes are subject to dual regulation. Atomic Energy Act
requirements apply to the radioactive portion of mixed radioactive wastes, and
the Department of Energy (DOE_) or the Nuclear Regulatory Commission (NRC) is
responsible for promulgating-'and enforcing the requirements. RCRA standards
apply to the hazardous components of these wastes, and EPA is responsible for
promulgating and enforcing the standards.
B.I.2 Status of Mixed Radioactive Wastes in the LDR Program
*
Radioactive wastes that are mixed with spent solvents, dioxins, or
California list wastes are subject to the land disposal restrictions already
promulgated for those hazardous wastes. EPA determined that radioactive
wastes that are mixed with First Third and Second Third wastes will be
included in the Third Third rulemaking (40 CFR 268.12(c)). Thus, today's
proposal addresses radioactive wastes that contain First Third, Second Third,
and Third Third wastes.
B.I.3 Distinctions Based on Radioactivity
Radioactive wastes are often separated into groups according to their
relative radioactivity (EPA, March 1987). These divisions include high-level
wastes (HLW) , transuranic (TRU) wastes, and low-level wastes (LLW). The
processing of nuclear reactor fuels generates two types of HLW: ~>-ene resulting
from dissolving naval reactor fuel elements to recover enriched uranium; the
other resulting from dissolving nuclear reactor fuel elements to recover
uranium. HLW are generated in a liquid form, and most HLW have hazardous
chemical characteristics (e.g., corrosivity and toxicity). HLW may also
B-3
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contain listed RCRA hazardous wastes. The primary hazard normally associated
with HLW, however, is their intense radioactivity
TRU wastes contain alpha-emitting transuranic isotopes with half-lives
greater than 20 years. They also contain more than 100 nanocuries per gram of
waste. TRU wastes are generated during the processing, shaping, and handling
of plutonium-containing materials. TRU wastes can be solid (e.g.. gloves,
rags, and cools) or liquid and may contain listed or characteristic RCRA
hazardous wastes.
LLW result from more varied processes than either HLW or TRU wastes.
LLW are generated during a variety of activities, and several RCRA waste codes
are potential LLW contaminants/ -'Among the most significant LLW contaminants
are organic chemicals, including liquid scintillation cocktails, and lead
metals used for containers and shielding.
Regardless of the type of radioactive constituents that mixed
radioactive wastes contain (i.e., high-level, low-level, or TRU), these wastes
are currently subject to RCRA hazardous waste regulations, including
applicable land disposal restrictions.
B.I.4 Types of Mixed Radioactive Waste Generators
For the purpose of the Third Third capacity analysis, mixed radioactive
waste generators were separated into two groups: DOE facilities and non-DOE
facilities. DOE facilities generate the largest quantities of mixed
radioactive wastes of all groups. For this reason, the capacity analysis
focused primarily on DOE facilities.
Most non-DOE facilities that generate mixed radioactive wastes are
commercial operations. Federal agencies other than DOE, including the
Department of Agriculture and the National Institutes of Health, generate
mixed radioactive wastes that are similar to those generated by other non-DOE
facilities. 'In"%emiral, non-DOE facilities can be grouped into the following
categories:
• Nuclear power plants (e.g., boiling water and pressurized water
reactors);
• Medical institutions (e.g., research and clinical activities);
• Academic institutions (e.g, non-medical research); and
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• Industrial facilities (e.g., pharmaceutical, sealed source, and
irradiator manufacturers, biotechnical manufacturers, spent fuel
storage facilities, and waste processors)
B.2 Information and Data Sources
In support of this capacity analysis, EPA collected the available
information on the generation, characterization, and management of mixed
radioactive wastes.
B.2.1 Department of Energy Data
EPA recognized that a large amount of radioactive wastes generated at
DOE facilities are contaminated with RCRA hazardous wastes. In cooperation
with EPA, DOE provided data to EPA outlining the generation, treatment, and
disposal of mixed radioactive wastes at DOE facilities. DOE.,provided these*
data in a series of tables for -21 DOE facilities. The data included volume of
waste streams generated annually and in storage, current treatment capacity,
and planned treatment. The majority of the capacity analysis for mixed
radioactive wastes was based on these data.
B.2.2 Information on Non-DOE Mixed Radioactive Waste
In an effort to obtain as much information as possible on the
characterization, generation, and management of non-DOE mixed radioactive
wastes, EPA investigated several potential sources of information. These
included hazardous waste management and generation surveys, summary reports on
mixed radioactive waste generation and management, available state surveys and
interstate compact surveys and reports, as well as phone contacts with several
state, regional, and federal government officials and industry
im ~ ~v^
representatives. Attachment B-l to this appendix outlines these sources of
information in more detail.
Although EPA believes that the information collected for this analysis
is the best available, EPA recognizes that the information on the quantities
of mixed radioactive wastes generated and managed at non-DOE facilities could
B-5
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be improved. Consequently, in the proposed Third Third rule the Agency
requested comments by interested parties on the current generation and
management of mixed radioactive wastes. Commenters submitted information that
supports the national capacity variance for mixed radioactive wastes.
B.3 Methodology for Analyzing DOE Data
After analyzing available information, EPA believes that the DOE data
set represented the most accurate information on mixed radioactive wastes
available. EPA also determined that the quantities of mixed radioactive
wastes generated at DOE facilities constitute a significant portion of all
mixed radioactive wastes generace.d. For these reasons, the capacity analysis
focused primarily on the data provided by DOE. The following sections
describe the methodology and assumptions used in the capacity analysis.
B.3.1 DOE Generation of Mixed Radioactive Waste
t
To estimate the quantity of DOE mixed radioactive wastes, DOE annual
generation rates were combined with the quantities of untreated wastes
currently in storage at DOE facilities (i.e. , estimated inventory at the end
of 1989) The annually- generated volumes and volumes in storage were combined
because EPA assumed that all untreated wastes constitute a demand for
treatment .
EPA used DOE estimates of these combined quantities. The DOE
methodology for developing these numbers involved estimating the total
inventory as of July 1989 and adding one half of the annual generation rate to
estimate the total volume of each waste stream requiring treatment at che end
of 1989.
B.3. 2 Facility-by-Facility Analysis of DOE Mixed Radioactive
neration "***
Analysis of the data provided by DOE involved grouping waste streams
according to the applicable best demonstrated available technology (BOAT) at
each DOE facility. A key issue in this analysis was how to address several of
B-6
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the DOE waste screams chat concained more Chan one RCRA waste code, many with
different- BDATs . To prevent double-counting of waste quantities when grouping
che wastes by treatability group, the streams were divided by assigning an
equal portion of che quantities to each waste code (i.e., straight
proportionality) For example, DOE may have provided a single volume (e.g.,
20,000 gallons) for a stream called "wastewater treatment sludge," which
contains D001, D008 , D009 , and D011. Using scraighc proporcionalicy , each
wasce code would be assigned 5,000 gallons. Alchough this procedure may not
be che most precise way of assigning volumes, EPA believes that the conclusion
of chis analysis would remain che same if another, more complex method was
used.
f~
B.3.3 DOE Treatment Capacity
Estimates of RCRA treatmenc capacicy were developed using DOE-supplied
daca on each of the treatment units located at the various facilities. EPA
determined whether Che given treatment was a BOAT or BDAT equivalent for
parcicular wastes created in that unit. DOE also provided considerable data
on planned treatment units and their capacities. Because these units will noc
be operacional until afcer 1992, Chey were not included in the capacity
analysis for decermining the need for a national variance.
B.3.4 Net Capacity at each DOE Facility
The estimates of mixed radioactive waste generation outlined above were
compared to the available on-site treatment capacity to determine the nee
creacmenc capacicy at each DOE facility for each treatment technology
B.3.5 Net DOE Treatment Capacity
To determine the net DOE treatment capacity for each treatab*lity group
across all DOE facilities , aggregates of the quancities of wastes requiring a
particular treatment were subtracted from the available capacity for that
treatment .
B-7
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B.4 Results of DOE Analysis
Analysis of the mixed radioactive waste generation data supplied by DOE
shows that approximately 363 million gallons of radioactive waste mixed wich
Firsc Third, Second Third, and Third Third RCRA wastes are affected by this
proposed rule.. A variety of waste types and RCRA waste codes are generated.
and several creatability groups were identified. The results of the DOE data
analysis are provided in a series of tables included in Attachment B-2 of this
appendix. The following discussion outlines the major findings of the
analysis and explains the Attachment B-2 tables in more detail.
The DOE data included 3Q different First, Second, and Third Third RCRA
waste codes. As Section B.3 "discussed, the methodology used to analyze these
data involved arranging the DOE wastes requiring the same BOAT into
treatability groups Tables B-2(a) through B-2(m) in Attachment B-2 provide
facility-specific information on the volumes requiring treatment and the on-
site treatment capacity for each treatability group. The on-site treatment
capacity is based on treatment unit data provided by DOE for "each site. In *
most cases, the capacity provided represents the "maximum" capacity of the
unit. The "maximum" capacity is the capacity of the unit before subtracting
any capacity currently being used. "Available" capacity refers to the amount
of treatment capacity that a unit offers beyond any treatment that is
currently taking place.
B.4 1 Stabilization
Table B-2(a) lists the on-site stabilization treatment capacity and the
quantity requiring stabilization as treatment for each of the DOE facilities.
In the proposed rule, EPA estimated that approximately 77.7 million gallons of
DOE mixed radioactive wastes require stabilization treatment capacity
Because a portion of this volume requires the new BDAT of vitrification,
approximately^J^ui^million gallons have been reassigned from stabilization to
vitrification. For this final rule, EPA estimates that 63.6 million gallons
of mixed radioactive wastes will require stabilization. This volume accounts
for approximately 40 percent of the non-soil and debris mixed radioactive
wastes generated at DOE facilities that are affected by this rule. EPA has
B-8
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decermined chat DOE mixed radioactive wastes requiring stabilization include
chose containing D005, D006, D007, D008. and D011 nonwastewaters.
EPA determined that 14.4 million gallons of DOE mixed radioactive wastes
contain lead (D008). This quantity is about 8.5 percent of all non-soil and
debris mixed radioactive wastes generace.d by DOE chat are affected by chis
rule .
• Based on brief waste descriptions, EPA decermined that at least
155,000 gallons of solid lead generated by DOE require surface
deactivation followed by encapsulation, which is discussed in
Section B.4.2.
f-
• EPA was unable to determine whether lead was in a solid, elemental
form for 2.2 million gallons of mixed radioactive wastes and
assigned this volume to the stabilization BOAT.
• EPA determined that 12 million gallons of mixed Radioactive wastes
containing lead do not fall into the new BOAT category. This
volume was also assigned to stabilization.
A large amount of D009 (mercury) mixed radioactive wastes have been
assigned to the stabilization treatability group. Although stabilization is
not BOAT for D009 mixed radioactive wastes, a large amount of the D009 are
within wastes that contain other metals for which stabilization is BOAT.
Consequently the entire volumes of these streams were assigned to
stabilization.
EPA determined that approximately 2.8 million gallons of stabilization
capacity that is RCRA BOAT is available at DOE facilities. A stabilization
capacity shortfall; therefore, exists for mixed radioactive wastes at DOE
facilities.
B-9
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B.4.2 Maeroencapsulation of Radioactive Lead Solids as a Method of
Treatment.
EPA currently assumes that LDR treatment standards and technologies chat
apply to non-radioactive hazardous waste also apply to the hazardous waste
portion of mixed radioactive waste. In a few cases, however, EPA has
determined that special treatment technologies may be required for mixed
radioactive wastes because of the unique properties of the waste. One such
case is solid lead (i.e., elemental lead) that has been radiologically
contaminated. These wastes are commonly associated with lead shielding,
"pigs," bricks, etc. In the 'proposed rule, EPA used surface deactivation
_ ..*-
followed by encapsulation as BDA-T for this waste. In the final rule, this
BDAR has been changed to "macroencapsulation of radioactive lead solids as a
method of treatment." Analysis of the DOE data regarding lead wastes showed
that at least 150,000 gallons of mixed radioactive wastes in the form of solid
lead require this treatment, as shown in Table B-2(b).
"*' r
DOE data indicated that solid lead mixed radioactive wastes were
encapsulated at only one facility. The data, however, did not indicate that
the waste first underwent surface deactivation at this facility. In addition,
the DOE data did not identify any available capacity for this treatment. Even
if BOAT treatment is being applied at that one facility, a capacity shortfall
for surface deactivation followed by encapsulation currently exists at DOE
facilities.
B.4.3 Combustion
Table B-2(c) provides the results of the analysis of DOE mixed
radioactive wastes requiring combustion capacity Data provided by DOE listed
wastes containing the following waste codes that require combustion as
treatment: D001, D012, D013, D014, D015, D016, D017, P068, U002, U019, U022,
U213, U220, U2aS^-and U239 wastewaters and nonwastewaters. In addition,
volumes for wastes for which the waste codes were described only as "P's" and
"U's" were assigned to the combustion treatability group.
Analysis of the DOE data showed that 1.6 million gallons of First Third,
Second Third, and Third Third mixed radioactive wastes generated at DOE
B-10
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facilities require combustion capacity This quantity is about one percent of
the non-soil and debris mixed radioactive wastes generated at DOE facilities
affected by this rule.
On-site combustion capacity at DOE facilities is listed as zero gallons
in all cases in Table B-2(c) Unlike the other tables, which list the
"maximum" capacity for on-site treatment units, the combustion capacities
listed in this table represent "available" capacity Although DOE does have
operational combustion facilities, EPA has assigned their capacity to mixed
radioactive wastes other than those containing First Third, Second Third, or
Third Third wastes. For the purposes of the capacity analysis for the Third
Third rule, therefore, available DOE combustion capacity for those radioactive
f-
mixed wastes affected by this rule is zero.
B.4.4 Incineration as a Method of Treatment
In the proposed rule, EPA has proposed incineration with ash
stabilization as BOAT for mixed radioactive wastes in the fo-rm of hydraulic|f-
oils containing mercury (D009). In the final rule, this BOAT has been changed
to "incineration as a method of treatment." During analysis of the DOE data,
the generation of these wastes could not be distinguished from the generation
of other D009 mixed radioactive wastes. Specific generation numbers,
therefore, could not be developed. No incineration/ash stabilization
treatment capacity was identified, so a capacity shortfall for this technology
currently exists at DOE facilities.
B.4 5 Neutralization
Table B-2(~d) provides data mixed radioactive wastes requiring
neutralization as treatment at DOE facilities. Mixed radioactive wastes
exhibiting the characteristic of corrosivity (D002) were identified in the DOE
data. These wastes require neutralization as BOAT. Analysis of^the DOE data
showed that 26.2 million gallons of DOE mixed radioactive wastes require
neutralization. This quantity accounts for 15 percent of all non-soil and
debris mixed radioactive wastes generated by DOE affected by this rule.
B-ll
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The DOE data did not contain any specific capacity information for
neutralization. The data, however, indicated that several D002-containing
waste streams are currently being neutralized. In these cases. EPA has used
the annual generation rate as the annual treatment capacity Although this is
an indirect method of estimating treatment capacity, this method does not
affect the outcome of this capacity analysis Even with the treatment
capacities assigned in this way, a DOE capacity shortfall of nearly 26 million
gallons was calculated.
B.4.6 Vitrification
f-
Table B-2(e) addresses vifr.ification. DOE mixed radioactive wastes
requiring vitrification include D004 and D010 nonwastewaters. In addition,
EPA is promulgating "vitrification of high-level radioactive waste as a method
of treatment" for high-level radioactive mixed wastes generated during the
reprocessing of fuel rods. This second category was not included in the
proposed rule, but has been added to the final rule based on data submitted .Dy
DOE. These wastes are generated at six DOE facilities, in a combined amount
of 14 million gallons. Although the DOE data included information on planned
vitrification facilities, no operational vitrification capacity was determined
to be available. Thus, there is a DOE capacity shortfall for this technology
B.4.7 Alkaline Chlorination
Table B-2(f) provides data on DOE mixed radioactive wastes that require
alkaline chlorination. Approximately 800,000 gallons of non-explosive D003
wastes (reactive characteristic) were identified as requiring this treatment.
This quantity accounts for 0.5 percent of non-soil and debris DOE mixed
radioactive wastes affected by this rule.
No alkaline chlorination capacity is available at DOE facilities. Thus,
there is a DOS ^•fneity shortfall. ^
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B.4.8 Treatment of Reactives
Table B-2(g) provides data on DOE mixed radioactive wastes requiring
treatment of reactives. Analysis of DOE data identified explosive D003 wastes
(reactive characteristic) in this category These wastes were reported as
generated at only one DOE facility, which indicated that 5,000 gallons require
treatment. No treatment of reactives capacity was identified during the
analysis. Thus, there is a DOE capacity shortfall this technology
B.4.9 Chemical Precipitation
Table B-2(h) provides data .on DOE mixed radioactive wastes requiring
chemical precipitation. Approximately 12,000 gallons of mixed radioactive
wastes require chemical precipitation capacity, including D004, D005, D006,
D008, D009, D010, and D011 wastewaters.
No chemical precipitation treatment capacity was identified in the *~
analysis of DOE data. There is a capacity shortfall for chemical
precipitation currently exists at DOE facilities.
B.4 10 Sulfide Precipitation
Sulfide precipitation is BDAT for mixed radioactive wastes containing
mercury (D009) Table B-2(i) provides information on D009 mixed radioactive
wastewaters at DOE facilities. Approximately 51.6 million gallons of D009
mixed radioactive wastes were identified, accounting for approximately 30
percent of all non-soil and debris DOE mixed radioactive wastes. No sulfide
precipitation treatment capacity was identified, so a DOE capacity shortfall
currently exists.
B . 4 .11 .^.Amalgamation as a Method of Treatment ^
Originally proposed as "amalgamation with zinc," EPA is promulgating
"amalgamation as a method of treatment" in this final rule for mixed
radioactive wastes containing elemental mercury (D009 or U151). It was
difficult to determine, from the DOE data, the quantity of DOE wastes that
B-13
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require this treatment. Table B-2(j) provides information on streams that
could be identified.
Amalgamation capacity was not identified in the DOE data, so a DOE
shortfall in capacity currently exists.
B.4.1-2 Metals Recovery
Table B-2(k) provides data on DOE mixed radioactive wastes requiring
metals recovery as treatment. Approximately 200.000 gallons of P015 wastes
(beryllium dust) require metals recovery treatment at DOE facilities. This
figure accounts for less than^ one percent of all non-soil and debris DOE mixed
radioactive wastes affected by- phis rule.
EPA's analysis of DOE data identified no metals recovery capacity
Therefore, there is a capacity shortfall for this technology.
B.4.13 Chromium Reduction followed by Chemical Precipitation
fr
Table B-2(l) provides data on DOE mixed radioactive wastes for which
chromium reduction followed by chemical precipitation is the required
treatment. Analysis of the DOE data identified 1,650 gallons of D007
wastewaters as the only DOE mixed radioactive wastes requiring this treatment.
This waste was generated at only one facility. The analysis, however,
identified no chromium reduction or chemical precipitation treatment capacity
Thus, there is a DOE capacity shortfall for chromium reduction followed by
chemical precipitation.
B.4.14 Alkaline Chlorination Followed by Chemical Precipitation
Table B-2(m) provides data on DOE mixed radioactive wastes for which
alkaline chlorination followed by chemical precipitation is the required
treatment. The _following DOE wastes require this treatment: FQQ£ wastewaters
and F007, F008, and F009 nonwastewaters and wastewaters. Approximately
500,000 gallons of mixed radioactive wastes require this treatment. This
volume accounts for approximately 0.3 percent of the non-soil and debris DOE
mixed radioactive wastes affected by this rule.
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No alkaline chlorination or chemical precipitation treatment capacity is
available at DOE facilities. Consequently, there is a capacity shortfall for
this technology
B.4.15 Alkaline Chlorination Followed by Stabilization of Metals
Alkaline chlorination followed by stabilization of metals is BOAT for
mixed radioactive wastes containing F006 nonwastewaters. Table B-2(n)
provides information on these wastes, and shows that 8 million gallons are
generated at DOE facilities. This quantity accounts for 5 percent of all non-
soil and debris DOE mixed radio.active wastes affected by this propose ruie.
No capacity for this treatment was identified, so there is currently a DOE
capacity shortfall for alkaline chlorination followed by stabilization of
metals.
B.4 16 Soil and Debris
f
Through analysis of DOE data, EPA has determined that there are 193
million gallons of soil and debris contaminated with mixed radioactive waste
at DOE facilities. This volume accounts for 53 percent of all DOE mixed
radioactive wastes that may be affected by this rule. Table B-2(o) provides
information on these soil and debris wastes.
Over 98 percent of the soil and debris volume contains "unknown" or
"various" RCRA hazardous wastes. The types of RCRA hazardous wastes listed
for the less than two percent that were characterized included D006, D008,
D009. and D011. One facility listed almost three million gallons of soil and
debris contaminated with D008.
EPA has added a subcategory to debris called "inorganic solid debris."
Mixed radioactive waste in this form have been included in the capacity
analysis for soil and debris.
There if jpo.JjQE treatment capacity for soil and debris contaminated with
mixed radioactive wastes.
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B.4.17 Other DOE Wastes
Several wastes identified within the DOE data could not be placed in a
particular treatability group. These "other" wastes amounted to 3.3 million
gallons, or one percent of all DOE mixed radioactive wastes affected by this
rule. Approximately 87,000 gallons of these miscellaneous wastes listed
"various" or "unknown" waste codes, and could not be classified in any
particular treatability group. Two wastes, amounting to 3,210,030 gallons.
were classified as containing "D's," "P's," and "U's." Approximately 2.3
million gallons of this total^was identified as high-level fuel process
wastes. The other one million gallons were designated as calcinated wastes.
Because of the incomplete classification of these wastes and their unique
physical form, these mixed radioactive wastes were not assigned to a
particular treatability group. Excluding these wastes from the analysis does
not affect the need for a variance, as these volumes would only add to the
" r
capacity shortfalls that have already been identified.
B.4.18 DOE Planned Treatment Capacity
Although there are currently DOE capacity shortfalls for all
treatability groups, a considerable number of treatment units are either
planned or under construction at DOE facilities When operational, these
units will provide significant treatment capacity for a number of treatability
groups. Because these units will not be available in May 1990, however, they
were not considered in the Third Third capacity analysis.
At least 20 different treatment units are expected to come on line at
DOE facilities between 1992 and 2012. These units will include several
incinerators (including controlled air, rotary kiln, and plasma arc),
solidification units, vitrification and glass/ceramic process units, grout
operations (a«me. w4
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B.5 Analysis of Non-DOE Mixed Radioactive Waste Generation
Several types of non-DOE facilities generate mixed radioactive wastes.
In chis analysis, EPA used the best available information on the quantities
and characteristics of mixed radioactive wastes generated at non-DOE
facilities. Information used for this capacity analysis include data
developed as part of EPA's Generator Survey, state and interstate compact
surveys and reports, a study developed for the Office of Technology Assessment
of the U.S. Congress, a study developed for the Nuclear Management Resources
Council, and a series of reports developed by Brookhaven National Laboratory
for the Nuclear Regulatory Commission. These data sources vary in detail and
none of them provide national estimates of non-DOE mixed radioactive waste
generation.
To derive non-DOE mixed radioactive waste generation information that
could be compared or combined with DOE data to determine the total demand for
alternative capacity. EPA had to develop:
(1) Rough estimates of the quantities of non-DOE mixed radioactive
wastes generated; and
(2) The types of RCRA hazardous waste codes found in these wastes.
Ideally, the non-DOE mixed radioactive waste generation rates would be linked
to specific RCRA waste codes. With this level of detail, EPA could allocate
non-DOE mixed radioactive wastes to treatability groups and combine this
information with similar data for DOE facilities. In analyzing the available
information, however, EPA found that, in most cases, the information
characterizing non-DOE mixed radioactive wastes was not sufficiently detailed
to perform such an analysis. As described below, several data sources list
"mixed waste" as a single category, while others provide a single, overall
generation rate while listing several potential hazardous contaminants. Thus,
in many cases,-JtBA-£ould not directly calculate generation rates^y RCRA waste
code .
The following discussion outlines the most relevant information.
Attachment B-l provides complete citations for these data sources. The volume
B-17
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analysis and characterization of these wastes were performed simultaneously
as these pieces of information were usually presented together
EPA's Survey of Hazardous Waste Generators provided limited data on the
quantities of mixed radioactive wastes generated in 1986. It did not.
however, provide generation information by RCRA waste code. The available
Generator Survey information identifies 47 facilities that reported generating
mixed radioactive wastes. Nine of these were DOE facilities, which were not
considered in the non-DOE analysis. The remaining 38 facilities were
universities, medical institutions, industrial facilities, and waste
processors. These non-DOE facilities reported generating a total of 307,626
gallons of mixed radioactive vaste. An unknown portion of these wastes are
subject to this Third Third rule...
The 1987 Annual Survey Report developed by the State of Illinois
Department of Nuclear Safety included information on two categories of mixed
radioactive wastes:
(1) Liquid scintillation fluids. The report indicates that Illinois
generators shipped 1,444 cubic feet (10,776 gallons) of liquid
scintillation fluids. How these shipped wastes were managed is
discussed in Section B.6.
(2) "Hazardous chemicals." The report indicated that a total of 1,762
cubic feet (about 13,149 gallons) of hazardous chemicals is being
stored by Illinois generators due to technical or regulatory
concerns. The report states that "hazardous chemicals" may be
mixed radioactive wastes. No characterization data were available
beyond this classification. In addition, one generator indicated
that 53,774 cubic feet (401,299) gallons) of radioactive waste
contaminated with hazardous chemicals were being stored for future
shipment or alternative treatment.
In addi£A««L_tp the 1987 Illinois report, EPA analyzed info~*fnation from
the 1988 Illinois LLW Generator Survey This survey reported that 2,774.3
cubic feet (20.J04 gallons) of mixed radioactive wastes were being stored due
to technical or regulatory constraints on disposal. A total of 2,372.2 cubic
feet (17,705 gallons) or about 85 percent of all mixed radioactive wastes in
B-18
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this section of the survey were contaminated with RCRA solvents, for which
Land disposal restrictions are already in place. Only 3,000 gallons of the
total, therefore, are affected by this Third Third rule. Potential RCRA
hazardous wastes found in these mixed radioactive wastes included
scintillation fluids (potentially D001), acidic liquids (potentially D002),
and lead (potentially D008).
The Northwest Interstate Compact on Low-Level Radioactive Waste
Management performed surveys in 1988 and 1989 to obtain information on mixed
radioactive wastes. The 1988 survey indicated an annual mixed radioactive
waste generation rate of 16,173.5 cubic feet (120,698 gallons) for states in
the Compact. Of this total, 15,000 cubic feet (111,940 gallons) were reported
as one-time generation by a single generator. The 1989 survey indicated an
annual generation rate of 184 cubic feet (1,373 gallons). Discounting the
15,000 cubic feet generated at the one facility in 1988, the total amount
generated fell by over 80 percent.between the 1988 and 1989 surveys.
The Northwest Compact report identified the following potential First
Third, Second Third, and Third Third mixed radioactive wastes^ fr
• Chromium waste (potentially D006);
• Lead mixtures (potentially D008);
• Organic corrosives (potentially D002);
• Scintillation fluids (potentially D001); and
• Exchange resins (potentially contain EP toxicity metals)
An informal LLW report by the Massachusetts Association of Radioactive
Waste Generators (cited in Jennrich, March 1989) reports that Massachusetts
annually generates 2932 cubic feet (21,881 gallons) of scintillation
materials, which are potentially affected by this Third Third rule.
The 1988 Connecticut Low-Level Waste Management Plan also contains some
information on mixed radioactive wastes. The 1987 Survey reported, the in-
state generation of 1906.4 cubic feet (14,277 gallons) of liquid scintillation
wastes and approximately 20 gallons of lead-contaminated mixed radioactive
wastes.
B-19
-------
The 1986 Generator Survey conducted by the Northeast Interstate Low
Level Radioactive Waste Commission indicated that mixed radioactive wastes
constitute four percent of the" regional waste stream. The report stated that
4 757 cubic feet (35,500 gallons) were shipped from the region for disposal.
New York and the Midwest Compact surveys addressed mixed radioactive
waste generation that would occur during or after 1993. New York generators
indicated that 4,535 cubic feet (32,488 gallons) of mixed radioactive waste
would be generated in 1993. The Midwest Compact states indicated that 8,372
cubic feet (62,477 gallons) would be generated between January 1993 and
December 1995, which is slightly more than 20,000 gallons per year.
The above discussion outlines the best available data from the state and
interstate compact surveys and'reports. Additional surveys were analyzed (see
Attachment B-l), but the information included in those documents was of
limited use in this capacity analysis.
In addition to the survey data discussed above, EPA also evaluated
information provided in two summary reports, one performed for the Office oJ'
Technical Assessment of the U.S.. Congress (Jennrich, March, 1989, referred to
as the OTA report) and the other for the Nuclear Management and Resource
Council (Jennrich, June 1989, referred to as the NUMARC report) The reports
were useful in identifying the types of wastes generated at non-DOE
facilities. Both reports, however, indicated that the data included do not
represent national estimates of national mixed radioactive waste generation.
The OTA report, which included information from the NUMARC report,
develop seven groups of mixed radioactive wastes based on the hazardous
constituents involved:
• Liquid scintillation cocktails or fluids;
• Organic chemicals/trash;
• Lead and lead decontamination solutions;
• Waste oil/oily trash;
•»-*
•
-------
Of these seven, only four are potentially affected-by this rule: liquid
scintillation fluids are potentially D001 wastes; lead and lead
decontamination solutions are potentially D008; aqueous corrosive liquids are
potentially D002; and chromates and cadmium are potentially D007 and D006.
respectively The other three categories are either not currently RCRA
hazardous wastes (waste oil) or are wastes for which the LDRs currently are
already in effect (solvents)
In addition to the four categories listed above, investigation of the
NUMARC report also identified reactive chemicals as potential D003 mixed
radioactive wastes. Information on the quantities of these wastes generated.
however, were not available. >-
_„»-
In an effort to roughly estimate the non-DOE mixed radioactive waste
generated annually, EPA used an analysis of mixed radioactive wastes performed
by Brookhaven National Laboratory for the Nuclear Regulatory Commission which
indicated that approximately three percent of all low-level radioactive wastes
are potentially contaminated with'RCRA hazardous wastes. Applying this
percentage to the approximately 13.4 million gallons of LLW generated in 198o
(Jennrich, March 1989), roughly 400,000 gallons of mixed radioactive wastes
were generated in that year.
Although this figure provides an approximation of the amount of non-DOE
mixed radioactive wastes generated annually, several other factors had to be
considered during the analysis of non-DOE mixed radioactive waste generation
in support of this rule. First, this figure accounts for all mixed
radioactive wastes, including solvents, dioxins, and California list wastes,
for which land disposal restrictions are already in place. EPA has determined
that the mixed radioactive wastes already subject to the LDRs constitute a
significant portion of all non-DOE mixed radioactive wastes.
A second factor that is not reflected in the approximation is the
quantity of mixed radioactive wastes in storage at non-DOE facilities. If
untreated, these wastes constitute a demand for treatment capacity EPA's
review of avaj V>>] p,information sources indicates that there are Significant
quantities of mixed radioactive wastes in storage at non-DOE facilities.
As a result of the analysis of available information on the generation
of non-DOE mixed radioactive wastes, EPA has reached several conclusions:
B-21
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(1) There is a lack of quantifiable information on the
generation and management of mixed radioactive wastes at
non-DOE facilities. EPA has based this analysis on what it
considers to be the best information available. EPA
recognizes, however, that these information sources are both
limited in content and limited to only a sample of the total
non-DOE mixed radioactive waste universe. In the proposed
rule, the Agency solicited any additional information on the
generation and management of non-DOE mixed radioactive
wastes. No additional data were submitted, but several
commenters supported the proposed national capacity variance
for mixed radio-active wastes and confirmed that a lack of
commercial treatment and disposal capacity currently exists.
(2) The volumes of mixed :radioactive wastes generated at non-DOE
facilities are relatively small compared to those generated
at DOE facilities. The rough estimate of 400,000"' gallons of
mixed radioactive wastes generated annually (based on the
Brookhaven estimate that three percent of all LLW is also
mixed radioactive waste) is known to include mixed
radioactive wastes that are not affected by this rule. EPA
has determined, however, that significant quantities of
mixed radioactive wastes are in storage at non-DOE
facilities requiring treatment. Even if the actual quantity
of mixed radioactive wastes was five times the 400,000
gallon estimate, this quantity would still be less than one
percent of the DOE-generated mixed radioactive wastes that
are affected by this rule. Non-DOE mixed radioactive
wastes, therefore, are expected to have no significant
impact on the capacity analysis performed on mixed
radioactive wastes at DOE facilities. "»•»
(3) The types of mixed radioactive wastes generated at non-DOE
facilities are also generated at DOE facilities. Upon
analysis of available non-DOE information, no additional
B-22
-------
RCRA waste codes were identified that were not already
identified in the DOE data. Non-DOE mixed radioactive waste
types, therefore, are not expected to affect the capacity
analysis performed on the DOE data (i.e., no additional
treatability groups for mixed radioactive wastes had to be
established).
B.6 Analysis of Non-DOE Treatment Capacity
EPA has taken several steps to identify available non-DOE treatment
capacity for mixed radioactive wastes. In support of the capacity analysis
for the First Third Rule, EPA.-analyzed information from the 1986 Survey of
Hazardous Waste Treatment, Storage, Disposal and Recovery Facilities (TSDR
Survey) EPA's review of process-specific TSDR Survey questionnaire responses
identified no existing or planned commercial treatment, recovery, or disposal
systems for mixed radioactive wastes. To supplement information in the TSDR
Survey, EPA investigated several other sources of information-,' which were (f-
discussed in section B.5. As described below, the various sources generally
indicated that a shortfall of available treatment capacity, for mixed
radioactive wastes exists around the nation.
B.6.1 Identification of non-DOE Treatment Capacity
In order to identify available non-DOE treatment capacity, EPA
investigated available non-DOE information to determine how the different
types of mixed radioactive wastes are currently managed.
One of the primary types of mixed radioactive wastes affected by the
Third Third rule is scintillation waste. Scintillation fluids usually meet
the RCRA ignitability characteristic (D001) and are therefore Third Thirds
wastes. Combustion is the BDAT technology for D001 wastes. Investigation of
the TSDR Survey identified no RCRA-permitted combustion facilities, chat accept
mixed radioactive wastes. Because many scintillation fluids contain
radionuclides with relatively short half-lives, EPA believes that a large
amount of these materials are stored for decay and then managed as non-
radioactive hazardous wastes. This conclusion is based on information in the
B-23
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OTA report, and is supported by several of the state and interstate reports
Although the scintillation fluids, such as toluene and xylene, may eventually
be incinerated as non-radioactive wastes, no combustion facilities handling
mixed radioactive wastes have been identified.
Analysts of the state and interstate reports and other data sources
identified no available treatment capacity for any other RCRA mixed
radioactive wastes subject to the Third Third rule. The data sources
contained evidence of capacity shortfalls, as discussed below
The 1987 Illinois LLW Annual Survey Report indicated that every LLW
generator possessing "hazardous chemicals" reported storing these wastes.
Although data characterizing fhese wastes were not available, EPA assumed that
"hazardous chemicals" may corrtfl-in First Third, Second Third, or Third Third
RCRA wastes. Generators reported storing at least 400,000 gallons of
potential mixed radioactive wastes because of regulatory or technical
constraints or for future shipment or alternative management. None of these
wastes are currently being treated.
The 1989 Northwest Compact Region Survey, the 1988 Connecticut Low-La^l
Radioactive Waste Management Plan, the Northeast Interstate Low-Level
Radioactive Waste Commission's Regional Waste Management Plan (August 1989"),
and the Pennsylvania/Appalachian States Compact Low-Level Waste Management
Survey (1987) also indicate a lack of available treatment capacity for mixed
radioactive wastes. The Northeast Interstate Low-Level Radioactive Waste
Commission's Regional Waste Management Plan, for example, indicated that mixed
radioactive waste generators are concerned about the storage limitations
imposed by the land disposal restrictions because there are no disposal or
treatment facilities within the Compact region.
The OTA report, which incorporates data from the state and interstate
surveys, the NUMARC report, and an informal survey of generators, processors,
and brokers^ also did not identify significant treatment capacity for First
Third, SecigpkXhird, or Third Third wastes.
• The OTA report noted that the majority of contaminated solid
and elemental lead (potentially D008) is currently stored.
The report did indicate that some lead decontamination
solutions are currently being solidified, which could
B-24
-------
represent BOAT if determined not to be EP Toxic for lead.
EPA, however, has not identified any non-DOE stabilization
capacity The Agency welcomes any information on
stabilization capacity for D008 wastes.
• The OTA report also stated that aqueous corrosive liquids,
which are potentially D002 mixed radioactive wastes, are
currently being stored in lieu of any ongoing treatment.
EPA has not identified any non-DOE neutralization capacity
for D002 wastes
• Chromate and cadmi-um.,wastes are the only remaining potential Third
Third mixed radioactive wastes identified in the OTA report. No
available treatment capacity for chromate- or cadmium-containing
mixed radioactive wastes was identified in the reports. (These
wastes are potentially D006 and D007 mixed radioactive wastes.
According to the NUMARC report, nuclear power planes are potential.
generators of these wastes. These wastes, however, were not
reported as mixed radioactive wastes in any of the other
information sources.)
In an effort to identify additional data sources that might contain
information on mixed radioactive waste treatment capacity, EPA contacted mixed
radioactive waste experts associated with federal, state, and interstate
organizations. Attachment B-3 to this appendix describes these phone
contacts. These individuals were asked to identify any relevant data sources
on the generation of and treatment or recovery capacity for mixed radioactive
wastes. All information sources that were obtained as a result of these
conversations are listed in Attachment B-l and were incorporated into this
analysis. A majority of the individuals contacted indicated that they knew of
no available commercial treatment or recovery capacity for mixed -radioactive
wastes. Other respondents, however, identified four existing and one planned
facility that they thought may be treating mixed radioactive wastes. Upon
reinvestigation of the TSDR data set, EPA concluded that none of these
B-25
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facilities have BOAT treatment capacity that affect the capacity analysis for
the Third Third rule.
B.6.2 Summary of Non-DOE Treatment Capacity
EPA trelieves that the information-developed for this capacity analysis
constitutes the best available data on the generation and treatment of mixed
radioactive wastes at non-DOE facilities. EPA recognized that the information
on non-DOE facilities was limited and the proposed rule solicited comments by
interested parties on the generation and management of non-DOE mixed
radioactive wastes. Commente^s addressing non-DOE mixed radioactive wastes
supported the national capacrty-...variance for these wastes.
EPA has not identified any non-DOE treatment capacity for non-DOE mixed
radioactive wastes affected by this rule:
• Combustion is the BDAJ for D001 wastes which may be found in
scintillation fluids. No non-DOE combustion capacity was "" J-
identified in this capacity analysis.
• Stabilization is the BOAT for D006 (cadmium), D007
(chromium), and most D008 (lead) nonwastewaters. No non-DOE
stabilization capacity was identified in this capacity
analysis.
• Macroencapsulation is the BOAT for solid (i.e., elemental) lead
(D008). This BOAT is unique to solid lead mixed radioactive
wastes, which are often in the form of shielding, lead "pigs," or
bricks. These waste are known to be generated at non-DOE
jiltties. No surface contamination/ encapsulation treatment
=»:fffs
Swacity, however, was identified in this analysis.
&*•
*•+::-. ~*+
m i ML •• > • -
Chemical Precipitation is the BOAT for D006 and D008
wastewaters. No non-DOE chemical precipitation capacity was
identified.
B-26
-------
• Chromium Reduccion followed bv Chemical Precipitation is the BOAT
for D007 (chromium) wastewaters. No non-DOE chromium reduction
followed by chemical precipitation treatment capacity was
identified in this analysis.
• 'Neutralization is the BOAT for D006 and D008 wastewaters.
No non-DOE neutralization treatment capacity was identified
in this capacity analysis.
In addition to the treatability groups discussed above, EPA has
identified two other treatment technologies that are unique to mixed
radioactive wastes -- amalgama'Eipji (for elemental mercury) and incineration as
amethod of treatment (for hydraulic oils containing mercury) -- which were
discussed in sections B.4.4 and B.4.10. No non-DOE treatment capacity for
these technologies was identified'.
Although no additional First Third, Second "Third, or Third Third waste
codes have been identified specifically, a large amount of urfcharacterized Ir
mixed radioactive wastes are generated at non-DOE facilities. (See Section
B.5.) These uncharacterized mixed radioactive wastes may contain RCRA wasi=
codes not identified above. Because no RCRA treatment capacity is available
for mixed radioactive wastes, any generation of First Third, Second Third, or
Third Third wastes not identified here would face a capacity shortfall.
B.7 National Capacity Variance for Mixed Radioactive Wastes
Based on the analysis discussed above, EPA has determined that there is
currently insufficient BOAT or equivalent treatment capacity for mixed
radioactive wastes at both DOE and non-DOE facilities. Because a treatment
capacity shortfall was identified for every mixed radioactive waste
creatability group, EPA is proposing to grant a national capacity variance for
all mixed radioactive wastes. The waste codes that have been id»atified in
this analysis are arranged in treatability groups according to BOAT or the
equivalent in Table B.I, which also summarizes the treatment capacity
shortfalls.
B-27
-------
Table B.I
Summary of National Capacicy Variance for Mixed Radioactive Waste
(millions of gallons/year)
3DAT or '^Sfer
EQUIVALENT f^Tt
Stabilization
Surface Oeactivation
Followed by Encapsulation
Combustion
Incineration
Followed by Ash
Stabilization
Neutralization
Vitrification
QUANTITY
RCRA WASTE REQUIRING MAXIMUM
CODE(S) TREATMENT TREATMENT
D005
D006
D007
D008
D011
D008
D001
D012
i- -D013
D01A
DOW
D017
DO 09
D002
DOOA
nonwastewaters 63 6 28
nonwastewaters
nonwastawatars
nonwastewaters
nonwastewaters
(solid) <0.2 :
P068 1.6 :*
U002
U019
U022
U213
U220
U226
U239
(hydraulic oils) <0.1 0
26.2 0.2
nonwaatewatars 14 *' 0 F
D010 nonwaitawatars
Hifh-laval mixed wastes
Alkaline Chlorination
D003
0.8
Traatmant of Raactivva
D003
Charaical Pracipitation
Sulfida Pracipitation
Amalgamation with Zinc
Matali Racovary
Chromium Reduction
Followed by
Precipitati
Aliallna)
FoUowtA
Preeipit«ti
Alkaline ,.__._,
Followed by St«biTlt«tioir
of Metals
Soil and Debris
Other
oastewatars
D005 waatewaters
D006 wastewaters
D008 waatewaters
D010 wastewatars
D011 waatewatera
DOOfl
D009 (elemental)
P015
D007 wastewaters
F007
F008
F009
F006 wastewaters
F006 nonwastewaters
various
varioua/unknown
51.6
0.2
0.5
8. 1
193
3.3
Combustion capacity expressed in terms of "available" capacity.
B-28
-------
No information was available for mixed radioactive wastes that are
disposed of in deep wells. For this reason, EPA is not proposing to grant a
national capacity variance for these wastes
B-29
-------
ATTACHMENT B-l
SOURCES OF INFORMATION ON NON-DOE MIXED RADIOACTIVE WASTES
B-30
-------
This attachment describes the sources of information on non-DOE wastes
gathered and analyzed by EPA as part of the capacity analysis. The attachment
is organized in the following sections: EPA national surveys, overview
reports, state and interstate compact surveys and reports, and telephone
contacts.
NATIONAL SURVEYS
In an effort to develop information on the universe of hazardous waste
management in the United States, EPA developed two comprehensive national
surveys. •'•'
TSDR Survey
The General Facility Information questionnaire requested information on
types and commercial status of mixed radioactive waste management, volumes
treated in 1986, the maximum quantity of mixed radioactive wastes that could
have been treated in 1986, and when treatment would discontinue at each
facility No specific waste code or waste stream information was requested,
but some waste codes were determined through the use of facility notes and
facility contacts. The TSDR survey was used to identify any operating
facilities that treat or recover mixed radioactive wastes, and to investigate
operations at facilities that could potentially handle mixed radioactive
wastes.
Generator Survey
The Generator Survey Questionnaires contain very general references to
mixed radioactive wastes. Specifically, Questionnaire GA (General Facility
Information) asfcs"-ehree basic questions: (1) Did the facility generate mixed
radioactive wastes on-site; (2) What quantity was generated; and (3) How are
these mixed radioactive wastes managed. Although the Generator Survey data
set is currently incomplete, only 47 facilities have been identified as
indicating that they generate mixed radioactive wastes. Several of these were
DOE facilities and several were research universities. Although these
B-31
-------
facilities reported mixed radioactive waste generation quantities, EPA is of
the opinion that these facilities represent only a small sample of the mixed
radioactivps.waste-generating community. This conclusion is based on
Jr*"'7 '
infonnat£on*rContained in the overview reports listed below, which indicace
•«»V-
that hundreds of facilities are potential generators of mixed radioactive
wastes. For: example, over 100 nuclear power plants are potential generators
of mixed radioactive wastes. Use of information in the Generator Survey is
discussed within, the text of this appendix.
B-32
-------
OVERVIEW REPORTS
In response to increased concern over the responsible management of
mixed radioactive wastes, several national trade associations and government
agencies undertook studies to examine the generation and management of mixed
radioactive wastes. These studies are outlined below.
• Jennrich, E.A., Rogers and Associates Engineering Corporation,
Management Practices and Disposal Concepts for Low-Level Radioactive
Mixed Waste, Congress of the United States, Office of Technology
f-
Assessment, Washington,. D. C., March 1989
This report is perhaps the most comprehensive analysis of low-level
mixed radioactive wastes completed to date. It identifies generators,
processes, and RCRA hazardous wastes. The report, however, provides no
national estimates of mixed radioactive waste generation. The data w^re
developed through reviewing existing information, contacting national
associations, and where necessary, surveying a sample of LLW generators,
processors, and brokers. The purpose of the study was to identify
current management practices and to develop a common understanding of
mixed radioactive waste management system performance goals and disposal
system design features. The information in this document was useful for
identifying processes and management practices at non-DOE facilities.
Generation rate information was also useful for determining the relative
magnitudes of different types of mixed radioactive wastes generated at
the various types of facilities.
• Jennrich, E.A., Rogers and Associates Engineering Corporation, The
Management of Mixed Waste in the Nuclear Power Industry, prepared for
Nuclear Management and Resources Council (NUMARC), Washington, D.C.,
June, 1989.
This analysis provided conservative (i.e., upper bound) estimates of
mixed radioactive waste generation at nuclear power plants. The
document carefully notes that its estimates of mixed radioactive waste
B-33
-------
generation ac a typical nuclear power plant should not be seen as
definitive. The value of the information presented in this report is
not so much in the magnitude of mixed waste volumes as it is in
identifying processes that potentially produce mixed wastes.
Brookhaven National Laboratory. Analysis of Low-Level Wastes: Review of
Hazardous- Waste Regulations and Identification of Radioactive Mixed
wastes. Final Report: study prepared for the Nuclear Regulatory
Commission, Washington, D.C., December 1985.
This report examines th§-identification and management of low-level
..»
radioactive mixed wastes. •'-Brookhaven developed the data by reviewing
existing data and surveying several of the largest LLW generators.
Wastes of potential concern that were analyzed include: Liquid
scintillation wastes, spent organic solvents, lead metal, and chromate-
containing wastes.
Weaknesses in the Brookhaven information for purposes of the Third Third
capacity analysis include a lack of detailed waste characterization and
problems associated with using a representative sample -- no national
estimates of specific mixed radioactive waste quantities were developed.
In terms of the capacity analysis, the information in these documents
was useful primarily in targeting processes and waste codes of concern
to be analyzed in more detail.
EPA, Mixed Energy Waste Study (MEWS), Office of Solid Waste, Washington,
D.C., 20640, March 1987
This repac-e summarizes the findings of EPA's MEWS Task Force- which
investigated DOE's management of HLW and TRU wastes in order to compare
the practices to requirements for hazardous waste management under RCRA
Subtitle C. This report was used to identify some of the types of mixed
-------
radioactive wastes chac are
investigation of the data provided by DOE.
B-35
-------
STATE AND INTERSTATE COMPACT SURVEYS AND REPORTS
The following state and interstate compact surveys and reports were
evaluated during this capacity analysis:
Carlin, Elaine, Mixed Waste in Washington and the Northwest Compact
Region: Problem Definition. Timelines, and Management Options, Low -
Level Radioactive Waste Program, Department of Ecology, State of
Washington, 1989
Carlin, Elaine, Mixed Waste Management in Washington and the Northwest
Compact Region. Low-Level Radioactive Waste Program, Department of
Ecology, State of Washington, 1988.
Connecticut Hazardous Waste Management Service, 1988 Connecticut Low-
Level Radioactive Waste"Management Plan. December 1988.
Illinois Department of Nuclear Safety, 1987 Annual Survey Report. May
1989
Illinois Department of Nuclear Safety, 1988 LLW Generator Survey, (data
set on facilities storing mixed radioactive wastes due to regulatory or
technical constraints on disposal)
New York State Energy Research and Development Authority, 1988 New Yonc
State Low-Level Radioactive Waste Status Report. June 1989
Northeast Interstate Low-Level Radioactive Waste Commission, Regional
Management Plan Update. August 1989.
Northwest Interstate Compact on Low-Level Radioactive Waste Management,
Options for Mixed Waste Management. Discussion Paper. April 1989
(revised)
Pennsylvania Department of Environmental Management, Appalachian States
Compact Low-Level Radioactive Waste Management Survey - 1987. 1988.
Pennsylvania Department of Environmental Management, Pennsylvania and
Maryland Low-Level Radioactive Waste Management Survey - 1986. October
1987
Southeast Compact Commission, 1987 Summary of Low-Level Radioactive
Waste Management in the Southeast Compact. 1988.
B-36
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TELEPHONE CONTACTS
In an effort co identify more information sources, data, or reports,
several state, regional, and federal officials were contacted by telephone.
These groups included the following:
Afton & Associates (Management Consultants of Working Group for Central
Compact Commission) Contact: Edgar Miller
Central Compact Commission, Lincoln, NE. Contact: Jay Ringenberg
Commonwealth of Pennsylvania, Department of Environmental Resources,
Bureau of Radiation Protection, Division of Nuclear Safety, 200 N. Third
Street, Fulton Bldg., 16th Fl., P.O. Box 2063, Harrisburg, PA 17120
Contact: Kenneth Singh..
I,*"
Congress of the United States, Office of Technology Assessment,
Washington, D.C. Contact:. Gretchen McCabe.
Connecticut Hazardous Waste Management Service, Suite 360, 900 Asylum
Ave., Hartford, CT 06105-1904. Contact: Meg Harvey
Envirosphere (consultant for Southwest Compact), WA. Contacts: Tim *
Gould- and Nancy Kerner.
Illinois Department of Nuclear Safety, 1035 Outer Park Dr., Springfield,
IL 62704. Contact: Melissa Young.
Midwest Low-Level Radioactive Waste Commission, 350 No. Robert St., Room
588, St. Paul, MN 55101. Contact: Susan Olsson, Assistant to the
Director
Nevada State Division of Health, Carson City, NV. Contact: John Vaden.
New York State Energy Research and Development Authority, Communications
Dept., Two Rockefeller Plaza, Albany, NY 12223. Contact: Ann
Constantino.
Nuclear Regulatory Commission--Washington State, Olympia, WA. Contacts:
Toby Michelina and Stephanie Ko, Low-Level Waste Management Group.
Principled Negotiations Inc., Amherst, NH. Contact: Arnie Wight.
Rocky Mountain Compact Commission, Denver, CO. Contact: Karen Salzer
Rogers ana Associates Engineering Corp., UT. Contact: Ed Jennrich.
South Carolina Dept. of Health and Environmental Control, Office of
Radiological Health, Waste Division. Contact: Vergil Autry.
B-37
-------
Southeast Compact Commission for Low-Level Radioactive Waste Management
3901 Barrett Dr., Suite 100, Raleigh, NC 27609 Contact: Kathryn
Visocki.
Southwest Compact Commission. Sacramento, CA. Contacts: Reuben
Junkert, Dept. of Health Services and Russ Huck.
State^ of Washington, Department of Ecology. Mail Stop PV-11, Olympia.
VJA. Contacts: Sarah Hana. Radiation Health Physicist, LLRW Management
Program and Earl Livennan and Roger Stanley
State of Washington Department of Health. Contacts: Gary Robeson and
Mike Elsen.
B-38
-------
;"-';•: ATTACHMENT B-2
TECHNOLOGY-BASED SUMMARIES OF DOE MIXED RADIOACTIVE WASTE
GENERATION AND TREATMENT CAPACITY
B-39
-------
TABLE S-2(a)
DOE NIT TREATMENT CAPACITY AT THI END OF 1989
(Quantities exprassad in gallons)
BOAT/TREATMENT TECHNOLOGY - STABILIZATION ••«••
Alfactad wasti codas:
D005 nonwastawaters
D006 nonwastawaters
3007 nonwastawatars
D008 nonwastawatars
D011 nonwastawaters
F006 nonwastawatars
FACILITY':
MAXIMUM
ON-SITE
TREATMENT
CAPACITY
QUANTITY
REQUIRING
TREATMENT
AMES LAB
ARGONHE NATIONAL LAB E
ARGONHE NATIORAL LAB W
BROOKHAVEN NATIONAL LAB
FMPC
HANfORD
IDAHO NATIONAL ENGINEERING LAB
ITRI
KANSAS CITY
LIVERMORE SNL
LOS ALAMOS NATIONAL LAB
MOUND
NEVADA TEST SITE
OAK RIDGE NATIONAL LAB
PANTEX
PINELLAS
ROCKY FLATS
SANDIA NATIONAL LAB
SAN LLNL
SAVANNAH RIVER
WEST VALLEY
0
0
0
0
0
0
680.050
0
0
0
0
0
0
1,518,093
0
0
121,737
0
0
0
4*4.120
37
35,953
5,277
193
1,69*
6
2
125
22
20,333
0
275
153
0
,648
,758
.851
705
"" 55
67
.967
978
79
.546
,782
,114
.186
,215
656
.123
0
TOTALS: 2,764,000
NET STABILIZATION CAPACITY: (60.886,158)
63,650,158
* SAN/LLNL and Savannah River havt stabilization tr«atm«nt
units, but th«y hava not b««n dattrminad to b« RCRA BDATs
B-40
-------
TABLE B-2tb)
DOE NET TREATMENT CAPACITY AT THE END OF 1989
(Quantities «xprtss«d in gallons)
3DAT/TREATMENT TECHNOLOGY - MACROENCAPSULATION *«*«
Aff«ct«d waste cod«s. D008 solid
FACILITY
MAXIMUM
ON-SITE
TREATMENT
CAPACITY
QUANTITY
REQUIRING
TREATMENT
AMES LAB
ARGONNE NATIONAL''£A4 ,- E
ARGONNE NATIONAL LAB'- W
BROOKHAVEN NATIONAL LAB
FMPC
HANTORD
IDAHO NATIONAL ENGINEERING LAB
ITRI
KANSAS CITY
LIVERMDRE - SNl
LOS ALAMOS NATIONAL LAB
MOUND
NEVADA TEST SITE
OAK RIDGE NATIONAL LAB
PANTEX
PINELLAS
ROCXY FLATS
SANDIA NATIONAL LAB
SAN LLNL
SAVANNAH RIVER
WEST VALLEY
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
214
0
0
74. 504
21. 136
54
120
0
0
0
••• o
0
3. 140
0
7,537
0
117 ;
48,600
0
TOTALS:
—* NET STABILIZATION CAPACITY:
(155.422)
155,422
B-41
-------
TABLE B-ZCO
DOE NET TREATMENT CAPACITY AT THE END OF 1989
(Quantities expressed in gallons)
***** BOAT TREATMENT TECHNOLOGY - COMBUSTION «-«•*
Afficted west* codes • D001 'J239
P068 3012
J002 2013
U019 D014
U022 D015
U213 D016
U220 D017
U226
FACILITY;-..
AVAILABLE
ON-SITE
TREATMENT
1 CAPACITY
QUANTITY
REQUIRING
TREATMENT
AMES LAB
ARGONNE NATIONAL LAB E
ARGONNE NATIONAL LAB W
BROOKHAVEN NATIONAL LAB
FMPC
HANTORD
IDAHO NATIONAL ENGINEERING LAB
ITRI
KANSAS CITY
LIVERMORE SNL
LOS ALAMOS NATIONAL LAB
MOUND
NEVADA TEST SITE
OAK RIDGE NATIONAL LAB
PANTEX
PINELLAS
ROCKY FLATS
SAHDIA NATIONAL LAB
SAN - LLNL
SAVANNAH RIVER
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
9
9
1. 557
6
i,
10
17
3
4
11
0
200
0
300
0
872
ti.8
i!7
0
317
529
964
0
701
76*
0
0
522
018
935
TOTALS:
**« NET COMBUSTION CAPACITY:
1.637.087
(1,637,087)
In this table, on-lit* treatment capacity is expressed in terms of
"available" capacity rather than "maximum" capacity.
Four DOE facilities have operating combustion units. The incinerator at
INEL (WERF) is primarily a LLW (non-hazardous waste) incinerator but does
burn some mixed waste. The Oak Ridge incinerator is believed to handle
only on-site wastes. The available treatment capacity of these units has
been assigned to mixed radioactive wastes other than those containing First
Third, Second Third, or Third Third wastes (i.e., solvents and dioxins or
California list wastes).
B-42
-------
TABLE B-2(d)
DOE NET TREATMENT CAPACITY AT THE END OF 1989
(Quantities expressed in gallons)
BDAT/TREATMENT TECHNOLOGY - NEUTRALIZATION
Affected wast« codes: D002
FACILITY
MAXIMUM
ON-SITE
TREATMENT
I CAPACITY
QUANTITY
REQUIRING
1 TREATMENT i
AMES LAB
ARGONNE NATIONAL LAB E
ARGONNE NATIONAL LAB W
BROOKHAVEN NATIONAL"LAB
FMPC
HANTORD
IDAHO NATIONAL ENGINEERING LAB
ITRI
KANSAS CITY
LIVERHORE SNL
LOS ALAMOS NATIONAL LAB
MOUND
NEVADA TEST SITE
OAK RIDGE NATIONAL LAB.
FANTEX
PINELLAS
ROCTY FLATS
SANDIA NATIONAL LAB
SAN LLNL
SAVANNAH RIVER
TOTALS: 206,68*
*** NET NEUTRALIZATION CAPACITY: (25,965.056)
103
70
11
20
0
,963
0
.013
0
0
0
0
0
0
0
0
0
,889
0
0
0
0
,819
0
0
10*. 106
0
31*, 583
264
11,507,219
1.556.031
2,*92
0
5
0
0
0
54,821
0
..0
0
0
2.556
12,629.663
26,171,7*0
* No neutralization treatment capacities were provided.
In cases where DOE indicates current treatment is neutralization,
the standard annual generation rate of the wait* stream is
used as the capacity of the treatment unit. Wastes in inventory
are assumed to be untreated.
B-43
-------
TABLE 3-2C.)
DOE NET TREATMENT CAPACITY AT THE END CF 1989
:Quantities expressed in gallons)
EDAT/TREATMENT TECHNOLOGY - VITRIFICATION
Affected waste codes
;OC4 nonwastewaters
2010 nonwastewaters
FACILITY
AMES LAB
ARGONNE NATIONAL "LAB E
ARGONNE NATIOHAL.-LAB w
BROOKHAVEN NATIONAL. LAB
FMPC
HANFORD
IDAHO NATIONAL ENGINEERING LAB
ITRI
KANSAS CITY
LIVERMORE SNL
LOS ALAMOS NATIONAL LAB
MOUND
NEVADA TEST SITE
OAK RIDGE NATIONAL LAB
PANTEX
PINELLAS
ROCKY FLATS
SANDIA NATIONAL LAB
SAN LLNL
SAVANNAH RIVER
MAXIMUM
CN-SITE
TREATMENT
CAPACITY
0
0
0
0
0
0
0
0
0
0
0
0
0
0.
0
0
0
0
0
0
QUANTITY
REQUIRING
TREATMENT
0
0
0
0
o
3.988.439
0
0
0
0
16,659
0
0 !
0
' 0
0
0
2,925
147
5,0*6,481
TOTALS :
NET VITRIFICATION CAPACITY:
0 14,062,55*
(14.062.554)
-------
TABLE B-2U)
DOE NET TREATMENT CAPACITY AT THE END CF 1989
(Quantities *xpr«ss«d in gallons)
BOAT/TREATMENT TECHNOLOGY " ALKALINE CHLORINATICN
Aff«ct*d wast* cod«s: D003
FACILITY
MAXIMUM
ON-SITE
TREATMENT
CAPACITY
QUANTITY
REQUIRING
TREATMENT
AMES LAB
ARGONNE NATIONAi"'tASt r E
ARGONNE NATIONAL LAB ^ W
BROOKHAVEN NATIONAL LAB
FMPC
HANFORD
IDAHO NATIONAL ENGINEERING LAB
ITRI ' -
KANSAS CITY
LIVERMORE - SNL
LOS ALAMOS NATIONAL LAB
MOUND
NEVADA TEST SITE
OAX RIDGE NATIONAL LAB
PANTEX
PINELLAS
ROCKY FLATS
SANDIA NATIONAL LAB
SAN LLNL
SAVANNAH RIVER
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Q
0
0
0
0
3.276
0
0
3,951
740,908
0
0
0
0
0
"*'' o I
0 I
0
0
0
4.522
358
34,580
TOTALS:
NET ALKALINE CHLORINATION CAP
(787,59J)
787,595
B-45
-------
TABLE B-2(g)
DOE NET TREATMENT CAPACITY AT THE END CF 1989
(Quantities expressed in gallons)
BOAT/TREATMENT TECHNOLOGY - TREATMENT OF REACTIVES **"*
Affected waste codas.
0003
FACILITY
AMES LAB
ARGONNE NATIONAL LAB E
ARGONNE NATIONAL^LAB W
BROOKHAVEN NATIONAL LAB
FMPC -' ,- ,
HAWTORD ' -
IDAHO NATIONAL ENGINEERING LAB
ITRI
KANSAS CITY
LIVEHMORE SNL
LOS ALAMOS NATIONAL LAB
MOUND
NEVADA TEST SITE
OAX RIDGE NATIONAL LAB-
PANTEX
PINELLXS
ROCKY FLATS
SAJJDIA NATIONAL LAB
SAN LLNL
SAVANNAH RIVER
TOTALS:
*•• NET CAPACITY: (4,
MAXIMUM
ON-SITE
TREATMENT
CAPACITY
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
'67)
QUANTITY
REQUIRING
TREATMENT
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
*• o
0
4.767
0
0
A. 767
B-46
-------
TABLE B-2(h)
DOE NIT TREATMENT CAPACITY AT THE END OF 1989
(Quantities txpr«ss«d in gallons)
BOAT/TREATMENT TECHNOLOGY - CHEMICAL PRECIPITATION
Affectad waste codts:
D004 wastawaters
0005 wast»wat»rs
0006 wast«*at«r3
D008 wastcwattrs
D010 wasttwattrs
D011 wast«wat«rs
FACILITY
MAXIMUM
ON-SITE
TREATMENT
I CAPACITY
QUANTITY
REQUIRING
| TREATMENT I
AMES LAB
ARGONNE NATIONAL LAB - E
ARGONNE NATIONAL LAB."- W
BROOKHAVEN NATIONAL LAB
FMPC
HANTORD
IDAHO NATIONAL ENGINEERING LAB
ITRI
KANSAS CITY
LIVERMORZ SNL-
LOS ALAMOS NATIONAL LAB
MOUND
NEVADA TEST SITE
OAK RIDGE NATIONAL LAB
PANTEX
PINELLAS
ROCKY FLATS
SANDIA NATIONAL LAB
SAN LLNL
SAVANNAH RIVER
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
•" o
0
0
0
0
0
27
0
11,549
0
NET CAPACITY:
TOTALS:
(11,576)
11,576
B-47
-------
TABLE B-2(i)
DOE NET TREATMENT CAPACITY AT THE END OF 1989
(Quantities «rpr«J3«d in gallons)
BOAT/TREATMENT TECHNOLOGY - SULFIDE PRECIPITATION
Affected waste cod«s D009 wastewat«rs
FACILITY
MAXIMUM
ON-SITE
TREATMENT
I CAPACITY
QUANTITY
REQUIRING
TREATMENT ,
AMES LAB
ARGONNE NATIONAL^LAB E
ARGONNE NATIONAL LAB - W
BROOKHAVEN NATIONAL LAB
FMK ' •' •'.
HANFORD
IDAHO NATIONAL ENGINEERING LAB
ITRI
KAHSAS CITY
LIVERMORE ;NL
LOS ALAMOS NATIONAL LAB
HOUND
NEVADA TEST SITE
OAK RIDGE NATIONAL LAB
PANTEX
PINELLAS
ROCKY FLATS
SANDIA NATIONAL LAB
SAN LLNL
SAVANNAH RIVER
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
o
o
o
0
->. 0
0
0
0
0
51.651. 100
TOTALS:
•• NET SULFIDE PRECIPITATION CAPACITY:
0 51.651,100
(51,651,100)
B-48
-------
TABLE B-2(j)
DOE NET TREATMENT CAPACITY AT THE END CF 1989
(Quantities expressed in gallons)
3DAT/TREATMENT TECHNOLOGY - AMALGAMATION **
Affected wast* codes: 2009 (elemental)
FACILITY
MAXIMUM
ON-SITE
TREATMENT
1 CAPACITY
QUANTITY
REQUIRING
1 TREATMENT I
AMES LAB
ARGONNE NATIONAL LAB E
ARGONHE NATIONAVLAB W
BROOKHAVEN NATIONAL LAB
FMPC
HANTORD
IDAHO NATIONAL ENGINEERING LAB
mi
KANSAS CITY
LIVERMORE SNL
LOS ALAMOS NATIONAL" LAB
MOUND
NEVADA TEST SITE
OAK RIDGE NATIONAL LAB,
PANTEX
PINELLAS
ROCKY FLATS
SAMDIA NATIONAL LAB '
SAN LLNL
SAVANNAH RIVER
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3
0
793
0
0
0
0
0
0
0
0
0
0
•"• 0
0
0
0
116
TOTALS:
*** NET AMALGAMATION WITH ZINC CAPACITY
912
(912)
B-49
-------
TABLE B-2(k)
DOE NET TREATMENT CAPACITY AT THE END OF 1989
(Quantities expressed in gallons)
BOAT/TREATMENT TECHNOLOGY - METALS RECOVERY
Affected waste codes.
P015
FACILITY
MAXIMUM
ON-SITE
TREATMENT
1 CAPACITY
QUANTITY
REQUIRING
! TREATMENT
i
AMES LAB
ARGONNE NATIONAL LAB E
ARGONNE NATIONAL LAB H
BROOKHAVEN NATIONAL LAB
FMPC
HANFORD .r;
IDAHO NATIONAL ENGINEERING LAB
ITRI
KANSAS CITY
LIVERMORE - SNL
LOS ALAMOS NATIONAL LAB
MOUND
NEVADA TEST SITE
OAK RIDGE NATIONAL LAB
PANTEX
PINELLAS
ROCKY FLATS
SANDIA NATIONAL LAB
SAN LLNL
SAVANNAH RIVER
0
D
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
o
0
0
0
246
0
143. 791
62
0
0
0
0
0
0
18,499
,.o
0
0
1.597
0
TOTALS:
••• NET METALS RECOVERY CAPACITY:
164,195
(164,195)
B-50
-------
TABLE B-2U)
DOE NET TREATMENT CAPACITY AT THE END OF
(Quantitits «jcpr»ss«d in gallons)
1989
.**.. BOAT/TREATMENT TECHNOLOGY - CHROMIUM REDUCTION FOLLOWED BY CHEMICAL PRECIPITATION
Af£«cted waste codes D007 wastew«t«rs
FACILITY
MAXIMUM
ON-SITE
TREATMENT
1 CAPACITY
QUANTITY
REQUIRING
1 TREATMENT !
AMES LAB
ARGONNE NATIONAL LAB E
ARGONNE NATIONAL LAB W
BROOKHAVEN NATIONAL LAB
FMPC
HAWORD
IDAHO NATIONAL ENGINEERING LAB
ITRI
KANSAS CITY
LIVERMORE SNL
LOS ALAMOS NATIONAL LAB
MOUND
NEVADA TEST SITE
OAK RIDGE NATIONAL LAB
PANTEX
PINELLAS
ROCKY FLATS
SAHDIA NATIONAL LAB
SAN - LLNL
SAVANNAH RIVER
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
*;0
0
0
0
1,650
0
TOTALS:
*•* NET CAPACITY:
0
(1,650)
1,650
B-51
-------
TABLE B-2(m)
DOE NET TREATMENT CAPACITY AT THE END OF 1989
(Quantities «rpr«si«d in galloni)
ALKALINE CHLORINATICN FOLLOWED BY CHEMICAL PRECIPITATION
Affected wajt» codes: F007
F008
F009
FACILITY
MAXIMUM
ON-SITE
TREATMENT
1 CAPACITY
QUANTITY
REQUIRING
1 TREATMENT ;
AMES LAB
ARGONNE NATIONAL "LAB E
ARGONNE NATIONAC LAB W
BRCOKHAVEN NATIONAL'-LAB
FMPC
HAN70RD
IDAHO NATIONAL ENGINEERING LAB
ITRI
KANSAS CITY
LIVERMORE SNL
LOS ALAMOS NATIONAL LAB
MOUND
NEVADA TEST SITE
OAK RIDGE NATIONAL LAB '
PANTEX
PINELLAS
ROCKY FLATS
SANDIA NATIONAL LAB
SAN LLNL
SAVANNAH RIVER
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
181,16*
0
0
0
6,957
0
0
0
0
0
0
0
0
•«• 0
0
0
338, 197
t
0
0
TOTALS:
»** NET CAPACITY:
(526,318)
526,318
B-52
-------
TABLE B-2(n)
DOE NET TREATMENT CAPACITY AT THE END OF 1989
(Quantitia< expressed in gallons)
ALKALINE CHLORINATICN FOLLOWED BY STABILIZATION OF METALS ***"•
Affected waste codes: F006 nonwastewaters
MAXIMUM
ON-SITE
TREATMENT
CAPACITY
QUANTITY
REQUIRING
TREATMENT
AMES LAB
ARGONNE NATIONAE-'LAR. - E
ARGONNE NATIONAL LAB"-- W
BROOKHAVEN NATIONAL LAB
FMPC
HANFORD
IDAHO NATIONAL ENGINEERING LAB |
ITRI
KANSAS CITY
LIVERMORE SNL
LOS ALAMOS NATIONAL LAB
MOUND
NEVADA TEST SITE
OAK RIDGE NATIONAL LAB
PANTEX
PINELLAS
ROCKY FLATS
SANDIA NATIONAL LAB
SAN LLNL
SAVANNAH RIVER
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
•»'• 0
8,096. 1*5
0
0
0
0
0
0
TOTALS:
••• NET CAPACITY:
(8,096,145)
8.096,145
B-53
-------
TABLE B-2(o)
DOE NET TREATMENT CAPACITY AT THE END OF 1989
(Ou«ntiti»» •rprcmd in gallons)
SOIL AND DEBRIS *•»•«
Affected wast.* codes: VARIOUS
FACILITY
MAXIMUM
ON-SITE
TREATMENT
1 CAPACITY
QUANTITY
REQUIRING
TREATMENT 1
AMES LAB
ARGONNE NATIONAL LAB E
ARGONNE NATIONAL LAB W
BRCOKHAVEN NATIONAL LAB
FMPC ;•-•
HASrORD
IDAHO NATIONAL ENGINEERING LAB
ITRI
KANSAS CITY
LIVERMORE - SNL
LOS ALAMOS NATIONAL LAB
MOUND
HFVADA TESt 3ITE
OAK RIDGE NATIONAL LAB
PANTEX
PINELLAS
ROCKY FLATS
SANDIA NATIONAL LAB
SAN - LLNL
SAVANNAH RIVER
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
132
1189
0
0
0
3
189,755,309
0
0
0
0
0
2,991.222
0
0
"'o
0
0
0
314,925
TOTALS:
**« SOIL AND DEBRIS REQUIRING TREATMENT:
193,062.777
(193,062,777)
B-54
-------
ATTACHMENT B-3
REQUESTS FOR NON-DOE MIXED RADIOACTIVE WASTE"
GENERATION AND TREATMENT DATA:
TELEPHONE LOGS
B-55
-------
August 22, 1989
Kenneth Singh
Commonwealth of Pennsylvania, Department of Environmental Resources
Bureau of Radiation Protection, Division of Nuclear Safety
200 N. Third Street
Fulton Building, 16th Floor
P.O. Box 2063
Harrisburg, PA 17120
(717) 783-2300
• 1987 Appalachian States Compact Low-Level Radioactive Waste Survey did
not get a good response for mixed radioactive wastes. No facility names
or locations are provided, nor are there any data tables.
• As of January 1990. generators of radioactive wastes for disposal will
have to submit quarterly reports.
• Anticipates having a mixed', radioactive waste facility in Pennsylvania by
1995.
August 22, 1989
Ann Constantino
New York State Energy Research and Development Authority -
Communications Department " *"
Two Rockefeller Plaza
Albany, NY 12223
(518) 465-6251
• Sending New York State LLU Survey Report (received).
August 22, 1989
Meg Harvey
Connecticut Waste Management Service
Suite 360, 900 Asylum Ave.
Hartford, CT 06105-1904
(203) 244-2007
• Has incomplete data from calendar year 1987. Currently updating data on
mixed radioactive wastes. Target date for completion of this update is
Oct. 12 (received 1987 data)
• Update of 1988 report will be sent (not received).
• Data will include New England Compact information. ^
B-56
-------
August 22, 1989-
Melissa Young
Illinois Department of Nuclear Safety
1035 Outer Park Drive
Springfield, IL 62704
(217) 785-9900
• Her department published a report based on Illinois LLW surveys
However, the report contains little data on mixed radioactive wastes
• Will send report and mixed radioactive waste survey data (received)
August 22, 1989
Vergil Autry
South Carolina Department of Health and Environmental Control
Office of Radiological Health-- ..
Waste Division
(803) 734-5000
• Barnwell site restricts mixed radioactive wastes from disposal.
August 22, 1989 ^
John Vaden
Nevada State Division of Health
Carson City, NV
(702) 885-4475
• License at the Beatty site prohibits mixed radioactive waste disposal.
August 24, 1989
Susan Olsson
Assistant to the Director
Midwest Low-Level Radioactive Waste Commission
350 N. Robert Street, Room 588
St. Paul, MN 55101
(612) 293-0126
• Midwest Compact Commission conducted a survey. She will send
data on mixed radioactive waste (received).
• This Compact wants its own waste disposal facility by 1993.
• Estima&a*r-*hAt one percent of their radioactive waste strewn is mixed
radioactive waste.
B-57
-------
August 28, L989
Toby Michelina
Nuclear Regulatory Commission -- Washington State
Olympia, WA
(206) 459-6862
• Mixed wastes were stored at the Hanford disposal facility in the past,
but are no longer.
August 31, 1989
Mike Elsen
State of Washington, Department of Health
Olympia, WA
(206) 753-1116
^-
• The Hanford facility accepted scintillation fluids and some oils until
1984-85. However, its restrictions on accepting mixed radioactive
wastes are now more stringent than current RCRA requirements.
August 31, 1989
Kathryn Visocki
Executive Director
Southeast Compact Commission for Low-Level Radioactive Waste^Management
3901 Barrett Drive, Suite 100
Raleigh, NC 27609
(919) 781 7152
• Doesn't have much information, but will send a report (received).
September 12, 1989
Ed Jennrich and Bob Beard
Rogers and Associates Engineering Corp.
(801) 263-1600
• Indicated that Texas, which is not currently in a Compact, generates
approximately 1000 cu. ft./year of mixed radioactive wastes.
• Referred to Arnie Wight of Principaled Negotiations, Inc. as well as
heads of various Compacts.
B-58
-------
October 5, 1989
Russ Huck
Southwest Compact Commission
Sacramento, CA
(916) 445-0498
• Referred to Envirosphere -- consultants for this Compact.
• No treatment capacity exists for mixed radioactive wastes at this time;
this Compact is still in its infancy
October 5, 1989
Karen Salzer
Rocky Mountain Compact Commission
Denver, CO
(303) 825-1911 "
• Has no information on mixed radioactive wastes for the Compact.
October 5, 1989
Jay Ringenberg
Chair of the Working Group
Central Compact Commission ->• $--
Lincoln, NE
(402) 471-3380
• The five states in this Compact generate approximately 150 cu. ft.
(1,119 gallons)/year of mixed radioactive waste.
• No information is available on types of hazardous constituents.
• Knows of no available treatment capacity in the Compact region.
• Referred to Gretchen McCabe (OTA), and Edgar Miller of Afton Associates
(Washington, D.C.) who is a consultant to the Working Group.
October 6, 1989
Gretchen McCabe
U.S. Congress, Office of Technology Assessment
Washington,. D.C.
(202) 228-6852
• New Rogers and Associates low-level mixed radioactive wast£, report is
expecte~dTln~T:he next six to eight weeks (at least before Congress'
November recess).
B-59
-------
Treatment facilities are still needed for mixed radioactive wastes
containing solvents.
Believes that no commercial treatment facilities are currently allowed
to treat mixed radioactive wastes legally
Supposedly there is a permitted storage facility in Texas.
The Scientific Ecology Group facility in Oak Ridge, Tennessee, might
build an incinerator.
October 6, 1989
Sarah Hana and Earl Liverman
LLRW Management Program
State of Washington, Department of Ecology
Mail Stop PV-11 \ '
Olympia, WA 98504-8711 "" :••.-.
(206) 459-6861
• Will send reports on mixed radioactive waste in the Northwest Compact
(received).
• Knows of no commercial capacity for treatment of mixed radioactive «
wastes in their Compact.
October 10, 1989
Edgar Miller
Afton & Associates
Washington, D.C.
(Management Consultants of Working Group for Central Compact Commission)
(202) 547 2620
• Says there is a brokerage and processing facility in Texas that claims
to be in a position to accept mixed waste.
October 10, 1989
Nancy Kerner and Tim Gould
Envirosphere
(Consultants for Southwest Compact)
Washington (State)
(206) 451-4247
• An initial California survey showed that California generatSt
approxinAPeTy "22-27,000 cu. ft. (164-200,000 gallons)/year of mixed
waste.
B-60
-------
• Mixed waste from California is usually transported to the Quadrex
facility, via three brokers, where it is stored for radioactive decay,
then transferred to a kiln for incineration. The waste is incinerated
under the RCRA supplemental fuels exemption. Therefore, there is little
waste generated that would require disposal.
. At an old nuclear power plant in Humboldt Bay, CA, oily sludges and
chromium are being found.
• Named other potential mixed waste treatment facilities including:
Ramp Industries, Denver, CO
Nuclear Sources and Services, Inc., Houston, TX
Scientific Ecology Group, Oak Ridge, TN
Diversified Scientific Services, Inc., Oak Ridge, TN
October 10, 1989
Arnie Wight
Principaled Negotiations, Inc.
Amherst, New Hampshire
(603) 672-1111 ,. I-
• New Hampshire's mixed radioactive waste is Below Regulatory Concern.
• Referred to Miriam Muneta of the Idaho National Engineering Laboratory.
• Provided data on the annual volume of low-level radioactive waste
disposed of in each State.
B-61
-------
APPENDIX C
REVISIONS TO REQUIRED CAPACITY
SINCE PROMULGATION OF THE SECOND THIRD RULE
-------
APPENDIX C
C Revisions to Required Capacity Since Promulgation of the Second Third
Final Rule
Since promulgation of the Second Third final rule, EPA has received
additional waste stream specific data from the Chemical Waste Management
facility in Alabama. Based on an analysis of this new information, EPA has
adjusted the required capacity section of the capacity analysis. This
appendix provides a brief summary of the Chemical Waste Management data and
shows how each rule was affected by these data.
The TSDR Survey originally submitted for the Chemical Waste Management
facility at Emelle, Alabama (CWM-Emelle) did not contain the necessary waste J
stream specific data which were to be included in the capacity analysis for
the final Third Third and past promulgated rules. The facility indicated that
1986 records which would supply the detailed information requested, were not
readily available. For the onsite landfill, the facility provided only those
waste codes that are not accepted at the site. For the onsite surface
impoundment, the facility provided the waste codes that entered the surface
impoundment in 1986, but did not provide waste description codes. This
information was inadequate to perform the required capacity section of the
capacity analysis.
EPA requefteoT'critical capacity information needed to support- the land
disposal restrictions and CWM-Emelle responded by providing their (1) 1987
Alabama Department of Environmental Management Facility Hazardous Waste
C-l
-------
Biennial Report (Biennial Report) and (2) National Survey of Hazardous Waste
Generators.
Although the CWM-Emelle Biennial Report was not received in time to be
included in p-rior rules, information provided in the report was used to both
update the data reported in previous rulemakings and to conduct the required
capacity analysis for the Third Third rule.
The CWM Emelle Biennial Report contains information on waste streams
managed at the site in 1987, not '1-986 as in the TSDR Survey Although the
Biennial Report contains 1987 data, it is considered to be the best
information available from the Emelle facility to estimate required capacity
The Biennial Report contains data on over 3,000 waste streams received or
*-
generated at the facility in 1987-. The data include a brief description of
the waste, the handling method, the applicable RCRA waste code(s), and the
volume of the waste received or generated.
The handling method represents the disposition of the waste stream as of
the end of 1987. The handling method in over 99 percent of the waste streams
received and/or generated at Emelle was landfill. These waste streams require
alternative treatment. Other handling methods specified were storage and
thermal treatment. Because these are not land placement methods, these waste
streams do not require alternative treatment.
^^^^^^^ >N^
The capacity analyses for previous rulemakings did not include Chemical
Waste Management quantities requiring alternative treatment technologies. As
a result, required capacity for past rules was underestimated and available
C-2
-------
capacity overestimated. Determination of available capacity for the final
Third Third rule accounts for the sequential and cumulative effects of all
previous regulations (and for projected capacity changes after 1986, as
reported in the TSDR Survey). Therefore, in order to accurately assess
available quantity for the Third Third rule, the required treatment capacity
reported for the Solvents, California list, First Third, and Second Third
rules had to be readjusted to reflect the CWM data. Approximately six of the
technologies considered in the Third Third Rule were affected by this
f-
adjustment. These technologies"' and the required capacity adjustments are
presented in Table 1.
All wastes reported by the Chemical Waste Management facility were
surface-disposed via landfill. Table 2 shows, for each rule, how CWM data
affect the quantity of landfilled wastes that require alternative treatment.
Tables 3 through 6 summarize all updates to required capacity since the Second
Third Final Rule was promulgated. Unless specifically stated, all changes
reflect the Chemical Waste Management data.
C-3
-------
UIC LI u Ua '_ d
______ _ _. , _, _
For Those Technologies Included In Chemical Waste Management Data
(millions of gallons/year)
Ca. First Second
Technology Solvents List Third Third Total
Alkaline Chlorination 0 0 1" l 1
Followed by Chemical
Precipitation
Carbon Adsorption, Followed by <1 0 0 0 0
Chromium Reduction, and
Chemical Precipitation
Chemical Precipitation 0 0 0 <1 0
f~
Chromium Reduction Followed by-' ... <1 0 6 <1 6
Chemical Precipitation ' "
Combustion of Liquids 1000 1
Combustion of 1 <1 2 0 3
Sludge/Solids
High Temperature Metals 0 0 lb 6 0
Recovery (Not Secondary
Smelting)
Stabilization 0 0 21 0 21
Wastewater Treatment 0 <1 0 0 0
(for organics)
Totals 2 0 31 1 32
Note: Quantities less than 1 million gallons are neither added nor subtracted
from capacity totals.
* For th*> Third Third proposed rule, EPA conducted a worst-case analysis
and determined that 12 million gallons of F006 nonwastewaters would require
treatment. For Che final rule, EPA has reevaluated the volume of F006
nonwastewaters-«**^*iicing treatment and determined that 1 million g~511ons of
CWM F006 requires alkaline chlorination followed by chemical precipitation. A
more detailed discussion of this analysis can be found in the executive
summary.
b High Temperature Metal Recovery (HTMR) was identified as the BOAT for
"high zinc" K061. Because of the shortfall of HTMR capacity, the Agency
granted a two-year capacity variance to the HTMR standard for "high zinc"
K061. However, during this two-year variance period, the Agency is requiring
that "high zinc" K061 meet the standard for "low zinc" K061, which is based on
stabilization. Therefore, this additional 1 million gallons of K061 waste has
already been accounted for under stabilization.
C-4
-------
Table 2 Adjusted Landfill Quantities
Since The Second Third Final Rule
(millions of gallons/year)
Landfill Quantity
Second Third Final
Rule" CWM Data
Adjusted Landfill
Quantity Second Third
Final Rule
Solvents
First Third
Second Third
71
302
10
2
31C
1
57b
331
11
a Data obtained from Second Third Background Document Final Rule.
b For the Second Third Rule, 16 million gallons of waste were assigned to
the solvent rule. Because this quantity represents multi-source leachate
waste, it was subtracted from the solvent required capacity. This leaves 55
million gallons of land disposed waste landfilled under the solvent rule. The
additional 2 million gallons comes from the CWM data.
c In the m.-»d Third proposed rule, EPA determined that 41 million
gallons of CUM waste would'require treatment. This estimate included 12
million gallons of F006 that required alkaline chlorination followed by
chemical precipitation capacity. EPA based this 12 million gallon estimate on
a worst-case analysis. Since the proposed rule EPA has reevaluated this
estimate and determined that 1 million gallons of F006 require alkaline
chlorination followed by chemical precipitation. A more detailed discussion
of the F006 analysis can be found in the executive summary.
C-5
-------
Table 3 Solvents Rule Capacity Numbers
For Those Technologies Included In Chem Waste Management Data
(millions of gallons/year)
Required Required Required
Capacity Capacity Capacity
Excluding Based on Including
Technology CWM data" CUM data CWM data
Carbon Adsorption Followed by 0 <1 <1
Chromium Reduction; and
Chemical Precipitation
Chromium Reduction Followed by 0 <1 <1
Chemical Precipitation
Combustion of Liquids '"•'• 1 12
Combustion of Sludge/Solids 38 1 23b
Data Wpained from Second Third Background Document, Final Rule.
b Only 1 million gallons of CWM required capacity was added to combustion
of sludge/solids. The remaining 16 million gallon difference is a solvent-
contaminated was£ewater treatment sludge which results from the treatment of
multi-source leachate. Although this quantity was included in the Solvent
capacity analysis for the Second Third Rule, this quantity should be evaluated
under the Third Third rule. Consequently it is no longer included in the
solvent required capacity total.
C-6
-------
Table 4 California List Rule Capacity Numbers
For Those Technologies Included In Chem Waste Management Data
(millions of gallons/year)
Required Required Required
Capacity Capacity Capacity
Excluding Based on Including
Technology CWM data4 CWM data CWM data
Combustion of Sludge/Solids 2 <1
-------
Table 5 First Third Rule Capacity Numbers
For Those Technologies Included In Chem Waste Management Data
(millions of gallons/year)
Technology
Required
Capacity
Excluding
CWM data"
Required
Capacity
Based on
CWM data
Required
Capacity
Including
CWM data
Alkaline Chlorination Followed by 0
Chemical Precipitation
Chromium Reduction and 40
Chemical Precipitation
Combustion of Sludge/Solids ^. 6-160
Combustion of Solids
High Temperature Metals Recovery 62
(Not Secondary Smelting)
Stabilization 231
21
46
8-162
63C
263C
* Data obtained from Second Third Background Document, Final Rule.
b In the Third Third proposed rule, EPA determined that 25 million
gallons of First Third wastes would require alkaline chlorination followed by
chemical precipitation. EPA conducted a worst-case analysis and determined
that 12 million gallons of CWM should be added to the First Third required
capacity total. The remaining 13 million gallons represented F006 wastes that
had been added since the Second Third Final Rule due to promulgation of the
cyanide standard on 6/8/89. Since the proposed rule EPA has reevaluated the
required estimate to derive a more realistic estimate of required capacity.
EPA has determined that 1 million gallons of CWM should be added to the First
Third required capacity total and 6 million gallons added due to the cyanide
standard.
c High Temperature Metals Recovery (HTMR) was identified as the BOAT for
"high zinc^Ofil. Because of the shortfall of HTMR capacity, the Agency
granted a twnl-year capacity variance to the HTMR standard for "high zinc"
K061. Howevent^duEing- this two-year variance period, the Agency i» requiring
that "high zinc" K061 meet the standard for "low zinc" K061, which is based on
stabilization. Therefore, this 1 million gallons has already been accounted
for under stabilization.
d Only 21 million gallons of CWM was added to the First Third required
capacity total. The remaining 11 million gallons represents soils that have
been added since the Second Third Final Rule.
C-8
-------
Table 6 Second Third Rule Capacity Numbers
For Those Technologies Included In Chem Waste Management Data
(millions of gallons/year)
Technology
Required
Capacity
Excluding
CWM data'
Required
Capacity
Based on
CWM data
Required
Capacity
Including
CWM data
Alkaline Chlorination Followed by
Chemical Precipitation0
Chemical Precipitation
Chromium Reduction and Chemical :~:
Precipitation
Stabilization
0
2
<1
<1
* Data obtained from Second Third Background Document, Final Rj^le.
Of the 3 million gallons added to required capacity for alkaline
chlorination followed by chemical precipitation, 1 million gallons comes from
CWM data, and the remaining 2 million gallons are soil and debris.
Titled alkaline chlorination in Second Third Rule.
This additional 2 million gallons is due to soil and debris waste not
included in the Second Third Rule, not CWM data.
C-9
-------
APPENDIX D
Capacity Analysis by Technology Per Waste Code
For Third Third Wastes
-------
APPENDIX D
The cables in this appendix present the results of the analysis of
required capacity for each alternative technology on a waste code-by-waste
code basis. The tables show the amount 'of required treatment capacity for the
wastes for which treatment standards are being for the Third Third rule. The
tables also total the amount of required capacity for each technology
The original TSDR Survey data were sorted by waste code, waste
description code, and type of alternative treatment required to generate these
tables. Computer printouts showing the original TSDR Survey data for the
Third Third promulgated wastes are contained in the "Analysis of the Required
Capacity Data for the Third Third Wastes Final Rule" contained in the docket.
The data were then combined and summarized to create the technology-specific
capacity analysis tables for the Third Third wastes contained in Section 2 of
this document. .''.•
D-l
-------
T«blt 0-1 Capacity Anglytii for AlUlirw CMorination
(Excluding Soil and 0«brit)
Typt of AUirnat.ivc?
Surf«ct-dispo*«d
Atquirinq Alttrrwtiv* C«p*city
(9«llon«/y««r)
l l-d1spo*td votuM
Requiring Alttrnativt Capacity
(Q«Uort»/yttr)
0002i
0003t
F019
TOTALS:
0
151,640
6,330,375
6,442,055
62,400
47,574,160
0
47,634,560
D002a is D002PI8£Ba* and alkalines
D003a is D003 cyanides
D-2
-------
Table D-2 Cacaoty Analysts for Alkaline CMorinatioo followed by Chemical Precipitation
(Excluding Soil and Debris)
Surface-disposed Voluw Oe«ow«U-disposed Voluiw
Typ« of Alternative Requiring Alternitive Capacity Retiring Alternative C«pecity
Tre«tment/Recov«ry (gallon»/ye«r) (gallons/year)
F006« 1,548,179 500,288
F019 1,812 1,440
TOTALS: 1,549,991 501,728
F006a is F006 cyanides and metals
D-3
-------
Tablt D-3 Capacity Analysis for i«rylliu» ««cov«ry
(Excluding Soil and Oaftris)
Typt of Alttnwttv*
Tr«itn«nt/((tcov«rv
Surf act-disposed Voluw
Raquirinfl Alttrnativ* Capacity
(gallor»/y«ar)
Dt«px
-------
Tafclt 0-4 Capacity Analysis for •>°tOflic«l Trtati
(Excluding Soil and Debris)
-
Type of AUtrnatlvt
Treatment /Recovery
0004
0005
P003
P020
P048
U002
U009
U019
U031
U051
U057
U112
UUO
U159
U170
U1M
U220
U239
Surf*ce-dispo**d Voluw
Requiring AUtrn«tiv« Capacity
(gal lon*/yt*r)
204
2W
240
0
0
0
0
0
0
•"'-'- 24,417
160
0
0
204
0
0
0
0
Ottpx«U -dispood Volunt
Rtquiring Alttrn«tiv« Capacity
(gallon
-------
T«blt D-5 CJO*city Anatytit for |ioloflic«l Trt«t«tnt Followed By Ch«aic«l Precipitation
(Excluding Soil and Dtt>ri«)
Surf«ce-di*po««d VoluM 0*«pw«l I-disposed Voluw
Typ* of Mttrnativ* Rtquiring AUtrrvitivt C»p4City Rtquiring Alttrnativt Cipacicy
Treatm»rt/R«cov«ry (g«Uon«/y««r)
F039 797,690 15,100,000
TOTALS: 797,690 15,100,000
D-6
-------
Tabu 0-6 Capacity An»ly»i§
(Excluding Soil and D«bri»)
Cheancal Oxidation Followed by CHeancal Precipitation
Typ« of Alt«rn«tiv»
Treatment/Recovery
Surface-disposed Volume
Requiring Alternative Capacity
(gatlon«/y««r)
TOTALS:
6,945,9*5
Ot«p«Mt l-dispostd
Requiring Alternative Capacity
(9allons/yc«r)
DOOlb
D002a
0003b
0004
0005
DOOoa
0007.
OOOfia
0010
0011
P006
P105
P115
P122
560
210,758
6,677,720
0
3,078
657
0
0
0
- -.., 612
47,280
480
4,800
0
0
89,242,840
1,593,538,840
640
0
400,000
400,000
400,000
400,000
0
0
0
0
7,920
1,66%, 390,240
DOOlb is D001 reactives, oxidizers
D002a is D002 ac*ds-*«d alkalines
D003b is D003 sulfides
D006a is D006 cadaium non-batteries
D007a is D007 chromium
DOOSa is D008 lead non-batteries
D-7
-------
T*6l* 0-7 C*c*ctty Ar»iy»is for Ch««ic»i Onditions Followed by Chraiiui Btduction too Chwicn Prtcipi t«t ion
(Excluoinf Soil »rw 0«erit)
Surf iCt-disDOttO VolLlM 0»*ewtt i-di soosea V
Typ« of Alt»rr»tiv« Requiring Aittrrntivt C«p«City fitquinnq Alttrn«tive
(g«Uon*/y««r) (9«l loos/yeir)
0001b 31,000 0
0002i 610,976 97,601,820
0003c 1,089,4U 97,6CK,340
0005 54,540 0
0006* 66,569 4,980
D007i 65,851 5,880
D00«« _ 0 40,020
OOOVl .. 0 35,040
TOTALS: 1,920,340 195,292,080
DOOlb is D001 reaccives, oxidizers
D002a is D002 acids and alkalines
D003c is D003 reaccives
D006a is D006 cadmium non-bacteries
D007a is D007 chromium
DOOSa is DOOSlead non-bacteries
D009a is D009 hj.gh conc«ncracion mercury
D-8
-------
Tiol« D-S Capacity Analytif for Cheaicai Precipitation
(Excluding Soil «nd Debris)
Surface-disposed volu»e Deepwel I-di sposed
Type of Alternative Requiring Alternative Capacity Requiring Alternative Capacity
Treatment/Recovery (gallons/year) (gallons/year)
0002*
D004
0005
D006a
0008a
D009a
0010
0011
F006b
(C031
P056
U134
U151
1,021,257
554,868
8,426,348
1,341,262
12,124,068
914,117
297,476
802,043
0
"" .-- • o
0
964
0
7,001,533
9,789,360
276,420
128,900
2,206,073
1,045 600
93,56 '60
23t '60
3,001,731
1,047,360
14,040
210,720
100,000
TOTALS: 25,482,403 118,618,457
D002a is D002 acids and alkalines
D006a is D006 cadmium non-batteries
D008a is D008 lead non-batteries
D009a is D009 high Concentration mercury
F006b is F006 treated cyanides and metals
D-9
-------
Tabia 0-9 Capacity Arwly*i( for Chromiui Induction and Chaaical Precipitation
(Excluding Soil and Oabris)
Surfaca-ditooaad VoLm* 0««ow«t (-di tpo»«d volUM
Typ« of Altarnativ* Rtquiring Altarnativ* Capacity Requiring Alternativt Capacity
Treatmtnt/Recovary C8allon«/y«ar) (9allor«/y«ar)
0002a
0004
0005
0006a
0007a
0008a
0009a
0010
0011
F006c
K002
K003
K004
K005
K006
P011
U032
1,198,275
61,918
187,563
1,400,950
59,344,986
3,053,865
35,245
:- ,_t 15,349
121,414
18,750,000
130,320
130,320
115,200
115.200
1 1 5 , 200
0
101
36,077,869
16,740
961,968
1,033,388
198,233,898
1,021,185
63,717
334,341
28,860
1,500,865
130,680
0
0
0
°$-
3,60fr
15,440
TOTALS: 84,775,906 239,422,591
D002a is D002 acids and alkalines
DOOSa is D006 cadmium non-bacceries
D007a is D007 ghTStttcmi
D008a is D008 lead non-bacteries
D009a is D009 high concentration mercury
F006c is F006 with chronium
D-10
-------
Table 0-10 Capeoty Analysis for CoMxation of Liquids
(Excluding Soil and Debris)
Type of Alternative
Treatment/Recovery
0001a
D002a
D003a
D004
D006a
D007a
DOOSa
0010
K032
K083
K097
K105
P003
POOS
P020
P024
P050
P051
P059
U001
U002
UOOfl
£609
\
•U812
U019
U031
U037
U043
U044
U045
U047
U048
U051
U052
U057
U066
U067 ^
U070
U073
U074
U077
U080
U105
U106
U108
U112
U113
U' 18
U121
U122
Surface-disposed volume
Requiring Alternative Capacity
(gallons/year)
6,897,000
37,478
1,180,422
659
59,320
91,432
223,823
1,369
•:-' 0
0
0
4,560
240
0
317
480
0
0
0
0
bU>
100
45,840
1,640
3,935
134
0
5,480
4,320
0
72
183
24,417
93,141
160
1,324
26
456
240
0
311
2,658,635
0
0
4,805
D-ll 273
0
0
370
7,96*
Deepwel I -disposed Volume
Requiring Alternative Capacity
(gallons/year)
6,897,000
104,880
7,004,320
48,160
10,920
31,300
10,380
9,600
5,360
5,000,000
26,480
0
0
27,000
0
*
377,533
9,216 .
377,533
534,480
0
0
0
100,000
775,440
0
33,120
0
129,600
17,600
0
0
0
0
0
0
•^ o
100,000
0
50,400
0
2,754,520
100,000
100,000
0
178
4,500
240
0
100,000
-------
U123
U125
u13l
U138
U140
U142
U154
U157
U158
U159
U161
U162
U165
U169
U170
U180
U185
U188
U192
U196
U197
U201
U210
U211
U220
U225
U226
U227
U228
U239
U247
,'TOmS:
1,533
251
103
0
40
240
30,183
0
41
1,832
1,581
4,320
85
1,054
26,640
240
0
3,885
•": -'. 0
480
0
23
2,331
12,551
31,346
12
5,640
2,658,120
1,493
158,147
93
14,293,838
0
0
0
100,000
0
0
1.738
100,000
0
3,780
0
100,000
540
100,000
0
0
1 , 000 , 000
0
100,000
0
100,000
0
1,000,000
111,520
20,290
Of
100,000
2,654,520 .
1,200
69,360
0
30,302,708
DOOla is D001 ignitables
D002a is D002- acids, and alkalines
D003a is D003 cyanides
D006a is D006 cadmiua non-batteries
D007a is D007 chromium
DOOSa is D008 lead non-batteries
D-12
-------
Table 0-11 Capacity Analysis for Coatmtion of Sludg««
(Excluding Soil and 0«bns)
Type of Alternative
T reatmem/Recovery
OOOIa
D002a
0003c
0004
0006a
0007a
DOOSa
0010
F019
K035
K073
P048
P077
P088
U004
U012
U019
U051
U080
U105
U122
U144
Ui59
8165
U188
U2VO
U211
U220
U226
U228
U239
TOTALS:
Surface-disposed volume Oeepuel I -disposed Volume
Requiring Alternative Capacity Requiring Alternative Capacity
(gallons/year) (gallons/year)
6,946,818
26,192
85,404
65,555
135,211
533,487
459,209
4,146
"" .-/ 1.680
1,920
1,723
2,549
4,560
240
139
303
2,018
13,604
290
2,160
29
19
36
8,330
6,553
123
171
12,716
364
261
12,469
8,328,299
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0 f-
0
0
0 '
0
0
0
0
0
0
0
0
0
0
0
0
0
DOOla is D001 ignicables
D002a is D002 acids and alkalines
D003c is D003 explosives, water reaccives, other reactives
D006a is D006 cadmium non-batteries
D007a is D007 chromium
DOOSa is D008 lead non-batteries
D-13
-------
Table 0-12 Capacity Analysis for Coatmtion of Solid*
(Excluding Soil •ndOtbrit)
Surface-ditpoaad Volume De«pw«U -disposed voluiw
Type of Alternative Requiring Alternative Capacity Requiring Alternative Capacity
Tre»tment/Recov«ry (gallons/year) (gallons/year)
D001a
D002a
0004
0006i
D007a
OOOSa
0010
K017
K021
K048
K049
K050
K051
<052
K085
P001
P004
POOS
P020
P024
P037
P048
£fl50
P051
P059
P077
P088
P123
U001
U002
U003
U005
U008
U009
U012
U019
U022
U029
U030
U031
U036
U037
U039
U043
U044
U048
U051
U052
U057
U061
5,779,183
162,640
57,759
130,954
260,620
300,133
1,952
-' . , 66,400
16,951
33,407,730
28,455,250
10,611,660
70,279,8*6
11,207,605
99,600
16
1,961
1,476
20,100
3,120
6,633
1,415
6,065
6,404
1,307
24
821
1,660
31
2,253
109
89
1,586
2,907
8,370
928 ^
' •"" -- 1,574
665
339
11,594
7,821
5,844
61
240
5,866
D-l
-------
U067 44 g
0070 53 0
u07i jog 0
U072 219,865- 0
U073 225 0
U075 240 0
fl, MO 0
12,240 0
U078 480
16 0
U080 u/786 Q
u081 11,381 0
U082 19
J.v<:u 0
U093 60 Q
u101 9,280 0
U106 60 0
u112 1,794 0
u117 " 30 0
u118 -' :•:. 827 0
U12° 158 0
u122 39,590 0
u123 1,422 0
u126 26,549 0
u127 743 0
u129 1,597 0
Ul31 144,000 „ 01
24 0
UUO 30 0
1,797 -0
UU/ 14,550 0
Ul5i 2,755 0
252,464 0
31,651 0
1,034 0
U165 29,880 0
U16/ 404 0
527 0
297
Ul81 314 0
1.520
37
- ^ :
- '•= :
J208 u
0209 « 0
U210 ^ -- *-800
4'159
2'40°
" 24° 0
89'M7
9'976
U239 3.*" °
U2.7 65'271 0
0248 D-15 336 °
13,525 0
TOTALS:
162.292,686 n
-------
DOOla is D001 ignitables
D002a is D002 acids and alkalines
D006a is D006 cadmium non-battefies
D007a is D007 chromium
D008a is D008 Lead non-batteries
D-16
-------
Table 0-13 Capacity Analysis for Incineration of Liquids
(Excluding Soil and Debris)
Type of Alternative
T reatment/Recovery
D002*
0005
0011
0012
0013
0014
0015
0016
0017
K086
P057
P064
P069
P073
P075
P102
U006
U007
U008
U034
U055
U056
JJ092
TJ193
U109
U115
U122
U123
U133
U147
U154
U156
U160
U194
U200
U219
U244
TOTALS:
Surface-disposed volume
Requiring Alternative Capacity
(gallons/year)
0
33,705
4,489
0
0
1,920,000
0
••-'. o
0
0
0
36
240
7,200
0
0
503
0
0
0
0
0
240
12
2,160
0
1,494
286
1,450
0
0
1,440
0
0
0
76
0
1,973,331
Deepwe 1 1 -disposed Volurw
Requiring Alternative Capaciw
(gal Ions/year)
24,000
0
8,540
2,333,333
2,333,333
2,390,213
2,333,333
2,333,333
2,333,333
237,600
9,216
0
100,000
" §-
1,440
84,240
0
100,000
100,000
17,600
100,000
12,624
0
1,560
0
8,000,000
0
0
100,000
480
339,600
0
12
9,120
-^ 315,600
240
13,920
23,632,670
D-17
D002a is D002 acids and alkalines
-------
Table 0-14 Capacity Analyst for Incineration of Sludge*
(Excluding Soil and Deferi»)
Surface-disposed Volume Oeepwel I -disposed Volune
Type of Alternative Requiring Alternative Capacity Requiring Alternative Capacity
Treatment/Recovery (galton*/yeer J (gal loot/year)
0004
0005
0007i
OOOSt
0009i
0011
P012
P022
P075
P108
U007
U240
U244
6
23,545
6
3
3
21,845
31
- r, 6,720
87
29
516
1,440
140
0
0
0
0
0
0
0
0
0
0
0
0
0
TOTALS: 54,371 - 0 $•
D007a is D007 chromium
D008a is D008 lead non-batteries
D009a is D009 high concentration mercury
D-18
-------
Table 0-15 Capacity Analytii for Incineration of Solids
(Excluding Soil end 0«t>rit)
Type of Alternative/
Treitmem /Recovery
0005
D011
D012
0013
0014
0015
0016
D017
F039
P002
P014
P018
P022
P028
P031
P047
P058
P064
P066
P067
P070
P081
^^
JftfcS
P105
P108
U007
U010
U014
U021
U055
U056
U103
U114
U116
U119
U133
U148
U149 - --~~I '
U177
U202
U218
U219
U234
U237
U238
U240
U244
U249
Surfece-ditpo*ed Volune Oeepwcl I -disposed Volune
Requiring Alternative Capacity Requiring Alternative Capacity
(gal loot/year) (gallons/year)
64,858
265
452,131
442,885
1 0 , 403
1,246
223,613
441,973
"' .-. 40,603,809
100
17,572
955
6,380
720
191
5,265
80
1,010
11,902
66
98
480
42
164
5,732
23,404
112
24
4,199
205,953
789
1,910
4,134
254
49
264
44 ^
33,600
1,520
60
60
1,817
4 1
463
205
D-19 55,870
86
55
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
o*
0
0
•o
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
TOTALS: 42,626,853
-------
Table 0-16 Capacity Analysis for M*rcury Retorting
(Excluding Soil and Dtbris)
Type of Alternative
T reatment/Recovery
Surface-dispwed Volume
Requiring Alternative Capacity
(g»Uon*/y*ir)
OeepwelI-disposed volume
Requiring Alternative Capacity
(gal ions/year)
D002a
D005
0006*
0007a
OOOfla
0009.
D011
K106a
P092
U007
U008
U019
U144
U151a
TOTALS:
38,262
34,803
49,489
49,600
200,088
2,047,161
." 392
-.'. 446,236
1,776
1
2
6
2
33,759
2,901,577
0
0
493
494
1,195
19,063
0
0
0
0
0
0
0
0^
I
21,245
D002a is D002 acids and alkalines
D006a is D006 cadmium non-batteries
D007a is D007 chromium
DOOSa is D008 lead non-batteries
D009a is D009 high concentration mercury
K106a is K106 high concentration mercury
U151a is U151 high concentration mercury
D-20
-------
Ttelt 0-17 Capacity Analysis for
(Excluding Soil *nd 0«Crif)
Surf*ct-dicpo««d Volunw 0*tpw«l l-disoottd VOILH«
Typ« of Alttrn«tivt R«quiring Alttrn«tiv« Capacity Rtquiring Alttrnativt Capacity
-------
T«Olt 0-18 Capacity An«ly*i» f"r Secondary Sa»lting
(Excluding Soil and Ottofi*)
Surface-di»po»e
-------
Table D-19 Capacity Analy*i» for Stabiliiation
(Excluding Soil and Debris)
Typ« of Alternative
Treatment /Recovery
D002a
D006»
0007a
DOOSa
0010
0011
F024
F039
K002
K003
K006
K069
IC083
P115
P119
P120
U146
U2CK
U2U
U217
TOTALS:
Surfic*-disoe«*d Volunc
Rtquiring Alternative C»p«city
(gal loos/year)
65,752
9,867,329
11,316,562
49,494,459
1,728,461
94,357
16,9*5
;- .-, 288,000
82,320
82,320
91,920
41
15,146
" 48
106
63,951
287
110
16
240
73,208,370
D»«pw«l 1 -disposed Volume
Requiring Alternative Capacity
(gal Ions/year)
0
0
0
22,061
935,812
0
0
0
0
0
0
0
631
0
0*
0
0
0 .
0
0
958,504
D002a is D002 acids and alkalines
D006a is D006 cadmium non-batteries
D007a is D007 cnfbnTroni
DOOSa is D008 lead non-batteries
D-23
-------
Table 0-20 Capacity Analy»i« for Stabilization of Incinerator A«h
(Excluding Soil and Debris)
Type of Alternative
T reatment/tecovcry
0005
D006«
D007a
D008a
0011
F019
F039
K017
K021
K048
K049
K050
K051
KOS2
K083
K086
P064
U004
U006
U019
U044
U051
4J577
U080
U122
U144
U158
U181
U1B8
U220
U239
TOTALS:
Surface-diipoaed Volu»e
Requiring Alternative Capacity
(gallons/year)
11,824
233,845
272,685
275,594
2,207
168
4,060,380
12,528
3,390
3,340.773
2,983,115
1,086,370
7,163,678
1,139,558
0
0
1,212
14
5
39
24
16,513
768
3
0
372
49,248
63
2,517
40
114
20,657,047
Oe«p»«e 1 1 -disposed volim
Requiring Alternative Capacity
(gal tons/year)
0
17
874
10
0
0
0
0
0
0
0
0
0
0
50,000
2,376al
0
0 .
0
0
0
0
0
0
2
0
0
0
0
0
0
53,279
D006a is D006 cadmium non-batteries
D007a is D007 chromium D-24
DOOSa is D008 lead non-batteries
-------
TtOlt D-21 Capacity Analysis for Stabilization of Kttort Slag
(Excluding Soil and Debris)
Surface-disposed Volume Deepwell-disposed
Type of Alternative Requiring Alternativt Capacity RequiPing Altarnativ* Capacity
Treatment/Recovery (gallons/yaar) (gallona/y«ar)
0005
D006«
0007a
OOOSa
0011
U007
U008
U019
UU4
3A.63Z
45,802
76,519
1,333,435
1,406
9
9
63
3M
0
657
658
2,060
0
0
0
0
0
TOTALS: 1,492,639 3,375
D006a is D006 cadmium non-batteries
D007a is D007 chromium
DOOSa is D008 lead non-batteries
D-25
-------
i«>it o-a. capacity Analytic *of Stabilization of Senjbbar yattr Tr«at**nt Sludge
(Excluding Soil and Debris)
Type of Alternative
T reatmem/Rec ovary
0005
0006*
0007»
ooofi*
0011
F019
F039
K017
K021
K048
K049
K050
K051
K052
K083
K086
POM
UOOi
U006
U019
U044
U051
,l»77
illOAO
U122
U158
U181
U188
U220
U239
TOTALS:
Surfaca-di>po«ad Voluw
Raquiring Altarnativ* Capacity
(9allon«/y«ar)
7,158
23,131
31,3*7
213,625
266
17
406,038
626
170
" ;r, 334,077
2W.553
106,117
702,796
: 112,078
0
0
60
1
5
39
1
1,125
38
3
0
2,462
3
126
40
U
2,225,988
Ot«pw«t I -disposed volur.
laquirinfl Alternative Cap*
(gal Ions/year)
0
17
874
10
24
0
0
0
0
0
0
0
0
0
50,000
2,376
*
0
0
0
0
0
0
0
2
0
0
0
0
0
53,303
D006a is D006 cadmium non-bacteries
D007a is D007 chromium
DOOSa is D008 lead non-batteries D"26
-------
Trtle 0-2J Capacity Analvtif for St«Oi 11 Ittion of W«»teweter Treeweot Sludge
(Excluding Soil end Debris)
Surface-disposed Volu«e DeepwelI-disposed Volant
Typ« of Alternative Requiring Alternative Capacity Requiring Alternative Capacity
Tre«tiB»nt/*ecovery (g«llon«/ye«r) (g«i lon$/vetr)
D005
0006*
0007a
DOOfl*
D011
FOOAl
F019
K002
K003
K004
K005
1C 006
U032
U159
TOTALS:
6,325,600
574,809
44,479,844
2,128,898
153,955
10,063
6,267,089
23,605
23,605
;" •:, 1.152
1,152
1,152
1,426
2
59,992,356
U.723
15,847
2,475,797
31,931
366
0
14
2,614
0
0
0
0
235
0
2,541,527
I
D006a is D006 cadmium non-batteries
D007a is D007 chromium
DOOSa is D008 lead non-batteries
F006a is F006 cyanides
D-27
-------
for
Rtcov«ry
(Excluding SoH *rd 0«brit)
Typ« of
Surf*ct-dity
(g*Uor«/y«»r)
P087
TOTALS:
2,600
2,600
D-28
-------
Teble 0-25 Capacity Analvst* 'or Therwel recovery of CKtoiui b»tterie«
(Excluding Soil end Debris)
Surfece-dispoaed VoluM 0*«pw«l I-disposed Votuw
Type of Attem«t1v« Requiring Alternative C«p«city Requiring Alternative Ccpecity
Trettwent/Recovery (gel lone/veer) (gellons/yeer)
D006b U.278 0
TOTALS: 14,278 0
D006b is D006 cadaiua batteries
D-29
-------
:ity Analytit for vitrification
(Excluding Soil and Oabrit)
Typ» of AlttrnKiv*
T rtatMnt/RacqV^ry
000 ib
D002i
D003«
0004
DOOS
0006*
0007i
oooea
00091
0011
K031
KO&4
P010
P011
P012
P108
U022
U051
U120
U144
U159
U169
liJM
\
'TOTALS:
Surfact-ditpoaad vetuM
Rtquirinfl Alttrrwtlvt Capacity
(9«Uon«/y««r)
655
157,264
23,380
12,072,431
1,206,300
1,753,273
1.872.888
2.161.060
1,080,616
;'; >.. 1,309.530
620,258
213,912
1,117
2,048
3,228
6
461
73
26
2
2
4
6
22,478,540
Ot«pwtU-dispo««d voluH
Ktquirine Alternative Capacity
(gaUont/y«ar)
0
0
0
150,796
U
5.441
5,190
10,204
0
228
10,474
0
0
72
.0
fi-
ll
0 '
0
0
0
0
152,419
DOOlb is D0
-------
T»tsi* D-27 C«o«city An«ly*i* for w«t Air Oxidation (only)
(Excluding Soil end D«brts)
Surf ace-disposed Volume Deepwell-disposed Voluw
Type of Alternative Requiring Alternative Capacity Requiring Alternative Capacity
Treatment/Recovery (gallons/year) (gall
D002« 0 55,990,320
K011 0 433,204,160
•C013 0 407,166,320
KOU 0 130,950,320
TOTALS: 0 1,027,311,120
D002a is D002 acids and alkalines
D-31
-------
Table 0-28 Capacity Analyst for y*t Air Oxidation followed by Carbon Adsorption
(Excluding Soil and Debris)
Surface-ditpoeed Voluw Deepwel l-di»po«ed voliM
Typ« of Alttrnctiv* Requiring Alttrnativ* Capacity Requiring Alttrnativ* Capac
Treatm«nt/R«cov«ry (gal I one/year) (gaUona/y«ar)
P058 0 12,720
D-32
-------
APPENDIX E
The Cables in this appendix present the results of the analysis of
required capacity for each alternative technology for contaminated soils The
tables show the amount of required capacity for each technology
To generate these tables, the original TSDR Survey data were sorted by
waste code, waste description code (i.e., those described ss soils), and type
of alternative treatment required. Computer printouts showing the original
TSDR Survey data for the Third Third wastes are contained in the "Analysis of
Required Capacity Data for the Third Third Wastes Final Rule" contained in the
docket. The data were then combined and summarized to create the technology-
specific capacity analysis tables for contaminated soils contained in Section
2 of this document.
E-l
-------
T«bl« E-1 Capacity Ar*ly»l« for *l*«Ur» Chlorirwtion of Soils
(Soil and Otbris only)
VOIUM Requiring
Typ« of Alnrn»tfv« Alternttivt Ctp^ity
TrtitMnt/Recovvry (gillon«/y«ir)
F019 59,996
TOTALS: 59,994
E-2
-------
Tablt E-2 Capacity Analysis 'or Ch«. Oxidation Followed by CJiro»njn Induction and Chwt. Prteipititu
(Soil and D«bri§ only)
Requiring
Typ* of Alttrnctiv* Alttrn«tive Capacity
Trtantnt/ttcawry (gallons/year)
D003e 130,040
TOTALS: 130,080
D003c is D003 reactives
E-3
-------
T«6lt £-3 Capacity Ai»ty«<« f»r Chro»ii» ««duction and Chcaical Precipitation of Soil*
(Soil and D«bH« only)
Typt of Alttrnativ*
T rtat*tnt/R*eov*ry
D002a is D002 acids and alkalines
D006a is D006 cadmium non-batteries
D007a is D007 chromium
DOOSa is D008 lead non-batceries
D009a is D009 high concentration mercury
VoliM Requiring
Alttrnativt Capacity
(gatlont/yvar)
0002*
0004
D005
D006«
0007i
OOM*
0009i
TOTALS:
f-
U2.939
66,512
209,811
336,396
982,669
342,315
5,370
2,1«,012
E-U
-------
Table E-4 Capacity Analytic for
(Soil Mid Oetorit only)
Incineration of Soil/D«tori»
Type of Alternative
T reatment/Reeovcry
D001«
D002a
D003c
D004
D005
0006*
D007i
D012
0013
K035
P012
P020
P022
P037
P047
P048
P051
=054
-364
P070
P10S
P122
P123
U002
U003
JJ008
*U009
0019
U022
U031
U036
U044
U050
U051
U052
U060
U061
U070
U080
U103
U105
U106
U108
U114 - --~~ '
U118
U120
U122
U123
U125
U129
U147
U154
1 11 *»Q
U159 £_5
1 1 1 1 1
U161
U162
U165
Volune Requiring
Alternative Capacity
(gallona/year)
1,489,128
2,400
3,160
1,051
1,791
12,906
63,646
164,958
381,892
310,560
27
50,880
138,720
403
8,625
1,920
87,211
1,200
5,050 -
437,520 *~
5,625
960
477
22,999
720
95,203
221,211
131,001
461
602
877
382
461
1,881,258
617,510
17,149
17,178
480
4,419
1,863
11,398
10,920
720^
4,347
180
461
27,128
1,677
4,320
403
1,200
7,440
375,972
7,440
127,981
438,096
-------
U181 315
U18S 470,9*2
U220 312,619
U228 U,2SO
U239 290,492
U248 480
TOTALS: 8,322,697
DOOla is D001 ignicables
D002a is D002 acids and alkalines
D003c is D003 reaccives
D006a is D006 cadmium non-batt«ries
D007a is D007 chromium
E-6
-------
Table E-5 Capacity Analyti* for H«rcury Kttortlng of Soil/Debri»
(Soil and Debris only)
Type of Alternative
Trt«ii»nt/*ecov«ry.
VoliM Requiring
Alternative Capacity
(gallona/ycar)
0002i
D005
D006a
D007a
D008a
D009i
K106a
UlSIa
TOTALS:
__*-
60
1,140
5,024
5,064
441,212
3,051.369
9,600
4,242
3,517,731
D002a
D006a
D007a
DOOSa
D009a
JQ06a
U151a
is D002 acids and alkalines
is D006 cadmium non-batteries
is D007 chromium
is D008 lead non-batteries
is D009 high concentration mercury
is K106 high concentration mercury
is U151 high concentration mercury
E-7
-------
Table 1-6 Capacity Analy»i» for Neutral I ration of $oil/D«torit
(Soil and 0«bris only)
VolUM Rtquiring
Typt of Alternative Alttrnativt Capacity
Trtatmtnt/Ktcovcry (gallons/year)
D002i 23,401
TOTALS: 23,401
D002a is D002 acids and alkalines
-------
T«tol« 1-7 Capacity Amiy»1« 'or Secondary Smiting of Soi ts
(Soil and 0«brit only)
VolUM Requiring
Typ« of Alttrnativ* Alttrrutiv* Capacity
(g«Uor»/y«ir)
000«b 59,162
TOTALS: 59,162
DOOSb is D008 lead acid batteties
E-9
-------
>«oi« e-o capacity Analy«i» for Stabilization of tttort Slag (Soil*)
(Soil and Dtbrit only)
VolUM (•quiring
Typt of Alttrn«t1v« Alttrn«tiv« Capacity
TrtatMnt/R«cov«ry (gallons/year)
0005 12,252
DOOea 6,699
0007a 6,699
TOTALS: 25,650
D006a is D006 cadmium non-batt«ries
D007a is D007 chromium
E-10
-------
Tefcle 1-9 Capacity Analy»i»
(Soil and Datorii only)
Stabilixation of SoU/D«6M«
Typt of Alttrmtiv*
Treat»tnt/tteov«ry
Voluat Requiring
Alternative Capacity
(gaUora/ytar}
D001»
0002t
D005
D006*
0007t
0008a
0010
F019
P011
P012
P110
P122
U032
U051
U052
U144
UlSIa
TOTALS:
27
2,787
273,833
250,461
27.856
9,631,111
6,69*
29,997
0
0
480
;r-'. 0
1,440
1,862,445
10,930
267
80
12,098^4,08 I
DOOla is D001 igni
jb
£>Q02a is D002 acids and alkalines
D006a is D006 cadmium non-batteries
D007a is D007 chromium
DOO&a is D008 lead non-batteries
U151a is U151 high concentration mercury
E-ll
-------
Ttblt 6-iG Capacity Ar*ly*U for StabUlutlon of W«tttMt»r TrMtMnt Slubv* and Soils
(Soil and Oebrii only)
VotuM Ktquiring
Type of Alternative Alt«rn«tiv» Capacity
T rtita«nt/l«cov«ry (gaUor»/yt«r)
D006* 67,78*
D007t 70,277
0006* 85,643
F019 6,400
U052 6,998
TOTALS: 237,146
D006a is D006 cadmium non-batteries
D007a is D007 chromium
D008a is D008 lead non-batteries
E-12
-------
Table e-i) capacity A/aty»'» for Th«mi «tcov«ry from
(Soil and Dcbrit only)
Typ« of
Trti«»nt/ttcov«ry
voluw
Alt»rnitiv«
(g«Uon«/ye«r)
P015
TOTALS:
E-13
-------
Tatolt 1-12 Capacity An*ly«i* for Th«nMl ltcov«ry of Chroaiui tricks
(Soil and D«br1t only)
VolUM Requiring
Typt of Altirrwtlv* Alttrr«tiv« C*p«city
Trt»t*«nt/l«eov«ry (g«llons/y«ar)
DOOTb 3,000,000
TOTALS: 3,000,000
D007b is D007 chromium refractory bricks
E 14
-------
Tabla 1-13 Capacity Analytic for vitrification of Soil/o«bri»
(Soil *nd Dtbrit only)
Typt of Alttrnatlvt
DOOla is D001 ignitables
D002a is D002 acids and alkalines
D006a is D006 cadmium non-batteries
D007a is D007 chromium
DOOSa is D008 lead non-batteries
D009a is D009 high concentration mercury
Volu
Atttrrntivt C«p*city
D001*
0002*
DOCK
D005
0006i
D007.
0008*
0009i
0011
P011
P012
576
640
469,597
40,610
43,095
104,466
89,344
17,699
51
2,880
56,400
E-15
-------
APPENDIX F
Documentation of Waste Volumes for Waste Codes Addressed In Previous Rules
-------
EPA is promulgating revised or additional standards for the wastewater
and nonwastewater forms of several waste codes for which standards were
promulgated in a previous rule. In addition, EPA is promulgating standards
for the waste codes for which the wastewaters or nonwastewaters have jeen soft
hammered in a previous rule. Because waste volumes for these codes were
considered in a previous capacity analysis, waste volumes for these codes were
initially excluded from the Third Third capacity data. Although these volumes
have been included in the baselfne study, they have been reanalyzed and
included in the Third Third capacity analysis for the sake of completion.
This appendix presents the waste volumes for the waste codes that were
considered in a previous capacity analysis. Section F.I presents tables
(Tables F-l, F-2, F-3, F-4) listing waste codes, and associatedAyolumes ,
disposed of waste codes which have been evaluated in previous rules. This
section also includes documentation for waste codes whose volumes had been
initially evaluated in the capacity analysis for a previous rule. These
volumes were previously considered because they were mixed with a waste code
promulgated in a previous rule. Table F.I lists surface disposed California
list HOC's and Table F.2 lists all other surface disposed wastes. Table F.3
lists the deepwell-injected California list HOC's and Table F-4 lists all
remaining deepwell-injected wastes. Section F.2 lists surface disposed waste
codes for for which volumes requiring alternative treatment were based on the
capacity analysis from previous the rule. Discussions explain the use of
volumes from pss*=-eap«city analyses in the capacity analysis for ThYrd Third
proposed rule. In cases where a waste code exists in a waste stream with
other wastes, volumes were divided equally between the wastes before being
added to the capacity analysis.
F-l
-------
Test F 1 Documentation for Waste Codes Evaluated fn Previous Rules
TABLE F-l
REQUEST D0906A
DATA SOURCE: TSDR SURVEY CAPACITY DATA SET
WASTE STREAMS WITH SPECIFIED WASTE CODES IN BOOKS J-N
SURFACE DISPOSED CALIFORNIA LIST HOC WASTES
NON-CBI FACILITIES ONLY
ALL VOLUMES ARE IN GALLONS
Facility ID
NYD080336241
Facility Name
Book Question
Key Waste Waste
Letter Code Desc
Waste Codes: D001,D002,D007,
U122,U151,U044.U080,D009,P030,
U144,U188,U165,P077,U007,P058
Cecos International L
Waste Codes: P059
31
P059
A08
1986 Quantity
OHD045243706
NYD080336241
NVT330010000
Envirosafe Services of L
Ohio, Inc.
Waste Codes: D016.D017
Cecos International L
Waste Codes: P050
US Ecology Chera Site Inc. L
35
31
35
CT 6017
U P050
AH P058
B36
A08
B88
1
5
1
,680
,172
,200
48
NYD080336241
Cecos International
Waste Codes: U043
31
AL
U043
A08
108
WA7890008967
Waste Codes: U043
31
U043
A13
240
NYD080336241
Cecos International
Waste Codes: U047
31
AN
U047
A08
72
F-2
-------
TABLE F-l
REQUEST D0906A
DATA SOURCE: TSDR/SURVEY CAPACITY DATA SET
WASTE STREAMS WITH SPECIFIED WASTE CODES IN BOOKS J-N
SURFACE DISPOSED CALIFORNIA LIST HOC WASTES
NON-CBI FACILITIES ONLY
ALL VOLUMES ARE IN GALLONS
Facility ID
ijacility Name
Book Question
Key Waste Waste
Letter Code Desc
1986 Quantity
NVT330010000
NYD080336241
US Ecology Chem Site Inc. L 35
Waste Codes: D001,11122 ,U159 ,
U002,D002,D005.D008,P104,D007,
D011,U080,U228,U048
Cecos International L 31
Waste Codes: U048
AO
U048 B88
i)04'8 A08
480
26
NYD080336241
TXD069452340
AZD980665814
TXD069452340
NVT330010000
Cecos International L 31
Waste Codes: U067
Texas Ecologists Inc. L 35
Waste Codes: D001,0002,U037,
U077.U067
University of Arizona L 35
Waste Codes:D001,U002,
D003,U151,U075
Texas Ecologists Inc. L 35
Waste Codes: U078,U211
US Ecology Chem Site Inc. L 35
Waste Codes: D001,D002,0005 ,
U080,U239,P030,P106>D010,U151)
U228,U079,U188,U1171U077,U134
AS
11
35
AG
U067 A08
U067 B36
U075 B53
U078 B36
U079 B88
26
240
1,200
960
240
F-3
-------
TABLE F-l (continued)
REQUEST D0906A
DATA SOURCE: TSX>R>SURVEY CAPACITY DATA SET
WASTE STREAMS WITH SPECIFIED WASTE CODES IN BOOKS J-N
SURFACE DISPOSED CALIFORNIA LIST HOC WASTES
NON-CBI FACILITIES ONLY
ALL VOLUMES ARE IN GALLONS
/ ;
Facility ID :
acility Narte
Book Question
Key
Letter
Waste
Code
Waste
Desc
1986 Quantity
NYD080336241
Cecos International
Waste Codes: U081
31
AY
U081 A08
9,701
NYD080336241
Cecos International
Waste Codes: U082
31
AZ
U082 A08
19
NVT330010000
TXD069452340
US Ecology Chem Site Inc. L 35
Waste Codes: D001,0002,D006,
D010>P030PU211,U057,U239,U188,
U002,D007,U127,U185
Texas Ecologists Inc. L 31
Waste Codes: U142
AK
'U127 B88
U142 A08
480
240
NVT330010000
NYD080336241
NVT330010000
US Ecology Chem Site Inc. L 35
Waste Codes: D001,D002,D006,
0010,P030 ,0211.0057,0239,0188.
U002,D007,U127,U185
Cecos International L 31
Waste Codes: U225
U& Ecology Chem Site Inc. L 35
Waste Codes: 0001,0002,0009,
U112,U237,P106,U151,U122,U196,
0154,0211.0156,0165.0188,0057
AK
U185 B88
480
BY
AL
U225 A80
U237 B88
12
240
F-4
-------
TABLE F-2
REQUEST D0906A
DATA SOURCE: T6D* SURVEY CAPACITY DATA SET
WASTE STREAMS WITH SPECIFIED WASTE CODES IN BOOKS J-N
ALL OTHER SURFACE DISPOSED WASTES
NON-CBI FACILITIES ONLY
ALL VOLUMES ARE IN GALLONS
Facility ID
Facility Name
Book Question
Key
Letter
Waste
Code
Waste
Desc
1986 Quantity
NVT330010000
NVT330010000
NVT330010000
NVT330010000
OHD087433744
OHD087433744
US Ecology Chem Site Inc.
Waste Codes: D001,0002,D005,
D007,D009,D010,P106,P030,D008,
U151,D004,U204,U134,P098,P087
US Ecology Chem Site Inc.
Waste Codes: D001,U003,U044,
U154>U1231D002,P087,P012,U151,
U239,U007,P106,P121
US Ecology Chem Site Inc.
Waste Codes: D001,D002,D007,
D009,0011,U134,P106,D008,P098,
P121,D005,D004,P012,P087
US Ecology Chem Site Inc.
Waste Codes: D001,D002,U213,
U220,U239,U144,U112,U037,U167
U021,U188,U117,U055,U228
Cecos International Inc.
Waste COdes: K022,K083,U012,
U055.U188
Cecos International Inc.
Waste Codes: K022,K085,U012,
U055.U188
35
35
35
35
35
35
AE P087 B55
AN P0'8*7 B88
P087 B55
U055 B88
CO U055 B90
CU U055 B90
960
32,160
960
240
8,640
960
F-b
-------
TABLE F-2 (continued)
REQUEST D0906A
DATA SOURCE: TED* SURVEY CAPACITY DATA SET
WASTE STREAMS WITH SPECIFIED WASTE CODES IN BOOKS J-N
ALL OTHER SURFACE DISPOSED WASTES
NON-CBI FACILITIES ONLY
ALL VOLUMES ARE IN GALLONS
\
1
Facility ID
Facility Name
Key Waste Waste
Book Question Letter Code Desc
1986 Quantity
OHD087433744
NVT330010000
NVT330010000
Cecos International Inc.
Waste Codes: D001,D014.U240,
U093
US Ecology Chem Site Inc.
Waste Codes: D001,D002,D005,
U080,U239,P030,P106,D010,U151,
U228 ,uo79,\}iQ8,uin,\)077,uiu
US Ecology Chem Site Inc.
Waste Codes: D001,D002,U213,
U220,U239IU144,U112,U037IU167
U021,U188,U117,U055,U228
35
BZ U093
AG
B80
B88
240
240
35
U117
B88
240
F-6
-------
Table F-3
REqUEST D0912A
DATA SOURCE: TSDRlTSURVEY CAPACITY DATA SET
WASTE STREAMS WITH 'SPECIFIED WASTE GOES IN BOOK N
CALIFORNIA LIST DEEPWELL WASTES
NON-CBI FACILITIES ONLY
ALL VOLUMES ARE IN GALLONS
Facility ID
OKD000402396
TXD027147115
TXD078432457
icility Namte
.
Chemical Resources Inc.
Waste codes: D001, K086
Malone Service Co.
Waste Codes: K086
Celanese Chemical Co.
Book
N
N
N
Question
24
20
24
Key
Letter
D
AD , i T
B
Waste
Code
K086
K086
U138
1986 Quantity
222,960
14,640
124,000,000
LAD008175390
TXD027147115
TXD078432457
Waste Codes: D002,D007,F001,
F002,F003,F004,F005,U001,U002,
Ul 15 ^154,0031^138^159^133,
U197.U226
American Cyanamid Co. N
Waste Codes: K011,K013,U009,
U154,F001,U162,P063,P069,D008
U007.U008.U192
Malone Service Co.
Waste Codes: U226
Celanese Chemical Co
W^ste Codes: D002,D007,F001,
F002,F003,F004,F005,U001,U002,
U115,U154,U031,U138,U159,U133,
U197.U226
N
24
20
24
AB
U192
U226
U226
188,727,600
480
124,000,000
F-7
-------
Table F-3 (continued)
REQUEST D0912A
DATA SOURCE: TSDR>'SURVEY CAPACITY DATA SET
WASTE STREAMS WITH SPECIFIED WASTE GOES IN BOOK N
CALIFORNIA LIST DEEPWELL WASTES
NON-CBI FACILITIES ONLY
ALL VOLUMES ARE IN GALLONS
Facility ID
Facility Name
Book
Key Waste
Question Letter Code 1986 Quantity
TXD091270017
TXD027147115
Cecos International Inc. N
Waste Codes: F002;U226
Malone Service Co.
Waste Codes: U228
N
20
Y •
U226
U228
4,080
1,200
F-8
-------
Table F-4
REQUEST D0912A
DATA SOURCE: TSDR>SURVEY CAPACITY DATA SET
WASTE STREAMS WITH'SPECIFIED WASTE GOES IN BOOK N
ALL OTHER DEEPWELL WASTES
NON-CBI FACILITIES ONLY
ALL VOLUMES ARE IN GALLONS
Facility ID
LAD000618256
LAD000618256
LAD000618256
LAD000618256
LAD000618256
OKD000402396
OKD000402396
TXD027147115
TXD091270017
| Facility Name
Cecos
Waste
Cecos
Waste
Cecos
Was te
Cecos
Waste
Cecos
Waste
International
Codes: F006
International
Codes: F006 ,
International
Codes: D002 ,
International
Codes. K016,
International
Codes : F002 ,
Chemical Resources
Waste Codes: F006
Chemical Resources
Waste Codes: F006 ,
Marone
Waste
Cecos
Service Co.
Codes: F006
International
Inc.
Inc .
U103
Inc .
F006
Inc .
K031.F006
Inc .
F006
Inc .
Inc .
F007.F008
Inc .
Book
N
N
N
N
N
N
N
N
N
Question
20
24
24
24
24
20
24
V
20
20
Key
Letter
C
...'•€ T
G
R
T
B
G
G
I
Waste
Code
F006
F006
F006
F006
F006
F006
F006
F006
F006
1986 Quant
62,
3,
1,
339,
1,
150,
17,
12,
3,
ity
400
120
920
120
680
000
040
240
600
Waste Codes: F006
F-9
-------
Table F-4 (continued)
REQUEST D0912A
DATA SOURCE: TSDR!1 SURVEY CAPACITY DATA SET
WASTE STREAMS WITH SPECIFIED WASTE GOES IN BOOK N
ALL OTHER DEEPWELL WASTES
NON-CBI FACILITIES ONLY
ALL VOLUMES ARE IN CALLONS
Facility ID ,
Facility Name
Book Question
Key
Letter
Waste
Code
1986 Quantity
LAD008213191
OHD005108477
LAD008175390
LAD008175390
LAD008175390
OK.D000402396
Rubicon Inc.
Waste Codes: K083,K103,U012,
U056.U169
Aristech Chemical Co.
Waste Codes: K083.U012
American Cyanamld Co.
Waste Codes: K011,K013,U009,
U154,F001.U162,P063,P069,D008
U007.U008.U192
American Cyanamld Co.
Waste Codes: K011,K013,U009,
U154,F001,U162.P063,P069,D008
U007.U008.U192
American Cyanamid Co.
Waste Codes: K011,K013,U009,
U154,F001,U162.P063,P069.D008
UOf7.U008.U192
Chemical Resources Inc.
Waste Codes: K062,D002,F003,
F004.U008.U009
24
24
24
24
24
24
K083
KU83
P069
U007
U008
U008
63,120
5,000,000
188,727,600
188,727,600
188,727,600
81 , 120
F-10
-------
Table F-4 (continued)
REQUEST D0912A
DATA SOURCE: TSDR''SURVEY CAPACITY DATA SET
WASTE STREAMS WITH SPECIFIED WASTE GOES IN BOOK N
ALL OTHER DEEPWELL WASTES
NON-CBI FACILITIES ONLY
ALL VOLUMES ARE IN GALLONS
/ i
Facility ID
Facility Name
Book Question
Key
Letter
Waste
Code
1986 Quantity
LAD008213191
LAD000618256
LAD008213191
LAD008213191
LAD008213191
TXD078432457
Rubicon Inc.
Waste Codes:
U056.U169
K083,K103,U012.
Cecos International Inc.
Waste Codes: F006;U103
Rubicon Inc.
Waste Codes: D002,0003,U012,
U037.U105
Rubicon Inc.
Waste Codes: U012,U105,U106
U169.U221
Rubicon Inc.
Waste Codes: U012.U105.U106
U169.U221
Celanese Chemical Co.
Waste Codes: D002,D007.F001,
FQ{fc ,F003,F004,F005,U001,U002,
0115,0154^031,0138,0159^133,
U197.U226
N
24
24
24
24
24
v 24
•••; c
U056
U103
U105
U105
U106
U133
63,120
3,120
1,073,040
26,824,080
26,824,080
124,000,000
F- 11
-------
Table F-4 (continued)
REQUEST D0912A
DATA SOURCE: TSDff SURVEY CAPACITY DATA SET
WASTE STREAMS WITH SPECIFIED WASTE GOES IN BOOK N
ALL OTHER DEEPWELL WASTES
NON-CBI FACILITIES ONLY
ALL VOLUMES ARE IN GALLONS
1
t ,
Facility ID
'acility Name
Book
Question
Key
Letter
Waste
Code
1986 Quantity
KYD003924198
DuPont
Waste Codes: D002,F005,F024
F002,F001,U154,U162,U220,U159,
U002,U044,U080,U210.U213,F003.
U239
N
24
U162
55,000,000
LAD008175390
TXD027147115
American Cyanamid Co.
Waste Codes: K011,K013,U009,
U154,F001,U162,P063,P069,D008
U007.U008.U192
Malone Service Co.
Waste Codes: D001.U165
24
24
AA
U162
U165
188,727,600
240
TXD027147115
Malone Service Co.
Waste Codes: D001,U031,U165,
U159
24
U165
1,680
LAD008213191
LAD008213191
Rubicon Inc.
Waste. Codes: K083 , K103 , U012 ,
U056.HJ169
Rubicon Inc .
Waste Codes: U012,U105,U106,
U169.U221
24
24
U169
U169
63, 120
26,824,080
F-12
-------
Table F-4 (continued)
REQUEST D0912A
DATA SOURCE: TSDRl'SURVEY CAPACITY DATA SET
WASTE STREAMS WITH SPECIFIED WASTE GOES IN BOOK N
ALL OTHER DEEPWELL WASTES
NON-CBI FACILITIES ONLY
ALL VOLUMES ARE IN GALLONS
/ !
Facility ID
Facility Name
Book Question
Key
Letter
Waste
Code
1986 Quantity
TXD078432457
KYD003924198
Celanese Chemical Co.
Waste Codes: D002,0007,F001,
F002,F003.F004,F005,U001,U002,
U115,U154,U031,U138,U159.U133,
U197.U226
DuPont
Waste Codes: D002.F005.F024
F002.F001,U154,U162,U220,U159,
U002,U044,U080,U210,U213,F003 ,
U239
N
24
U197
124,000,000
24
U213
55,000,000
F- 13
-------
F.2 Documentation On the Use of Volumes From Previous Capacity Analysis
This section lists those waste codes and associated volumes that were obtained
from the background documents from previous capacity analyses. These volumes were
reevaluated for the Third Third final rule because of BOAT revisions or additions
from the background documents from the previous capacity analysis.
Waste Code
F024
K069 (calcium sulfate)
K083
Total Quantity
81,025"
41b
75,732C
Quantity Requiring
Treatment Capacity
8,785
41
15,146
In the Second Third rule, 8 ,06'2-'gallons/year of F024 waste was assigned to
stabilization of incinerator ash and 723 gallons/year was assigned to
stabilization of scrubber water treatment sludge, both after incineration of
wastewaters and nonwastewaters. EPA is promulgating BOAT standards for new
I-
nonwastewaters metal constituents based on stabilization. Therefore, the volumes
of F024 waste have been 'worst cased' and re-assigned to stabilization in the
Thl'rd Third capacity analysis despite prior inclusion in the baseline study.
In the First Third rule, the 'no land disposal' restriction was promulgated
for K083 nonwastewaters based on the performance of incineration. EPA is revoking
this restriction and promulgating concentration restrictions based on incineration
for organics and stabilization for inorganics. Based on the 75,732 gallons/year
assigned to combustion in the First Third rule, 15,146 gallons/year is being
assigned to stabilization in the Third Third rule.
a Source: Background Document for Second Third Wastes to Support 40 CFR Part
268 Land Disposal Restrictions, Final Rule, Volume I, June 1989, p. 2-93.
b Source: Single generator of waste that responded to Waste Treatment
Branch.
c Background Document for First Third Wastes to Support 40 CFR Part 268 Land
Disposal Restrictions, Final Rule, August 1988, p. 2-77.
F-14
-------
For K069 non-calcium sulfate nonwastewaters, EPA is promulgating recycling as
a method in place of the 'no land disposal based on recycling' restrictions
promulgated in the First Third rule. For calcium sulfate nonwastewaters, EPA is
promulgating stabilization as a BOAT Through comments, EPA has identitfied a
single generator of this waste. Therefore, the volume generated by this one
generator has been added to the capacity data set and assigned to stabilization.
F-15
-------
Appendix G
Documentation for California List HOCs
-------
The California list final rule for Halogenated Organic Compounds (HOCs)
was not waste code specific, but instead regulated all hazardous wastes
containing HOCs above a specified concentration. Consequently, the Agency's
capacity analysis for HOCs included some Third Third wastes. Today's rule is
waste code specific; therefore, some overlap exists between the California
list final rule and the Third Third final rule. In addition, some of the
technologies to which Third Third wastes were assigned for the California list
final rule may no longer be appropriate as a result of today's rule.
The Agency has therefore decided to reanalyze all California list HOC
wastes subject to today's rule a"nd has included these wastes in the estimates
of required capacity as a resultr'oS the Third Third final rule. The following
tables present these wastes, their TRD groups, and volumes requiring
alternative treatment capacity; Table 1-1 listing the surface disposed wastes,
Table 1-2 listing the deepwell injected wastes. In order to avoid double
counting these wastes, the Agency has subtracted their volumes from required
I
capacity estimates for the California list final rule, and has rendered the
capacity to which these wastes were assigned under the California list final
rule as available for the Third Third final rule.
G-l
-------
TABLE G-l
REQUEST C0367G01
DATA SOuhcE: TSDR SURVEY
WASTE VOLUMES (GALS) BY WASTE CODE, WASTE DESCRIPTION, AND TRD GROUP
SURFACE DISPOSED CALIFORNIA LIST HOC'S
SINGLE WASTE CODES ONLY BY WASTE CODE
Waste
Code
D012
D012
D012
D012
D013
D013
D013
D013
D013
D014
Waste
Desc
B02
B44
B6A
B80
B02
B02
B44
B70
B80
B02
' NO ';RD
1986 Vol
0
500,000
0
0
960
0
500,000
480
0
t
0
With
1986 Vol
144,000
0
16,800
288,000
0
720,000
0
0
291,120
864,000
TRD
1988 Vol
144,000
0
16,800
288,000
0
720,000
0
0
291,120
864,000
1988 Volume TRD
w/o Reason Group
144,000 2
0
'. T
16 , 800 ;;- 2
288,000 2
0
7.20,000 2
0
0
• 291,120 2
864,000 2
AfR
Code
1
2
1
2
1
2
1
2
1
2
1
2
Volume
Assigned
144,000
0
0
0
0
0
0
0
720,000
0
0
0
0
0
864,000
0
G-2
-------
REQUEST C0367G01
DATA SOURCE: TSDR SURVEY
. ...^
WASTE VOLUMES (GALS) BY WASTE CODE, WASTE DESCRIPTION, AND TRD GROUP
SURFACE DISPOSED CALIFORNIA LIST HOG'S
SINGLE WASTE CODES ONLY BY WASTE CODE
Waste
Code
D014
D015
D015
D015
D016
D016
D016
D016
D016
D016
K085
Waste
Desc
B80
B
B02
B56
B02
B64
B70
B80
B86
B90
A07
No ; RD
' 1986 Vol
* 0
7,968
0
0
0
0
0
0
0
-------
REQUEST C0367G01
DATA SOURCE: TSDR SURVEY
' ' >
WASTE VOLUMES (GALS) BY WASTE CODE, WASTE DESCRIPTION, AND TRD GROUP
SURFACE DISPOSED CALIFORNIA LIST HOC'S-
SINGLE WASTE CODES ONLY BY WASTE CODE
Waste
Code
K105
K105
P024
P024
P024
P028
P037
P123
U006
Waste
Desc
A
A05
A01
A08
A08
A08
A08
A08
A01
No T»D
1986 )/ol
f
0
0
0
0
0
0
0
0
(
0
With TRD 1988 Volume
1986 Vol 1988 Vol w/o Reason
00 0
4,560 4,560 4,560
480 480 480
2,880 2,880 2,880
240 240 240
720 720 720
240 240 240
1,200 1,200 ' 1,200
1,920 1,920 1,920
TRD ATR
Group Code
21 23
5
21
'" ' 22
.:' 8
3 IB
2B
2 1
2
2 1
2
2 1
1 1
39 1A
2A
3 IB
2B
Volume
Assigned
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,920
0
U006
A05
-------
REQUEST C0367G01
DATA SOURCE: TSDR SURVEY
. "*»
WASTE VOLUMES (GALS) BY WASTE CODE, WASTE DESCRIPTION, AND TRD GROUP
SURFACE DISPOSED CALIFORNIA LIST HOC'S
SINGLE WASTE CODES ONLY BY WASTE CODE
Waste
Code
U030
U036
U036
U044
U044
U044
U061
U061
U072
Waste
Desc
All
A08
All
A05
A08
A08
A08
A08
• A08
NO ITRD
198fl Vol
0
0
0
13
0
0
0
0
•to
With
1986 Vol
240
4.080
960
0
4,320
240
3,600
480
218,160
TRD
1988 Vol
240
4,080
960
0
4,320
240
3 , 600
480
218,160
1988 Volume TRD
w/o Reason Group
240 2
4,080 2
960 ; 2
0
4,320 3
240 3
3,600 2
480 2
ir
218,160 2
1
ATR
Code
1
2
1
2
1
2
IB
2B
IB
2B
1
2
1
2
1
2
Volume
Assigned
0
0
0
0
0
0
240
0
0
0
0
0
0
0
-------
REQUEST C0367G01
DATA SOURCE: TSDR SURVEY
"'t
WASTE VOLUMES (GALS) BY WASTE CODE, WASTE DESCRIPTION, AND TRD GROUP
SURFACE DISPOSED CALIFORNIA LIST HOC'S
SINGLE WASTE CODES ONLY BY WASTE CODE
Waste
Code
U072
U073
U076
U080
U080
U080
U129
U131
U138
U142
U156
Waste
Desc
AEB
A08
A08
A
A05
A08
A08
A13
A05
A08
All
No ;'RD
1986 Vol
0
0
0
1,440
23
0
0
0
10
0
With
1986 Vol
240
240
8,880
0
0
960
480
144,000
0
240
1,440
TRD
1988 Vol
240
240
8,880
0
0
960
480
144,000
0
240
1,440
1988 Volume
w/o Reason
240
240
8,880
0
0
960
480
144,000
0
240
1 ,440
TRD ATR
Group Code
2 1
2
3 IB
2B
2 1
2
3 IB
2B
2 1
2 1
2
2 1
2
2 1
2
Volume
Ass igned
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
U158
2,400
C-6
-------
REQUEST C0367G01
DATA SOURCE: TSDR SURVEY
", "'*
WASTE VOLUMES (GALS) BY WASTE CODE, WASTE DESCRIPTION, AND TRD GROUP
SURFACE DISPOSED CALIFORNIA LIST HOG'S
SINGLE WASTE CODES ONLY BY WASTE CODE
Waste
Code
U158
U209
U210
1191 0
U210
U211
U211
U226
U226
U226
Waste
Desc
A13
A08
A05
AOR
A08
A05
A08
A05
A08
A13
, No CRD
1986/Vol
!
0
0
0
n
0
11
0
(
1
0
0
With TRD 1988 Volume TRD
, 1986 Vol 1988 Vol w/o Reason Group
3,840 3,840 3,840 2
6,240 6,240 6,240 3
'* T
1,700 1,700 1,700 ;•;• 40
79f) 790 790 9
6,480 6,480 6,480 2
00 0
240 240 - 240 2
00 0
6,240 6,240 6,240 3
240 240 240 2
r~
ATR
Code
1
2
IB
2B
5
21
22
24
6
1
2
1
2
1
2
IB
2B
1
2
Volume
Assigned
0
0
6,240
0
0
0
0
0
0
0
.0
6,480
0
0
0
0
720
0
0
0
G- 7
-------
REQUEST C0367G01
DATA SOURCE: TSDR SURVEY
, "'»
WASTE VOLUMES (GALS) BY WASTE CODE, WASTE DESCRIPTION, AND TRD GROUP
SURFACE DISPOSED CALIFORNIA LIST HOG'S
SINGLE WASTE CODES ONLY BY WASTE CODE
Waste Waste No T,
Code Desc 1986
U227 A08
U228 A13
U240 A08
U240 AEF
D012 B80
D013 B80
D014 B
D014 B80
D014 B90
D014 B80
ID With TRD 1988 Volume TRD
rol 1986 Vol 1988 Vol w/o Reason Group
0 3,600 3,600 3,600 3
0 480 480 480 2
'• f
0 20,400 20,400 20,400 2
0 720 720 720 2
0 146,400 146,400 146,400 1
0 146,400 146,400 146,400 1
0 1,920,000 1,920,000 1,920,000 75
i
,0 480 480 480 2
0 00 02
0 0 0 0 2
1
ATR
Code
IB
2B
1
2
1
2
1
2
1
2
1
2
48
59
1
2
1
2
1
2
Volume
Assigned
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
-------
REQUEST C0367G01
DATA SOURCE: TSDR SURVEY
. ""»•
WASTE VOLUMES (GALS) BY WASTE CODE, WASTE DESCRIPTION, AND TRD GROUP
SURFACE DISPOSED CALIFORNIA LIST HOC'S
SINGLE WASTE CODES ONLY BY WASTE CODE
Waste
Code
D015
D016
K017
K017
K116
P004
P037
P123
U036
U036
U071
U072
Waste
Desc
B
B64
B82
B82
B64
B89
B89
B81
B80
B89
B89
B89
NojTRD
, 198* Vol
2J.256
1,168,800
0
0
93,578,880
0
0
0
0
0
t
0
0
With
1986 Vol
0
0
5,760
62,640
0
336
336
480
0
336
480
480
TRD
1988 Vol
0
0
5,760
62,640
0
336
336
480
0
336
480
480
1988 Volume TRD
w/o Reason Group
0
0
5,760 2
't r
62,640 " 65
0
336 2
336 2
480 2
0 2
336 2
480 2
480 2
ATR
Code
1
2
41
7
1
2
1
2
1
2
1
2
1
2
1
2
1
2
Volume
Ass igned
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
G-9
-------
REQUEST C0367G01
DATA SOURCE: TSDR SURVEY
". 't
WASTE VOLUMES (GALS) BY WASTE CODE, WASTE DESCRIPTION, AND TRD GROUP
SURFACE DISPOSED CALIFORNIA LIST HOC'S
SINGLE WASTE CODES ONLY BY WASTE CODE
Waste
Code
U080
U240
U240
U037
U037
U044
U071
U072
U077
U080
U080
U080
Waste
Desc
B36
B
B80
B64
B89
B89
B89
B89
B08
• B
B02
B89
NO JTRD
198^ Vol
1
0
0
0
1,073.040
0
0
0
0
52,895,520
1.2J00
0
0
With
1986 Vol
136,956
0
240
0
3,180
288
320
320
0
0
2,654,520
3,468
TRD
1988 Vol
136,956
0
240
0
3,180
288
320
320
0
0
2,654,520
3,468
1988 Volume TRD
w/o Reason Group
136,956 1
0 1
240 '• " 2
.•-'
0
3,180 2
288 2
320 2
320 2
0
0
2,654,520 5
^ 3,468 2
ATR
Code
1
1
1
2
1
2
1
2
1
2
1
2
5
21
22
1
2
Volume
Assigned
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
-------
REQUEST C0367G01
DATA SOURCE: TSDR SURVEY
IP
WASTE VOLUMES (GALS) BY WASTE CODE, WASTE DESCRIPTION, AND TRD GROUP
SURFACE DISPOSED CALIFORNIA LIST HOC'S-
SINGLE WASTE CODES ONLY BY WASTE CODE
Waste
Code
U121
U129
U158
U192
U208
U209
U210
U211
U226
U226
U226
Waste
Desc
B02
B89
B42
B81
B89
B89
B89
B89
B02
B89
B90
No "AlD
' 1986 |/ol
f
2,017,560
0
0
0
0
0
0
0
2,017,5*0
0
0
With
1986 Vol
0
336
246,240
1,440
48
4,800
3,180
608
0
48
9,120
TRD
1988 Vol
0
336
246,240
1,440
48
4,800
3,180
608
0
48
9,120
1988 Volume
w/o Reason
0
336
246,240
1,440
48
4,800
2
608
^
0
48
9,120
TRD
Group
2
;,: 20
2
2
2
1
2
2
2
2
1
ATR
Code
1
2
7
1
2
1
2
1
2
0
0
1
2
1
2
1
2
Volume
Ass igned
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
G- 11
-------
REQUEST C0367G01
DATA SOURCE: TSDR SURVEY
'. '>
WASTE VOLUMES (GALS) BY WASTE CODE, WASTE DESCRIPTION, AND TRD GROUP
SURFACE DISPOSED CALIFORNIA LIST HOC'S-
SINGLE WASTE CODES ONLY BY WASTE CODE
Waste
Code
U227
U228
U240
U247
Waste
Desc
B02
B89
B81
B89
No 'JJRD With TRD
1986jVol 1986 Vol 1988 Vol
[
0 2,654,520 2,654,520
0 3,180 3,180
0 1,440 1,440
0 336 336
1988 Volume
w/o Reason
2,654,520
3,180
1,440
336
TRD
Group
5
'•• >• 2
2
2
ATR
Code
5
21
22
1
2
1
2
1
2
Volume
Assigned
0
0
0
0
0
0
0
0
0
C-12
-------
TABLE G-2
REQUEST C0367G01
DATA SOURCE: TSDR SURVEY
WASTE VOLUMES (GALS) BY WASTlflCODE, WASTE DESCRIPTION, AND TRD CROUP
CALIFORNIA LIST HOC ' S
SINGLE WASTE CODES ONLY BY WASTE CODE
UNDERGROUND INJECTION WELL ONLY
Waste Waste No TRD With TRD
Code Desc 198f Vol 1986 Vol 1988 Vol
D014 B01 [ 0 56,880 56,880
(
K033 A07 0 4,237,680 4,237,680
K097 A07 0 21,120 21,120
P058 A05 0 12,720 12,720
U044 A13 0 12,000 12,000
U074 A13 , 0 50,400 50,400
'*
U077 A05 0 9,594,480 9,594,480
1988 Volume TRD ATR
w/o Reason Group Code
56,880 19 5
21
22
3
4
4,237,680 '•'• ^ 40 5
21
22
24
6
21,120 40 5
21
22
24
6
12,720 35 38
12,000 3 IB
2B
50,400 3 IB
2B
9,594,480 40 5
21
22
24
6
Volume
Assigned
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
12,720
0
0
0
0
0
0
0
0
0
-------
REQUEST CO367GO1
DATA SOURCE: TSDR SURVEY
WASTE VOLUMES (GALS) BY WASTE* tfODE, WASTE DESCRIPTION, AND TRD GROUP
CALIFORNIA LIST HOC'S
SINGLE WASTE CODES ONLY BY WASTE CODE
UNDERGROUND INJECTION WELL ONLY
Waste Waste No TRD With TRD
Code Desc , 1986iVol 1986 Vol 1988 Vol
U080 A08 0 3,360 3,360
U185 A05 0 1,000,000 1,000,000
U210 A05 0 1,000,000 1,000,000
U211 A05 0 11,520 11,520
1988 Volume TRD ATR
w/o Reason Group Code
3,360 3 IB
2B
1,000,000 21 23
5
21
'• ' 22
/' 3
1,000,000 40 5
21
22
24
6
11,520 40 5
21
22
24
6
Volume
Assigned
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
C-1 4
-------
TABLE G-2
REQUEST C0367G01
DATA SOURCE: TSDR SURVEY
WASTE VOLUMES (GALS) BY WASTE'00DE, WASTE DESCRIPTION, AND TRD GROUP
CALIFORNIA LIST HOC'S
SINGLE WASTE CODES ONLY BY WASTE CODE
UNDERGROUND INJECTION WELL ONLY
Waste
Code
D012
D013
D014
D015
D016
D017
K017
Waste No T
Desc 1986 ,
B70 (
B70
B70
B70
B70
B70
B01
P
tol 1986
0 2.333
0 2,333
0 2,333
0 2,333
0 2,333
0 2,333
0 88,080
With TRD
Vol
,333
,333
,333
,333
,333
,333
,000
1988
2,333
2,333
2,333
2,333
2,333
2,333
88,080
Vol
,333
,333
,333
,333
.333
,333
,000
1988 Volume
w/o Reason
2,
2,
2,
2,
2,
2,
88,
333,
333,
333,
333,
333,
333,
080,
333
333
333
333
333
333
000
TRD
Group
83
83
83
'> > 83
83
83
46
ATR
Code
61
61
61
61
61
61
5
Volume
Assigned
0
0
0
0
0
0
0
K032
K033
K097
BO 7
B07
BO 7
22
22
22
22
22
22
22
22
22
10
10
10
6
21
22
12
13
49
12
13
49
12
13
49
0
0
0
0
0
0
0
0
0
0
0
0
G-15
-------
TABLE G-2
REQUEST C0367GO1
DATA SOURCE: TSDR SURVEY
WASTE VOLUMES (GALS) BY WASTE "CODE, WASTE DESCRIPTION, AND TRD GROUP
CALIFORNIA LIST HOC'S
SINGLE WASTE CODES ONLY BY WASTE CODE
UNDERGROUND INJECTION WELL ONLY
Waste Waste No T,
Code Desc , 1986 ,
P050 B14
P051 B14
P059 B14
U034 B02
U037 B01
U037 B64
«D With TRD 1988 Volume TRD ATR
lol 1986 Vol 1988 Vol w/o Reason Group Code
0 227,520 227,520 227,520 5 5
21
22
0 46,080 46,080 46,080 5 5
21
'" * 22
0 227,520 227,520 227,520 5 5
21
22
0 17,600 17,600 17,600 40 5
21
22
24
6
0 66,240 66,240 66,240 40 5
21
22
24
6
0 1,073,040 1,073,040 1,073,040 36 IB
2B
5
21
+ 22
Volume
Assigned
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1 ,073,040
0
0
0
c; -16
-------
TABLE G-2
REQUEST C0367G01
DATA SOURCE: TSDR SURVEY
WASTE VOLUMES (GALS) BY WAST.E (IfODE, WASTE DESCRIPTION, AND TRD GROUP
CALIFORNIA LIST HOC'S
SINGLE WASTE CODES ONLY BY WASTE CODE
UNDERGROUND INJECTION WELL ONLY
Waste Waste No '
Code Desc 1986,
U041 B01
U044 B02
U045 B02
U077 B01
RD With TRD 1988 Volume TRD ATR
Vol 1986 Vol 1988 Vol w/o Reason Group Code
0 30,178,560 30,178,560 30,178,56u 40 5
21
22
24
6
0 17,600 17,600 17,600 '" T 40 5
'•': 2 1
22
24
6
0 17,600 17,600 17,600 40 5
21
22
24
6
0 30,178,560 30,178,560 30,178,560 40 5
21
22
24
6
V
U080 B02 2,654,520 2,654,520 2,654,520 2,654,520
U083 B01
0 30,178,560 30,178,560 30,178,560 40 5
21
22
24
^ 6
Volume
Assigned
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
C- 17
-------
TABLE G-2
REQUEST C0367G01
DATA SOURCE: TSDR SURVEY
WASTE VOLUMES (GALS) BY WASTK'dODE, WASTE DESCRIPTION, AND TRD GROUP
CALIFORNIA LIST HOC ' S
SINGLE WASTE CODES ONLY BY WASTE CODE
UNDERGROUND INJECTION WELL ONLY
Waste
Code
Waste
Desc
No T
, 1986 ,
RD
I/O 1
With
1986 Vol
TRD
1988
Vol
1988
w/o
Volume
Reason
TRD
Group
ATR
Code
Volume
Assigned
U084
B01
30,178,560
30,178,560
30,178,560
40
5
21
22
24
6
0
0
0
0
0
U227
B02
2,654,520
2,654,520
2,654,520
2,654,520
-------
APPENDIX H
BIBLIOGRAPHY FOR THIRD THIRD LAND DISPOSAL RESTRICTIONS
-------
1. USEPA. 1984. U.S. Environmental Protection Agency. National
survey of hazardous waste generators and treatment, storage, and
disposal facilities regulated under RCRA in 1Q81. EPA/530-SW-
005, GPO Pub. #5/N055-000-00239-8.
2. USEPA. 1986. U.S. Environmental Protection Agency, Office of
Solid Waste. Background document for solvents to support 40 CFR
Part 268. land disposal restrictions. Final rule. EPA Contract
No. 68-01-7053. Washington, D.C.: U.S. Environmental
Protection Agency.
3. USEPA. 1987. U.S. Environmental Protection Agency, Office of
Solid Waste. Background document for California List wastes to
support 40 CFR Part 268 land disposal restrictions. Final rule.
EPA Contract No. 68-01-7053. Washington, D.C.: U.S.
Environmental Protection;:Agency.
4. USEPA. 1988. U.S. Environmental Protection Agency, Office of
Solid Waste. Background document for First Third wastes to
support 40 CFR Part 268 land disposal restrictions. Final rule.
EPA Contract No. 68-ai-7053. Washington, D.C.: U.S.
Environmental Protection Agency.
5. USEPA. 1988. U.S. Environmental Protection Agency, Office or
Solid Waste. Background document for Second Third wastes to
support 40 CFR Part 268 land disposal restrictions. Proposed
rule. EPA Contract No. 68-01-7053. Washington, D.C.: U.S.
Environmental Protection Agency.
_*.
6, Versar. 1989. The conpgT-cial treatment /recovery TSDR Survey
data set. Prepared for the Office of Solid Waste. Washington,
D.C.: U.S. Environmental Protection Agency.
7. USEPA. 1987. U.S. Environmental Protection Agency, Office of
Solid Waste. National survey of hazardous waste treatment,
storage, disposal, and recycling facilities. OMB No. 2050-0070.
8. Versar. 1988. Technical review procedures for the TSDR Survey.
Prepared for the Office of Solid Waste. Washington, D.C.: U.S.
Environmental Protection Agency.
9. Versar.- 1988. Quality assurance plan for the TSDR Survey.
Prepared for the Office of Solid Waste. Washington, D.C.: U.S.
Environmental Protection Agency. ^
10. Temple, Barker & Sloane, Inc. 1987. Findings on Class I
hazardous wells affected by the land ban rules. Memorandum
report to ~John Atcheson, Dave Morganvalp, and Mario Salazar,
USEPA, from TBS, December 15, 1987.
H-l
-------
ll.USEPA. 1989. U.S. Environmental Protection Agency, Office of
Solid Waste. Response to capacity-related comments submitted
on the Second Third proposed land disposal restrictions rule.
Volume II. Washington, D.C.: U.S. Environmental protection
Agency
12.Versar. 1989. Analysis of incineration capacity requirements
for contaminated soils from CERCLA remedial action sites.
Prepared for the Office of Solid Waste. Washington, D.C*: U.S.
Environmental Protection Agency.
13. Booz-Allen & Hamilton Inc. 1988. Waste volume remediation
analysis summary tables. Memorandum to USEPA, Hazardous Site
Control Division, from Booz-Allen & Hamilton Inc. July 4, 1988.
14. Environ. 1985. Characterization of waste streams listed in 40
CFR Section 261: Waste profiles. Volumes I and II. Prepared
for Waste Identification Branch of Characterization and
Assessment Division, Office of Solid Waste. Washington, D.C.:
U.S. Environmental Protection Agency -
15. U.S. EPA. 1985. U.S. Environmental Protection Agency.,^
Physical-chemical properties and categorization of RCRA wastesr
according to volatility= ' EPA-450/3-85-007. Research Triangle
Park, N.C.: U.S. Environmental Protection Agency -
16.IT Enviroscience, Inc. 1983. Survey of industrial applications
of aqueous-phase activated-carbon adsorption for control of
.*• pollutant compounds from manufacture of organic compounds.
' - Prepared for U.S. Environmental Protection Agency, Industrial
Environmental Research Laboratory.
17.Metcalf and Eddy, Inc. 1985. Technologies applicable to
hazardous waste. Briefing presented for the U.S. Environmental
Protection Agency, Office of Research and Development, Hazardous
Waste Engineering Research Laboratory, Cincinnati, Ohio.
IS.Versar. 1985. Assessment of treatment technologies for
hazardous waste and their restrictive waste characteristics.
Draft Final Report. Prepared for the Office of Solid Waste.
Washington, D.C.: U.S. Environmental Protection Agency.
19. USEPA. 1986. U.S. Environmental Protection Agency, Office of
Solid Was£4*»—^. Best demonstrated available technology (BOAT)
background document for F001-F005 spent solvents. Vols. 1-3.
EPA/530-SW-86-056. Washington, D.C.: U.S. Environmental
Protection -Agency-
20. USEPA. 1989. U.S. Environmental Protection Agency, Office of
Solid Waste. Background Document for Second Third Wastes to
Support 40 CFR Part 268 land disposal restrictions. Final Rule.
Vols. I and II. EPA Contract No. 68-01-7053. Washington, D.C. :
U.S. Environmental Protection Agency-21.Versar. 1988.
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21. Procedures for completing PC data sheets for priority TSDR
facilities. Prepared for the Office of Solid Waste.
Washington, D.C.: U.S. Environmental Protection Agency.
22.Versar. 1989. Analysis of TSDR Survey Data for the Third Third
Wastes Proposed Rule. Prepared for the Office of Solid Waste.
Washington, B.C.: U.S. Environmental Protection Agency.
23.Versar. 1989. Analysis of Generator Survey Data for the Third
Third Wastes Proposed Rule. Prepared for the Office of Solid
Waste. Washington, D.C.: U.S. Environmental Protection Agency.
24. ICF Incorporated. Response to Comments Background Document for
the Third Third Land Disposal Restrictions Proposed Rule,
November 22. 1989 (54 -FR 48372). Volume 2 — Capacity Related
Comments, May 8. 1990.- Prepared for the Office of Solid Waste.
Washington, D.C.: U.S. Environmental Protection Agency -
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H.I Bibliography for Multi-Source Leachate
1. Information presented by Barbara McGuiness, DuPont, during a
meeting on leachate capacity with Jo-Ann Bassi and Les Otte,
EPA, On Leachate Treatment Residuals. September 30, 1989.
2. Data request prepared by DPRA, Request Number D0895B, Data from
the Generator LDR Mainframe Data Set. September 14, 1989.
3. Data request prepared by DPRA, Request Number D08868A, Data from
the TSDR Survey Capacity Data Set.
4. Data table prepared by ICF, Quantity of Multi-Source Leachate
Surface-Disposed.
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5. Data table prepared by-TCF, Quantity of Multi-Source Leachate
Deepwell Disposed.
6. Phone log of industry representatives contacted by ICF.
7. Letter submitted by D.L. Berry, Dow Chemical Company, Michigan
Division, to Barbara McGuiness, DuPont, on Wastewater Treatment
Plant Solids Generation and Subsequent Treatment ^and Disposal^
at the Dow Chemical Company. Michigan Division. September 25,.*"
1989.
8. Letter submitted by Jon Gerhart, Envirosafe Management Services,
__ Inc., to Barbara McGuiness, DuPont, on Estimated Sludge
'• Generation from Treatment of Leachate at Hazardous Waste
Landfills. September 13, 1989.
9. Letter submitted by Timothy Kent, GSX Chemical Services of Ohio,
Inc., to Barbara McGuiness, DuPont, on Estimated Quantities of
Treatment Residuals from Leachate Treatment. September 7, 1989.
10. Letter submitted by Steve Bowe, U.S. Ecology, to Barbara
McGuiness, DuPont, on Estimated Solids Residues Generated from
Leachate and Groundvater Treatment. August 17, 1989.
11. Letter submitted by Carl Bender, Mill Service, to Barbara
McGuiness, DuPont, on Annual Quantities of Residues Generated
from the^On-site Treatment of Leachate. September 5, 1989-
12. Letter submitted by Barbara McGuiness, DuPont, to Jo-Ann Bassi,
EPA, on th»-Availability of Incineration Capacity forM:he Solid
Residuals from Leachate Treatment. September 13, 1989.
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H.2 Bibliography for Radioactive Wastes
1. Brookhaven National Laboratory. 1985. Analysis of
Wastes; _ Review of Hazardous Waste Regulations and
Identification of Radioactive Mixed Wastes. Final Report.
Washington, D.C.: Nuclear Regulatory Commission.
2. Carlin, Elaine. 1989. Mixed Waste in Washington and the
Northwest Compact Region: Problem Definition. Timelines, and
Management Options. State of Washington: Low-Level Radioactive
Waste Program, Department of Ecology.
3. Carlin, Elaine. 1988. Mixed Waste Management in Washington and
the Northwest Compact Region. State of Washington: Low-Level
Radioactive Waste Program, Department of Ecology.
4. Connecticut Hazardous Waste Management Service. 1988. 1988
Connecticut Low-Level Radioactive Waste Management Plan.
5. Illinois Department of Nuclear Safety. 1989. 1987 Annual
Survey Report.
6. Illinois Department of Nuclear Safety. 1988.' 1988 LLWJ
Generator Survey. (Data set on facilities storing mixed
radioactive wastes due to regulatory or technical constraints
on disposal. )
>.. Jennrich, E.A. Rogers and Associates Engineering Corporation.
'- 1989. Management Practices and Disposal Concepts for Low-Level
Radioactive Mixed Waste. Washington, D.C.: Congress of the
United States, Office of Technology Assessment.
8. Jennrich, E.A. Rogers and Associates Engineering Corporation.
1989. The Management of Mixed Waste in the Nuclear Power
Industry. Washington, D.C.: Nuclear Management and Resources
Council (NUMARC) .
9. New York State Energy Research and Development Authority. 1989.
1988 New York State Low-Level Radioactive Waste Status Report.
10. Northe
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13. Pennsylvania Department of Environmental Management. 1987.
Pennsylvania and Maryland Low-Level Radioactive Waste Management
Survey - 1986.
14. Southeast Company Commission. 1988. 1987 Summary of Low-Level
Radioactive Waste Management in the Southeast Compact.
15.USEPA. 1987. Mixed Energy Waste Study (MEWS^. Washington,
D.C.: U.S. Environmental Protection Agency.
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APPENDIX I
MEMORANDUM ON AVAILABILITY OF SURVEYS
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
'"I «BO^°
MEMORANDUM
DATE: May 8, 1990
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SUBJECT: The National,., Survey of Hazardous Waste Treatment,
Storage, Disposal, and Recycling Facilities and National
Survey of Hazardous Waste Generators
FROM: Jo-Ann Bassi
Land Disposal Branch
TO: Docket ^
The National Survey of Hazardous Waste Treatment, Storage,
Disposal, and Recycling Facilities was conducted during 1987-1989.
The Survey included about 2,500 hazardous waste facilities, i.e.,
.facilities with RCRA permits or RCRA interim status. However, for
.the capacity analysis for land disposal restrictions, those
"facilities with land disposal (i.e., waste piles, surface
impoundments, landfills, land treatment, deep wells), or with
commercial processes were considered. These facilities were
designated as priority facilities and the survey responses provide
the basis for the capacity analysis for the land disposal
restrictions rules (including the analysis of land disposal volumes
requiring alternative treatment/recycling capacity, and analysis
of available commercial capacity). All surveys were first screened
to be classified as priority or non-priority. For the priority
facilities, EPA conducted a comprehensive technical review of
survey responses and a facility capacity analysis, and also
developed a capacity data base. This data base was then used for
the national capacity analysis for the land disposal restrictions.
Given ^,hq Jarge amount of materials, the actual^TSDR Survey
booklets, all data provided in response to the Survey, all data
provided in follow-up for additional information (especially on
planned changes), and technical evaluation documentation are
located at EPA's contractor and will be available to the public
upon request to the Docket.
The National Survey of Hazardous Waste Generators was
conducted during 1987-1989. The survey included over 10,000
facilities throughout the United States. However, only a subset
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of facilities was available to support the Third Third final rule.
Printouts containing the data used by EPA are included in a report
entitled "Analysis of Generator Survey Data for the Third Third
Wastes Final Rule," which is included in the Docket for this final
rule. Given the large amount of materials, the actual Generator
Survey booklets and technical evaluation documentation that were
used for the Third Third rule are located at EPA's contractor, and
will be available to the public per requests to the Docket.
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