un«@a Slates Office of May 1990
Environmental Protectiofi Solid Waste
Agency Washington, DC 20460
Solid Waste
&EPA Background Document For
Third Third Wastes To
Support 40 CFR Part 268
Land Disposal
Third Third Waste Volumes,
Characteristics, and Required and
Available Treatment Capacity
Volume IV
APPENDIX J - APPENDIX M
-------
'TABLE OF CONTENTS (continued)
Section
CAPACITY ANALYSIS METHODOLOGY
4.1 Determination of Required Treatment Capacity.. . . . .
4.1.1 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 Treatabilityf Analysis ' . .' '. '. ... . *. .- . . . .
4.1.2.(i) Waste Characterization ......
4. 1.2. (2) Treatability Grouping/Assigning . ',
. "-'v Alternative Treatment ......
4. 1.2. (3) Treatment Residuals . . . .....'.
4. ,1.2. (4) Previous 'Management . ..... . . . .
4.2 Determination of Available Treatment Capacity ... . .
4 . 2 .1, v Determination of Combustion Capacity v .' . .
U.2.l.(l) 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
Available Treatment Capacity) ............
Volume II
APPENDICES . :.'''
Appendix A - Leachate . ............. '« ......
Appendix B - Mixed Radioactive Waste ........ .....
/
Appendix C - Available Capacity;iAnalyses for Each Rule and
Addition of Recent ChemWaste Management Data . .
Appendix D - Capacity Analysis for Third Third Promulgated
Wastes ..... ................
4-1
4-1
4-1
4-1
4-2
4-2
4-5
4-5
4-8
4-10
4-11
4-12
4-12
4-12
4-15
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
I
-------
TABLE OF CONTENTS (continued)
Section
Appendix. E Capacity Analysis 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
E 1
F-l
G-l
H-l
I 1
J 1
K-l
L-l
M-l
VLl
-------
LIST OF TABLES
Table ES-1 Summary of National Capacity Variances for Surface
Land-Disposed Wastes
Table ES-2 Summary of Two-Year National Capacity Variances for
Underground Injected Wastes
Table ES-3 Determination of Available Commercial Capacity for
Third Third Wastes (million gal/yr)
Table ES-4 Required Alternative Commercial Treatment/Recycling
Capacity for Surface-Disposed Wastes (million gal/yr)
Table ES-5 Required Alternative Commercial Treatment/Recycling
Capacity for Deepwell-Disposed Wastes (million gal/yr)
Table ES-6 Required Alternative Commercial Treatment/Recycling
Capacity For Soil and Debris Wastes (million gal/yr)
Table ES- 7 Summary of Capacity Analysis for Mixed Radioactive
Wastes
Table ES-8 Summary of Capacity Analysis for Third Third Wastes
by Waste Code [includes all wastes regulated under
Third Third]
Table 1 1 Third Third Final Rule Wastes by Waste Code
Table 2-1 Overview of All Surface Disposed RCRA Hazardous
Wastes (revised based on ChemWaste Data)
Table 2-2 Overview of Surface Disposed Solvent Wastes
(revised based on ChemWaste)
Table 2-3 Solvent Capacity Analysis (revised based on new
CheraWaste Management Numbers)
Table 2-4 Overview of Surface Disposed Potential California
List Wastes Containing Halogenated Organic
Compounds
Table 2-5 Overview of Surface Disposed First Third
Promulgated Wastes Containing Halogenated
Organic Compounds
Table 2-6 Overview of All Other Surface Disposed Wastes
Containing Halogenated Organic Compounds
Table 2-7 Capacity Analysis for HOC Wastes (Excluding First
Third and Third Third Promulgated HOCs)
Page
No.
E-8
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
-------
LIST OF TABLES (continued)
Page
No.
Table 2-8 Overview of All Surface Disposed First Third
Wastes
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 -1'8 Soft Hammer Wastes from the First Third and
Second Third Final Rules
2-30
2-33
2-38
2-42
2-43
2-45
2-47
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 .
2-52
2-54
2-56
2-58
2-60
2-63
IX
-------
LIST OF TABLES (continued)
Table 3-1
Table 3-237
Table 3-238
Capacity Analysis Tables for Each Waste Code
(Use Exhibit 3-1 Index)
Volume of Contaminated Soils Land Disposed
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 4-2 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
-------
APPENDIX J
ANALYSIS OF COMMERCIAL ALKALINE CHLORINATION/
CHEMICAL PRECIPITATION CAPACITY
-------
APPENDIX J
ANALYSIS OF COMMERCIAL ALKALINE CHLORINATION/CHEMICAL
PRECIPITATION CAPACITY
(all data in gallons per year)
To verify projected capacities reported in the TSDR Survey, EPA
contacted the facilities that anticipated in 1989 additional available
capacity for alkaline chlorination followed by chemical precipitation. Based
on the information provided by the facility contacts, EPA has determined that
four facilities (American Waste Processing LTD (ILD00716894), Envirite
Corporation (PAD004835146), Mill Services Inc Yukon Plant (PAD004835146), and
OSCO Treatment Systems Inc. (TND980515779)) did not come on-line as projected.
For two facilities (Envirite Corporation (PAD004835146) and Mill Services Inc.
(PAD059087072)), available capacity data are adjusted based on the additional
information provided by the facilities and by engineering judgement. For one
facility (Cyano Kern (MID09801192), the available capacity is updated based on
the information provided in the comment letter (Letter Number LD12-00110 dated
January 5, 1990) submitted by the facility. As a result of the facility
contacts and other information aide available during the comment period, 1989
available capacity data have been adjusted to reflect this additional
information as shown in Table 1.
-------
J-2 Appendix J
Table 1. Capacity Analysis For Alkaline Chlorinacion/Chemical Precipitation-
Total available capacity for 1989-90 (p. 791) - 51'8°6'oAO
Add capacity of Mill Service's gen. chem. precip. process (p.90)2 - + 2'^U'QQQ
Add additional capacity from comment letter L593 for Cyano Kern - + OOA nnn
Add additional capacity for USPCI, Uaynoka, OK*5 ' "*" nOO 000
Deduct capacity reported by American Waste Processing " " I''
Deduct capacity reported by Osco Treatment Systems " " 12
Deduct capacity reported by Envirite(expansion for 89-90) ' >
Deduct loss of capacity reported by Envirite for 1988 " ?
Deduct capacity reported by Mill Services Yukon Plant - - ^
79
Total available capacity ^^
Deduct required capacity for the previous rules " ' 11,000,000
Remaining capacity for Third Third vasces - 11,120,841
1 All page numbers refer to fi?mm,yr,cial Trtiyujnt/Recoverv Capacity Data Set. November
1989 Prepared for the Office of Solid Waste. Washington, D.C.: U.S. Environmental
Protection Agency.
2 One of the systems of this facility is categories as general chaaical precipitation. A
review of the schematics and survey indicated that this system has the capacity for alkaline
chlorination as well as chemical precipitation.
3 This com*enter stated that they have about 13.8 million gallons per year maximum
capacity at this facility. Of this, 12.8 million gallons per year is already reported in the
TSDR Survey The remainder is incorporated in the capacity analysis (p. 78).
4 Basis is provided in phone logs for the details of discussion with facility contacts.
5The available capacity is about 85% of annual maximum capacity (1,040,000 gallons). The
maximum capacity is calculated at the rate of 4,000 gallons per day for 260 days.
'This loss of capacity is due to mis-coding of the TSDR Survey information in the data
set. The actual available capacity of the facility is arrived as follows: The maximum annual
capacity for alkaline chlorination followed by chemical precipitation is 25X (4,260,000
gallons) of facilities maximum annual capacity (17,040,000 gallons). Only 25Z (based on annual
maximum capacity and utilization at the facility) of this capacity is available capacity for
alkaline chlorination and chemical precipitation. The loss of capacity (3,203,640 gallons) is
the difference of the available capacity reported in the data set (4,268,640 gallons) and
actual available capacity calculated (1,065,000 gallons) above.
-------
J-3
PHONE LOG FOR
FACILITY CONTACTS
Appendix J
Caller: Ravindra Sannareddy
Name of Contact: Craig Bruell
Phone Number: 405-697-3236
Title:
Location: USPCI, Waynoka (OKD065438376)
Date: April 24, 1990, 4.25 p.m.
Purpose of Call: Obtain the information on the permitted capacity for the
following process.
Alkaline Chlorination/Chemical Precipitation
Report on Discussion:
1. The maximum capacity of the process at this facility is waste
dependent. The maximum capacity varies from 2,000 gallons per day
to 6,000 gallons per day.
2. The current utilization of this process is about 10X to 20X of the
maximua capacity.
Any Follow up Planned:
-------
J-4
PHONE LOG FOR
FACILITY CONTACTS
Appendix J
Caller: Ravindra Sannareddy
Name of Contact: Joseph A Strosnik
Phone Number: 708-681-3999 (708-278-3999)
Title: Project Engineer
Location: American Waste Processing (ILD000716894)
Date: March 20, 1990, 11.00 a.m.
Purpose of Call: Obtain the information on the permitted capacity for the
following process.
Alkaline Chlorination/Chemical Precipitation
Report on Discussion:
1. The planned treatment process with a maximum annual capacity of 15
million gallons for 1988 never came on-line.
2. The facility has dropped the plans of expansion and, hence, the
capacity reported in the TSDR Survey will not be available in the
future.
Any Follow up Planned:
-------
J-5
PHONE LOG FOR
FACILITY CONTACTS
Appendix J
Caller: Ravindra Sannareddy
Name of Contact: Samuel J. Campagna
Phone Number: 615-381 1058
Title: Director of Environmental Services
Location: Osco Treatment Systems Inc. (TND980515779)
Date: April 20, 1990, 4.30 p.m.
Purpose of Call: Obtain the information on the permitted capacity for the
following processes.
Alkaline Chlorination/Chemical Precipitation
Report on Discussion:
1. The planned treatment process (maximum annual capacity of 1.3
million gallons in 1988) never came on-line.
2. The facility has plans to bring about 150,000 - 250,000 gallons
per year capacity by October 1990.
Any Follov up Planned:
-------
J-6 Appendix J
PHONE LOG FOR
FACILITY CONTACTS
Caller: Ravindra Sannareddy
Name of Contact: Curvin Snyder III
Phone Number: 717-846-1900
Title: Operation Manager
Location: Envirite Corporation (PAD010154045)
Date: April 24, 1990, 10.30 a.m.
Purpose of Call: Obtain the information on the permitted capacity for the
following process.
Alkaline Chlorination/Chemical Precipitation
Report on Discussion:
1. The planned treatment process (maximum annual capacity of 12
million gallons in 1989-90) never came on-line.
2. The facility operates in a batch process with a capacity of 50,000
to 65,000 gallons per day (i.e., 71,000 tons per year as reported
in TSDR Survey). Only 20-25Z of this capacity is available for
alkaline chlorination, even if there is demand for more capacity.
The remaining 75X of the capacity is utilized by chrome reduction
using ferric sulfate (up to 25Z of total capacity), neutralization
and other wastewater treatment processes available at the facility
(up to SOX).
3. It looks like there is a decline in the amount of liquid wastes
they are receiving at the facility.
Any Polloir up Planned:
-------
J-7
PHONE LOG FOR
FACILITY CONTACTS
Appendix J
Caller: Ravindra Sannareddy
Name of Contact: Gary Berman
Phone Number: 412-343-4900
Title:
Location: Mill Services Inc Yukon Plant (PAD059087072)
Date: April 25, 1990, 10.25 a.m.
Purpose of Call: Obtain the information on the permitted capacity for the
following process.
Alkaline Chlorination/Chemical Precipitation
Report on Discussion:
1. The State of Pennsylvania did not authorize the treatment of
cyanide wastes at this facility and, hence, the facility did not
expand for the above process as planned.
2. Mr. Berman said that they don't have any customers for the above
process; they will pursue their permit application if there is
demand.
Any Follow up Planned:
-------
APPENDIX K
Analysis of Commercial Sludge/Solid Combustion Capacity
-------
K-2
K.I. INTRODUCTION
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
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 regulatory offices (and
in a few cases from the incineration facilities) and has reevaluated available
sludge/solid combustion capacity based on these data. This Appendix, discusses
EPA's sludge/solid combustion capacity verification analysis.
EPA first compiled lists of commercial incineration facilities in each
EPA region. These lists contained more than 150 facilities identified from
the TSDR Capacity Data Set, commercially published literature, public comments
on the proposed Third Third rule and other sources. EPA contacted regional
and state environmental regulatory officials to determine the operating and
commercial status of each facility on the lists, and identify commercial
facilities that burn or plan to burn sludges and solids. Regional and state
contacts indicated that many of these facilities were planned commercial
incinerators at various stages of development. EPA found many of these
facilities to be non-commercial incinerators that burn wastes generated on-
site (on-site facilities) or off-site facilities under the same ownership
(company captive facilities) A few facilities were identified as hazardous
waste fuel burners, reportedly burning liquids only, or specialized material
recovery facilities units that are not truly commercial since they accept a
very limited variety of wastes. Permitting officials indicated that some
planned commercial incinerators appear to be inactive or abandoned.
Through contacts with the regional and state regulatory agencies, EPA
has verified 12 currently operating truly commercial hazardous waste
incineration facilities having sludge/solid capacity. Alchem-Tron is excluded
from this group since its operation will be delayed until 1991 while it awaits
a state permit. The following facilities have been omitted from the data set
since the proposed rule since they are not truly commercial hazardous waste
incinerators:
RFE Industries in New Jersey is a materials recovery facility that
does not accept wastes from the general public for incineration.
BDT, Incorporated in Clarence, New York is a small metals recovery
facility
Groce Laboratories in Greer, South Carolina operates several small
research units.
-------
K-3
Table K-l summarizes the revised commercial sludge/solid incineration
capacity estimates. This table provides the 1986 utilized capacity obtained
from the TSDR Capacity Data Set and used for the final rule. It also shows
the maximum capacity estimates reported in the TSDR Capacity Data and used for
the proposed rule; along with the revised maximum sludge/solid capacity
estimates used for the final rule. Table K-2 presents revisions to the
commercial sludge/solid reuse as fuel capacity data since the proposed rule.
The aggregated sludge/solid reuse as fuel capacity estimate includes all
estimates obtained from the TSDR Capacity Data Set, including CBI facilities.
Facilities presented individually on this table are discussed in Section K.4.
The remainder of this Appendix describes EPA's method of determining
maximum, or design capacity to burn sludges and solids at currently operating
and planned commercial incinerators that burn sludges and solids. It also
describes EPA's analysis of the three Ash Grove Cement Company facilities that
were identified as burning sludges and solids during the public comment
period, and updated information on several reuse as fuel facilities reported
in the TSDR Capacity Data Set. It includes the following sections:
Section K.2: General Methodology and Assumptions for Commercial
Incinerators: This section describes general methodology and
assumptions used to analyze sludge/solid incineration capacity
It discusses the type of capacity data generally obtained from
regional and state officials, and the methods used to estimate
annual maximum sludge/solid capacity from this data.
Section K.3: Individual Incineration Facility Analyses: This
section separately discusses EPA's analysis of each incineration
facility
Section K.4: Sludge/Solid Reuse as Fuel Analysis: This section
discusses EPA's analysis of sludge/solid reuse as fuel capacity at
Ash Grove Cement Company facilities. It also describes updates to
other reuse as fuel facilities reported in the TSDR Capacity Data
Set.
Section K.5: Planned Incineration Capacity Additions: This
section discusses the status and capacity of incineration units
that EPA expects to come on-line by the end of 1992. It also
lists planned additions reported in the TSDR Capacity Data Set for
1989 through 1992 that EPA believes will be delayed beyond 1992
Section K.6: Phone Logs: This section contains logs of each
conversation that provided data used EPA's sludge/solid combustion
capacity verification analysis. Calls are organized
chronologically for each EPA region. Calls to facilities are
logged at the end of this section.
-------
TABLE HI
SUMMARY OF COMMERCIAL SLUDaBSOUD INCINERATION CAPACITY THROUGH 1002
NAME
ALCHEM-TRON, MC.
CLEVELAND. OH
OHMOMB43*
ATTUV
COFFEEVHE. KB
KOOM1608026
APTIM (WESTtNOHOUSE)
TOELE.UT
CAUFORMA THERMAL TREATMENT
VBWON.CA
CHEMICAL WATTE MANAGEMENT
KETnCMAN mJLM. CA
CHEMICAL WASTE MANAGEMENT
ALMCT. .
UMMM2424
CHEMICAL WASTE MANAGEMENT (8CA)
CHCAaO.lt
JMOM72I2I
CHEMICAL WASTE MANAGEMENT
POUT ART HUH. TX
TKDOOOMM
ENKO
UAAACOPA.AZ
iMVMONMENTAL VCTEM8 CO.
ELDORADO. AR
AADOW74*I*2
FLOMDA FIRST
POLK COUNTY. FL
LAMD. MC.
CAt.VEHT.KY
KVDOW49M17
ROUJMS ENVIRONMENTAL SERVICES
BATON ROUOE. LA
LADOI03M127
ROLLMO ENVMONMENTAL SERVICES
noQEpom. NJ
NJD0433M739
ROU.MS ENVIRONMENTAL SERVICES
DEER PARK. TX
TX00MI4137*
UNIT
TYFB1
n
HK
m
RK
UK
FH
FH
FH
MflK
HX
RK
WRK
MRK
MHK
RK
RX
ttrn
RK
CM
CM
RK
RK
RK
RK
RK
RR
RR
MAY MAY DEC DEC DEC DEC
IftM MAXIMIMUM CAPACITY 1960 IWO IWO IMO IW1 IWt
UTILIZED FROMT80R MAXIMUM AVAH>BLE MAXIMUM AVAJLABLE MAXIMUM AVAEABLE
CAPACITY CAPACITY DATA SET CAPACTTV CAPACITY CAPACITY CAPACITY CAPACITY CAPACITY
(TONWVn) (TON8/YR) (TONWYR) (TONaTYR) (TONWVR) (TONWYR) (TONS/YR) (TONanrR)
0
0
0
0
0
CM
cat
cat
0
CM
CM
0
0
0
20.670
0
0
0
CM
CM
666
7.IOO
0
16.324
0
0
0
M.BOO
0
0
0
0
CM
CM
0
0
CM
CM
0
0
0
21.170
.000
0
0
CM
CM
2 MOO
10,000
0
41.122
42.160
0
0
0
0
0
0
0
1.MO
1.MO
t.MO
».36»
16.0*4
0
0
0
0
w.aoo
0
14.400
0
3.312
30.431
31.7*4
16.600
0
32.400
36.640
32.400
0
0
0
0
0
0
CM
CM
CM
2»,M*
CM
0
0
0
0
i*.oao
0
14,400
0
CM
CM
31.22O
6,480
0
17 07A
36.S4O
32.4OO
0
0
0
0
0
0
i.too
i.too
1.600
2».36»
1 6,O*4
126. 1OO
0
0
0
3*.*00
0
I4.4OO
0
3.312
30.43*
31.7*4
16.500
0
32.4OO
36.640
32.400
0
0
0
0
0
0
CBI
CM
CM
20.36*
CM
CM
0
0
0
I*.OM
0
14.400
0
CM
CM
31.220
(.400
0
17,078
36.«40
32.4OO
0
28.MO
27.0OO
30.800
0
0
1,900
1.6OO
i.too
29.3M
16.0*4
126.1OO
12.600
12,100
12,800
3».*OO
0
14.4OO
0
3.312
30.43*
31.7*4
16,680
0
32.400
36.840
32,400
0
28.600
27.000
30,800
0
0
CM
CM
CM
28.36*
CM
CM
12.6OO
12.600
12.600
10.030
0
14.400
0
CM
CM
31.220
6.480
0
17.078
36,840
32.400
0
DEC DEC
1002 1S02
MAXIMUM AVAILABLE
CAPACITY CAPACITY
(TON8/YR) (TONSfYR)
26.800
27,000
30,800
18,676
27.760
1.SOO
1.600
i.too
29.36*
16.0*4
126. 1OO
12.6OO
12.600
12.600
30.800
0
14.400
27.706
3.312
30,43*
31.764
I6.68O
10.400
32.400
36.840
32400
0
2t.*00
27,000
3O.800
1*.*76
27.760
CM
CBI
CBI
20.36*
CBI
CM
12.6OO
12,600
I2.6OO
10,030
0
14.400
27.706
CBI
CM
31.220
*.48O
10.400
17.076
36.840
32.400
0
K-A
-------
TABLE K-I
SUMMARY Of COMMERCIAL Si UDOEJSOtlD INCINERATION CAPACITY THROUOH IW2
NAME
MAY MAY DEC DEC DEC DEC OfcC DEC
1(66 MAXIMIMUM CAPACITY 10*0 I MO 10*0 I WO IWI 1001 1001 1002
UMT l/nUZED FROMTSOR MAXIMUM AVAILABLE MAXIMUM AVAILABLE MAXIMUM AVAILABLE MAXIMUM A V At ABIE
TYPBl CAPACITY CAPACITY DATA SET CAPACfTY CAPACITY CAPACITY CAPACITY CAPACITY CAPACITY CAPACITY CAPACITY
(TON8/YR) fTONSrVR) (TONB/YR) (TONS/YR) (TOMS/YR) (TONS/YR) (TONS/YR) (TONS/YH) (TONSfifH) (TONS/YH)
ROSS MCWERATION SERVICES CBI CM
ORAFTON.OH
ON004MI66W
RHONE -POULENC BASK CHEMICALS 8R 0
(FORMERLY STAUFFER CHEMICAL)
HOUSTON. TX
TXD00606M70
RHONE -POULEKC BASIC CHEMICALS BH 0
(FORMERLY STAUFFER CHEMICAL) SR 0
BATON nOUOE. LA
LAOOO*t61234
THERMALKEM FH 11.700
noCHHJLL.SC
SOD0444423M
IMTCI NKNOW 0
TOELE.OT
MUTE-TECH FB 0
KMBALL.NE
AOOREOATE CM 26.121
TOTAL (TONS/YEAR) 1 ,460
NOTES:
ItMttTyp*.:
M.bilraradUnH
FB-FkiWIntfBtd
CBI 16.200 CBI 10,200 CM I6.2OO CBI 18.200 CBI
000 66.320 66.320 66,320 66.320 66,320 66.320
000 60.147 60.147 60,147 60.147 60.147 60.147
000 106,266 106.266 106.266 106.266 106.266 106.266
17.626 16.427 6.637 16.427 6.637 18.427 6,637 16,427 6,637
0 0 0000 0 12,606 12,606
0 0 0000 0 4.6OO 4.600
36.406
234.37* 320.003 166.10* 671.636 304.641 706.736 618.741 606.660 616.546
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TABLE K-2
COMMERCIAL HAZARDOUS WASTE REUSE AS FUEL CAPACITY FOR SLUDGES AND SOLIDS
UNIT
TYPB1
NAME
AGGREGATE FROM TSDR CAPACTIY
DATA SET
ASH GROVE - CADENCE CK
LOUISVILLE. NE CK
NED007200A72
ASH GROVE - CHANUTE CK
CHANUTE. KS CK
KSO03 12033 18
ASH GROVE - FOREMAN CEMENT CK
FOREMAN. AH CK
ARDO8 161 2270
KOSMOS CEMENT COMPANY CK
(SOUTHDOWN PORTLAND)
LOUISVILLE. KY
KYD024111M1
SOUTHDOWN PORTLAND CEMENT CK
KNOXVILLE. TN
UNITED CEMENT COMPANY CK
ARTESIA. MS
MSO0770SM78
MAY MAY DEC
1080 1990 1990 1990
UTILIZED MAXIMUM AVAILABLE MAXIMUM
CAPACITY CAPACITY CAPACITY CAPACITY
(TON8/YR) (TONS/YR) (TONS/YH) (TONS/YR)
0 29.885 20.885 29.885
0 12.000 12,000 12.000
0 12.000 12.000 12.000
0 12.0OO 12.OOO 12.000
0 12.000 12.0OO 12.000
0 12.000 12.000 12.000
0 12.000 12.000 12.000
000 12.000
000 12.000
000 77.500
DEC
1990
AVAILABLE
CAPACITY
(TONS/YH)
29.885
12.000
12.0OO
12.000
12.000
12.000
12.000
12,000
12.000
77.500
DEC
1991
MAXIMUM
CAPACITY
(TONS/YR)
29.885
12,000
12.000
12.000
12,000
12,000
12.000
12.000
12.000
77,500
DEC
1991
AVAILABLE
CAPACITY
(TONS/YH)
29.885
12.000
12.000
12.000
12.000
12.000
12.000
12.000
12,000
77.500
DEC
1992
MAXIMUM
CAPACITY
(TONS/YR)
29.885
12.000
12.000
12.000
12.000
12.000
12.000
12.000
12.000
77.500
DEC
1902
AVAILABLE
CAPACITY
(TONS/YR)
29.885
12.000
12,000
12.000
12.000
12.000
I2.OOO
12.000
12.000
77.5OO
TOTAL (TONS/YEAR)
NOTE CK - CEMENT KILN
101.885
101,885
203,385
203.385
203.385
203.385
203,385
203.385
K-6
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K-7
K.2 GENERAL METHODOLOGY AND ASSUMPTIONS FOR COMMERCIAL INCINERATORS
EPA first contacted regional and state permitting agencies to obtain
both professional estimates of each facility's sludge/solid capacity and, if
applicable, the permitted sludge/solid capacity limit. EPA obtained permit
limits on either (1) mass feed rates for specific waste forms (e.g., sludges
and solids, containerized solids, aqueous wastes), (2) overall mass feed rates
to a particular unit or the facility, or (3) heat release or heat input limits
to a particular unit or facility. These limits came from draft or final
permits or from the permit application, as applicable in each case. EPA used
a slightly different method for estimating sludge/solid capacity in each of
these three cases.
When specific trial burn mass feed rates were obtained, EPA summed and
extrapolated the sludge and solid feed rates to estimate maximum sludge/solid
capacity If no other limit was specified (e.g., total feed to the facility),
EPA simply projected the total sludge/solid feed rate directly to an annual
estimate by multiplying the hourly feed by 7200 hours per year, the assumed
number of operating hours for hazardous waste incinerators. For example, if
the trial burn demonstrated 500 Ib/hour of containerized solids, 1000 Ib/hour
of bulk solids, 2000 Ib/hour sludges, and 800 Ib/hr energetic liquids, the
maximum annual sludge/solid capacity would be obtained as follows:
500 Ib/hr containerized solids
+ 1,000 Ib/hr bulk solids
+ 2,000 Ib/hr sludges
x 7,200 hr/yr
/ 2.OOP Ib/ton
12,600 tons/yr sludges and solids
If an overall limit was imposed in addition to the trial burn feed
rates, EPA apportioned the overall maximum capacity to individual waste forms
based on the percentage of sludges and solids specified in the trial burn
plan. For example if trial burns demonstrated 1500 Ib/hour of aqueous and
1500 Ib/hour solids, and the overall feed rate to the unit was limited to 2000
Ib/hour (or the equivalent) the maximum annual sludge/solid capacity would be
estimated as follows:
1,500 Ib/hr containerized solids
/ (1,500 Ib/hr solids + 1,500 Ib/hr liquids)
x 2,000 Ib/hr total feed limit
x 7,200 hr/yr
/ 2.000 Ib/ton
- 3,600 tons per year solids
If specific trial burn feed rates were not available, but some general
mass feed limit (e.g., total tons to unit per year); EPA relied on engineering
judgement to select the portion of the permit limit that could be practically
allocated to burning sludges and solids For rotary kilns in general, EPA
used 75 percent of the permit maximum to represent the maximum sludge/solid
capacity For fixed hearth kilns in general, EPA used 25 percent of the
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K-8
overall permit specification. While it is conceivable that any given facility
could burn more that these fractions under select conditions, it is unlikely
that all units could maintain a higher fraction of sludges and solids over an
entire operating year This judgement is based on the conclusion that certain
volumes of liquid wastes require incineration and will be burned at these
commercial facilities.
The following assumptions were used throughout analysis:
We assumed that commercial incinerators operate 7200 hours per
year (this corresponds to 365 days of planned 24 hour operation
with slightly more than 15 percent down time).
EPA. used a conversion factor of 2000 Ib/ton to convert feed rates
expressed in pounds to tons.
To convert between gallons and tons, EPA used a factor of 240
gallons per ton based on the density of waster.
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K-9
K.3. INDIVIDUAL INCINERATION FACILITY SLUDGE/SOLID CAPACITY ANALYSES
Chemical Waste Management (Trade Waste Incineration), Sauget, IL
Four units are currently operating at this facility according to EPA
regional and state contacts. Only two of these units were reported in the
TSDR survey response. The third unit has come on-line in the past two years,
is fully permitted, and is currently burning hazardous wastes. Trial burns
have been conducted and analyzed for the fourth unit, and it is currently
burning hazardous wastes under limited post-trial burn conditions pending
finalization of the permit which is expected within a few weeks.
Units 1, 2, and 3 are fixed-hearth incinerators rated at 16, 25, and 30
MBtu/hr, respectively. The only capacity estimates originally available from
region and state contacts were 2000 Ib/hr total waste feed estimates based
loosely on an assumed average waste heat value of 8000 Btu/lb and each units'
maximum thermal ratings. EPA used 25 percent of these overall estimates as
our maximum sludge/solid estimates based on engineering judgement for fixed-
hearth units. Extrapolating the resulting 500 Ib/hr method, EPA obtained a
maximum annual sludge/solid estimate of 1,800 tons/yr for each of these three
units.
The fourth unit at this facility is a potentially mobile rotary kiln
with a vertical secondary chamber rated at 50 MBtu/hr. EPA based our estimate
of this unit's sludge/solid capacity on actual trial burn feed rates. Since
no overall maximum limit is imposed by the permit, EPA simply extrapolated the
combined feed rate of sludges and solids to obtain an maximum annual
sludge/solid capacity of 29,358 tons/yr
Since permit limit data were not available for units 1, 2, and 3, EPA
contacted the facility directly The facility contact stated that each of
these units can burn about 500 pounds of solids per hour, 24 hours per day,
seven days per week; confirming our estimate for these units. The facility
contact indicated that the fourth unit can burn between 2,000 and 15,000
pounds of solids per hour, depending on the heating value of the waste, but
that 10,000 pounds per hour is a good estimate. Extrapolating this estimate
yields an annual capacity of 36,000 tons, almost 7000 tons more than the
estimate based on the trial burn data. EPA concluded that this difference was
not great enough to warrant revising the estimate based on trial burn data.
Chemical Waste Management (formerly SCA), Chicago, IL
This facility incorporates a 120 MBtu/hr rotary kiln with liquid
injection. According to the regional contact, the draft permit imposes
separate limits on hourly liquid and sludge/solid feed rates. Because the
estimate obtained by applying the standard method to the permitted
sludge/solid limit vastly exceeded other indicators of the facility's capacity
(i.e., the facility's size and capacities reported in the TSDR survey) EPA
deemed the permit limit estimate to be unreliable. Instead of using The
overall permit limits, EPA based our estimates on trial burns conducted in
July 1989. EPA extrapolated the highest demonstrated hourly solids feed rate
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K-10
from these runs to obtain a maximum annual sludge/solid capacity of 15,084
Because of these discrepancies, EPA contacted this facility to verify our
findings. The facility contact indicated that the permit limits the heat
release from the rotary kiln to 30 Mbtu/hr, and most sludges and solids
average between 6000 Btu/lb and 7000 Btu/lb. Extrapolating the average of
this range. EPA obtained an annual sludge/solid capacity estimate of 16,714.
This estimate was 11 percent greater than our estimate based on the trial burn
data.
Chemical Waste Management, Port Arthur, Texas
This facility, the latest addition to the nation's commercial
incineration system, incorporates a 150 Mbtu/hr rotary kiln. It is fully
permitted, operational, and is currently burning wastes under slightly
limiting post trial burn conditions pending analysis of trial buns completed
early this year However, a major obstacle jeopardizes uninterrupted future
operation of this facility It is depending on a no migration variance for
its underground injection well where it intends to dispose of its scrubber
water EPA has proposed granting the no migration variance, and a final
decision is expected within the next six months. EPA obtained a maximum
capacity estimate by apportioning the maximum permitted annual feed rates to
liquids, sludges, and solids based on demonstrated trial burn feed rates.
Using this approach, EPA estimates this facilities maximum annual sludge/solid
capacity to be 125,100 tons.
Environmental Systems Company (ENSCO), El Dorado, Arkansas
This facility incorporates one rotary kiln that burns primarily PCBs. A
second rotary kiln and a recently added mobile rotary kiln burn most of the
facility's sludge/solid RCRA wastes. Since it was added since 1987, the
mobile rotary kiln was not reported in the TSDR Capacity Data Set. Region and
state permit officials indicated that this facility's permit limits only the
heat release of the incinerator units -- mass feed rates are not directly
limited. The on-site state inspector at the facility estimated ranges of
hourly sludge/solid feed rates to both the main unit and the mobile unit based
on recent operating records. EPA extrapolated the average of these ranges to
obtain a maximum sludge/solid capacity of 39,600 tons per year for the fixed
rotary kiln and 14,400 tons per year for the mobile rotary kiln. These unit
capacities combine to a total facility sludge/solid capacity of 54,000
tons/yr Our estimate exceeds the maximum capacity reported in the TSDR
Capacity Data Set by 26840 tons/yr or 99 percent. This difference is
attributed to the addition of the mobile unit and a shift toward more sludges
and solids (relative to liquids) in recent years. The on-site inspector
confirmed that this shift has taken place.
LWD, Calvert City, Kentucky
Two rotary kilns -- rated at 30 and 37 Mbtu/hr -- are currently
operating under interim status at this facility The state has published its
intent to deny a final permit, but the denial is being appealed by LWD and the
facility is not expected to close in the foreseeable future. For unit one,
one set of maximum hourly feed rate limits are specified in the draft permit
-------
K-ll
as demonstrated in trial burns. No overall maximum feed rate limit is
imposed. EPA extrapolated these feed rates to obtain a maximum annual
sludge/solid capacity of 3,312 tons.
The draft permit specifies two different sets of operating condition
limits for unit 2, each with a different maximum feed rate for sludges and
solids. The amount of time spent operating under each condition is left to
the discretion of the facility, and no overall mass feed rate is imposed. EPA
assumed equal operating time under each set of conditions. Extrapolating
these hourly rates, EPA obtained a maximum annual sludge/solid capacity of
30,438 tons. These unit capacities summed to an overall facility sludge/solid
capacity of 33,750 tons/yr
Rollins Environmental Services, Baton Rouge, Louisiana
This facility's integrated system includes a rotary kiln with an after
burner and a Loddby liquids burner. The total heat release from the
incinerator complex is limited in the draft permit to 95.6 MBtu/hr. The draft
permit also explicitly limits hourly feed rates of wastewater, wastes fed to
the afterburner, and hazardous waste fed to the entire incinerator complex.
To estimate the maximum permitted sludge/solid feed rate, EPA deducted the
wastewater and afterburner feed limits from the total complex limit and
assumed that the remaining feed rate represented the maximum permitted
sludge/solid feed rate. Since specific, demonstrated, sludge/solid feed rates
were not available, EPA used 75 percent of the remaining capacity limit as our
sludge/solid capacity estimate. Using this method EPA obtained a maximum
sludge/solid capacity of 31,784 tons/yr. This estimate exceeds the maximum
capacity reported in the TSDR Capacity Data Set by 10,384 tons/yr or 49
percent. This difference is attributed primarily to a shift toward more
sludges and solids relative to liquids.
Rollins Environmental Services, Bridgeport, New Jersey
This facility incorporates a complex similar to that of Rollins' Baton
Rouge facility containing a rotary kiln, afterburner, and Loddby liquids
burner. This facility's final RCRA permit limits heat release from the rotary
kiln and Loddby burner to 35 and 90 MBtu/hr respectively. The permit also
limits hourly waste mass feed rates to the kiln, afterburner, Loddby, and the
entire incinerator system. Since the overall limit is less that the sum of
the individual limits, EPA apportioned the overall limit to the individual
system components based on the relative size of the individual component
limits EPA used 75 percent of the resulting net rotary kiln capacity to
obtain a maximum sludge/solid capacity estimate of 15,560 tons/yr
Rollins Environmental Services, Deer Park, Texas
This facility has two independent incinerator "trains" according to it's
final RCRA Permit. The first train consists of a rotary kiln (80 MBtu/hr
maximum rating), rotary reactor (36 Mbtu/Hr maximum rating), Loddby liquids
burner (100 MBtu/hr maximum rating), and afterburner. The second train (train
II) consists of a rotary kiln (120 MBtu/hr maximum rating), rotary reactor
(33.5 MBtu/hr maximum rating), and afterburner. Maximum overall hourly waste
-------
K-12
feed rates are specified in the permit for each unit of each train.
The TSDR Capacity Data Set reports only two units, the two rotary kilns,
both of which are reported to include liquid injection ports (these ports are
presumably the Loddby burner, although the permit only identifies one Loddby
Burner) This facility's final RCRA Permit limits heat input to these two
kilns to 120 and 80 MBtu/hr. It also limits waste feed rates to each unit.
Taking 75 percent of these waste feed limits and extrapolating, EPA obtained
maximum sludge/solid capacities of 32,400 and 35,640 tons/yr for these units.
These estimates are 8,722 tons/yr (21 percent) and 7,210 tons/yr (17 percent)
less than the maximum capacities reported in the TSDR Capacity Data Set. A
contact from Rollins indicated that these units typically burn between 50 and
75 percent sludges and solids, but could burn 100 percent solids for some
wastes. This contact suggested that the capacities reported in the survey
should still be accurate, but the estimate based on the permit limit coincides
more closely with permit limits and the percent sludges and solids suggested
by the contact.
Rollins' comment on the proposed Third Third rule indicated that EPA
omitted rotary reactor #2 from its capacity analysis; but did not mention
rotary reactor #1, which was also excluded from the analysis for the proposed
rule. A contact from Rollins confirmed that the second rotary reactor has not
been constructed. EPA estimated the existing rotary kiln's overall
sludge/solid capacity based on 75 percent of the permitted maximum, and 7200
operating hours per year (versus 75 percent and 8060 hours per year suggested
by Rollins' comment on the proposed Third Third rule). This units maximum
capacity was thus estimated at 32,400 tons/yr
The combined maximum sludge/solid capacity for the three units at this
facility is estimated to be 100,440 tons/yr. This estimate is 16,468 tons/yr
or 20 percent higher than the maximum capacity reported in the TSDR Capacity
Data Set. This difference is attributed to the addition of the rotary
reactor, but is offset by slightly lower estimates for the two rotary kilns.
Ross Incineration Services, Grafton, Ohio
This facility consists of a single unit for which the final RCRA permit
limits hourly liquid and sludge/solid feed rates. These limits may be raised
following successful trial burn demonstrations that are currently delayed
while Ross appeals certain permit conditions Taking 75X of this permit
limit, EPA estimates this facility's maximum sludge/solid capacity to be
16,200. If and when the planned trial burn is successfully conducted, this
facility's sludge/solid capacity could increase by 25 percent.
Rhone-Poulenc Basic Chemicals Company (formerly Stauffer Chemical Company),
Houston, Texas
This facility operates a sulfuric acid regeneration furnace that is
permitted as a hazardous waste incinerator. It is reported in the TSDR
Capacity Data Set as a liquids only incinerator rated at 205 MBtu/hr, but EPA
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K-13
has received information indicating that it can burn blended sludges1
According to this information, Rhone Poulenc, in cooperation with Calliet
Technologies, is able to burn slurried sludges, specifically K048-K052
petroleum refining wastes that have been physically separated. Rhone-Poulenc
claims that this facility and its facility in Baton Rouge, Louisiana have a
combined capacity of 300,000 tons per year for burning such sludges This
facility's permit limits the mass feed rate of hazardous wastes (excluding
spent sulfuric acid) to 360 Ib./min. Extrapolating this limit, EPA estimates
this facility's maximum capacity to be 77,760 tons/yr. Assuming that the unit
would continue to burn 25 percent liquids, EPA estimates this facility's
sludge capacity to be 58,320 tons/year. Because of the pretreatment required
for this facility to burn sludges, EPA expects this capacity to be fully
available within six months.
Rhone-Poulenc Basic Chemicals Company (formerly Stauffer Chemical Company),
Baton Rouge, Louisiana
This facility operates two sulfuric acid regeneration furnaces rated at
100 MBtu/hr and 180 MBtu/hr according to the TSDR Capacity Data Set. Like
Rhone-Poulenc's facility in Houston, Texas, this facility was reported in the
TSDR Survey as burning liquids only but is now planning to burn pre-processed
K048-K052 sludges. Both units are permitted as hazardous waste incinerators,
but this facility's permit does not limit mass feed rates. Moreover,
according to Louisiana state permitting officials, petroleum refining wastes
are manifested as recovery or reuse materials for this facility and would not
be subject to hazardous waste permit limits. To estimate this facilities
capacity, EPA divided the combined thermal rating of the two units by the
average heating value of K048-K052 as obtained from the National Survey of
Hazardous Waste Generators (4,489 Btu/lb). Extrapolating this hourly feed
rate over a year and again assuming the facility will burn 25 percent liquids
over the course of the year, EPA estimates this facility's maximum sludge
capacity to be 168,412 tons/year. All together, EPA estimates Rhone-Poulenc's
sludge capacity at the Houston, Texas, and Baton Rouge, Louisiana to be
226,732 tons/year. This estimate is about 73,000 tons/year less than the
estimate provided by Rhone-Poulenc (refer to previous paragraph). This
difference is attributed to estimation error and EPA's conclusion that despite
what is technically conceivable, facility's are likely to burn some liquids
for practical considerations (i.e., the types of wastes their customers are
likely to ask them to accept). Because of the pretreatment required for this
facility to burn sludges, EPA expects this capacity to be fully available
within six months.
ThermalKEM, Rock Hill, South Carolina
This fully permitted facility uses a fixed hearth incinerator The
permit does not limit mass feed rates explicitly, but does limit total heat
1 Klepeis , John E., and Scalliet, Robert M. (October, 1989). "Total
Treatment Service for Refinery Hazardous Wastes", Presented at the October 3.
1989 Meeting of the American Petroleum Institute: Solid Waste Program
Committee on Refinery Environmental Control.
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K-14
release to 42 Mbtu/hr. ThermalKEM's comment on the proposed Third Third rule
argued that EPA had underestimated this facilities sludge/solid capacity by a
factor of ten (EPA obtained its estimate of 17,528 tons/yr from the TSDR
Survey) EPA contacted ThermalKEM to clarify this comment. The facility
contact indicated that trial burns conducted since 1987 raised the maximum
heat release from 19 MBtu/hr to 42 Kbtu/hr; and that ThermalKEM has modified
their process to allow higher sludge/solid feed rates These modifications
include a ram feed system for charging containerized solids, a system for
transporting wastes from steel drums to fiber packs, and an oxygen enrichment
system for improving combustion, and improved air pollution control equipment.
The facility contact indicated that these modifications allowed the facility
to burn as much as 80 to 85 percent sludges and solids, and that ThermalKEM
typically burns wastes with heating values ranging from 5000 Btu/lb to 8000
Btu/lb. EPA concluded based on a technical considerations that this modified
unit could burn higher percentages of sludges and solids than would be
expected from a typical fixed hearth unit. Using 75 percent sludges and
solids as for rotary kilns, and the average of the range of heating values
provided by the facility contact; EPA estimated this facilities maximum annual
sludge/solid capacity to be 18,427 tons. This estimate is 5 percent higher
than the sludge/solid capacity reported the TSDR Capacity Data Set.
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K-15
K.4 SLUDGE/SOLID REUSE AS FUEL ANALYSIS
This section discusses EPA's analysis of sludge/solid reuse as fuel
capacity Section 4.1 provides details of EPA's analysis of Ash Grove
Cement's sludge/solid capacity Section 4.2 describes EPA's revisions to the
sludge/solid capacity estimates reported in the TSDR Capacity Data Set.
K.4.1 ANALYSIS OF ASH GROVE CEMENT'S SLUDGE/SOLID COMBUSTION CAPACITY
During the public comment period, EPA received a comment from Ash Grove
Cement Company and Cadence Chemical Resources, Incorporated describing a
recently patented process for burning containerized sludges and solids in
cement kilns. The system involves a network of licensed fuel blenders who
receive and package solid wastes suitable for reuse as fuel into standard six
gallon containers. These containers are then transported to one of the Ash
Grove facilities where they are charged to the cement kiln in mid-process
(either through a hole in the rotating body of the kiln or between the
stationary preheater or precalciner and the rotating section of the kiln).
This process has reportedly been incorporated by six cement kilns at three Ash
Grove facilities.
Before assuming that Ash Grove's recently patented technology should be
included in its capacity estimates, EPA reviewed the process, and contacted
EPA regional and state officials who have witnessed and/or are familiar with
the Ash Grove/Cadence process. EPA found no technical reason to doubt that
the process could work as claimed in Ash Grove's comment. State and regional
contacts confirmed that Ash Grove had implemented the technology on at least
four operating kilns at its facilities in Foreman, Arkansas; Louisville,
Nebraska; and Chanute, Kansas. State officials from Arkansas and Kansas have
evaluated the process and concluded that it is legitimate energy recovery. As
a result of these confirmations, EPA has included the sludge/solid combustion
capacity at Ash Grove's six operating modified kilns in it sludge/solid
combustion capacity estimates.
The Ash Grove/Cadence comment stated that Ash Grove's three facilities
currently possesses a combined sludge/solid capacity of 90,000 tons/year, but
they did not indicate how this number was obtained. EPA estimated each kiln's
sludge/solid capacity in the following manner:
6 Gallons per charge
x 1 Charge per kiln rotation
x 60 Kiln rotations per hour
x 8000 Hours per year
/ 240 Gallons/ton
12,000 Tons/year
Each charge was assumed to contain 6 gallons of sludge/solids as
specified in the process patent. One charge was assumed per rotation of the
kiln (as determined from the patent), and the kiln was assumed to operate 8000
hours per year (based on EPA's judgement of a normal operating year) Each
kiln was assumed to rotate at 60 revolutions per hour, the limit imposed by
the permit issued to the Foreman, Arkansas facility EPA's standard
-------
K-16
conversion factor of 240 gallons/ton is based on Che density of water and was
used for consistency with other analyses. Using this method for each of the
six kilns, EPA estimates Ash Grove's overall maximum sludge solid capacity to
be 72,000 tons/year
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K-17
K.4 2 UPDATING THE RAF SLUDGE/SOLID CAPACITY
EPA contacted EPA regional and state officials to verify the activities
of each RAF facility in the TSDR Capacity Data Set reported as having
sludge/solid capacity in either 1988 or 1989/90. In general capacity data was
unavailable, but in most cases EPA was able to determine whether the facility
was accepting hazardous wastes at this time. EPA did obtain updated data for
two cement companies.
United Cement, Artesia, Mississippi
This facility has been delayed by litigation regarding its state permit.
It has now cleared the courts, and is fully permitted to burn hazardous waste
fuels. Final feed system and truck-unloading area modifications are underway
This facility is permitted to burn up to approximately 155,000 tons of wastes
that exceed 8000 Btu/hr and contain up to 30 percent solids. Based on the
fraction of sludges and solids capacity reported in the TSDR Capacity Data Set
(50 percent liquids, 50 percent sludge/solids), EPA estimates this facility's
maximum practical sludge/solid capacity to be 77,500 tons/year EPA expects
this facility to complete modifications and begin burning wastes by the end of
1990.
Southdown Portland Cement Company
Two cement kilns owned by Southdown Portland Cement Company have
incorporated the Ash Grove/Cadence mid-process solid fuel charging system (one
kiln in Tennessee and one in Kentucky) . Both of these facilities are
reportedly operational and very close to final authorization. A third
Southdown kiln is currently under construction in Ohio. Since none of these
facilities is currently accepting wastes, EPA has not included them as
currently available capacity. EPA expects the Louisville, Kentucky, and
Knoxville, Tennessee facilities to be available by the end of 1990. Using the
same method described for Ash Grove, EPA estimates the combined sludge/solid
capacity of these two kilns to be 24,000 tons/year.
For the remainder of the reuse as fuel facilities, EPA obtained its
estimate sludge/solid capacity estimate from the TSDR Capacity Data Set.
Estimates of planned 1989/1990 capacity were used with the following omissions
resulting from regional and state updates:
Koppers Company in Mississippi no longer burns hazardous wastes.
Environmental Waste Resources, Waterbury Connecticut, is a fuel
blender but does not burn hazardous wastes
San Juan Cement, planned to close three of its four units by the
end of 1990
Ideal Cement Company, Saratoga, Arkansas, has been delayed to 1991
and will burn liquids only.
GSX, Pinewood, South Carolina, burns nonhazardous wastes only
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K-18
Lehigh Cement Company burns liquids only at its kilns in
Frederick, Maryland.
Ohio Lime, Incorporated of Millersville, Ohio, will not burn
hazardous wastes as planned due to local opposition.
Allied Chemical in Ironton, Ohio, will not burn hazardous waste
fuels in its planned industrial boiler
K.5 SLUDGE/SOLID COMBUSTION CAPACITY THROUGH 1992
EPA recognizes the uncertainties facing new commercial incinerators, but
through its discussions with regional and state officials has identified
several facilities that it expects will bring new sludge/solid capacity on-
line by the end of 1992. This section summarizes EPA's analysis of these
planned additions.
K.5.1 PLANNED ADDITIONS TO NATIONAL SLUDGE/SOLID INCINERATION CAPACITY IN 1991
While siting problems, local opposition, and permitting hurdles make it
difficult to predict the fate of planned hazardous waste incinerators, EPA has
identified four incineration facilities it expects to come on-line in 1991.
Their permits are either granted or imminent. Their status indicates that
construction, if necessary, could proceed quickly. Capacity estimates for
these facilities are based primarily on Part B permit applications. These
estimates were obtained using the same methods and assumptions as for the
currently operating facilities.
Environmental Systems Company. Maracop*, Arizona
According to Region IX contacts, this facility is one to six months away
from receiving its permit. This facility is likely to be brought on-line
quickly since it intends to incorporate three existing 33 MBtu/hr mobile
rotary kilns. Using 75 percent of the facilities design capacity, EPA
estimates this facility's sludge/solid incineration capacity to be 37,500
tons/year
Aptus, Coffeeville, Kansas
According to Region VII contacts this existing 62 MBtu/hr PCS
incinerator is about a year from receiving its operating permit and one and a
half years from burning RCRA wastes Using 75 percent of the sludge/solid
feed rate limit specified in the permit application, EPA estimates this
facilities sludge/solid incineration capacity to be 27,000 tons/year
Aptus, Tooele, Utah
Region VIII expects this facility to receive its final RCRA permit
sometime by the summer of 1990 Preliminary construction preparations for a
120 MBtu/hr rotary kiln are already underway Based on the trial burn plan
specified in Part B of the permit application, EPA estimates this facility's
maximum sludge/solid incineration capacity to be 30,600 tons/year
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K-19
Alchem-Tron (GSX), Cleveland, Ohro
This currently operational modified sludge drying bed was included in
the proposed rule, but EPA subsequently determined that it is not yet
accepting wastes because it is awaiting a state permit. EPA expects a final
permit decision from Ohio state officials this summer. Because this uni: is
only suitable for treating sludge and solids, EPA used 100 percent of its
permitted limit to obtain a maximum annual sludge/solid capacity of 28,800
tons/year
K.5.2 PLANNED ADDITIONS TO NATIONAL SLUDGE/SOLID INCINERATION CAPACITY IX 1992
The 1992 horizon is far less certain, though EPA included only those
facilities that appear at this time to have strong prospects according to
information provided by EPA regional and state officials. These facilities
are included because their permit applications are being actively processed,
and permits are expected by early next year.
Rollins Environmental Services, Bridgeport, New Jersey
Rollins intends to add a rotary kiln to its Bridgeport, New Jersey
facility by the end of 1992. This planned unit is included in the facility's
final RCRA permit. Based on the TSDR Capacity Data Set, EPA estimates this
unit's maximum sludge/solid capacity to be 10,400 tons/year.
California Thermal Treatment, Vernon, California
This facility has received a permit to build a 42 MBtu/hr rotary kiln.
The ultimate fate of this planned facility depends on the outcome of a permit
appeal against the facility Based on 75 percent of the maximum total
facility capacity, EPA estimates this facility's maximum sludge/solid capacity
to be 16,875 tons/year.
Waste-Tech, Kimball, Nebraska
This facility as received a permit from the state, and could begin
construction by the end of 1990. EPA expects this fluidized bed incinerator
to burn mostly liquids. Based on 25 percent of the total maximum feed rate,
EPA estimates this facility's maximum sludge/solid capacity to be 4,500
tons/year.
Chemical Waste Management, Kettleman Hills, California
Chemical Waste Management is currently addressing deficiencies in this
facility's permit application. This facility could receive its permit to
begin construction of its 50 MBtu/hr rotary kiln by the end of 1990. Based on
75 percent of the total capacity specified in the permit application, EPA
estimates this facility's sludge/solid capacity to be 27,750 tons/year
Florida First, Polk County. Florida
-------
K-20
According to a Region IV contact, Florida First is scheduled to receive
a construction permit for this facility in early 1991. Based on the trial
burn plan in Part B of the application, EPA estimates this facility's maximum
sludge/solid capacity to be 27,705 tons/year.
USPCI, Tooele, Utah
USPCI is currently addressing deficiencies in this facility's permit
application. This facility could receive its permit by early 1991, according
to a Region VIII contact. Based on the Part B trial burn plan, EPA estimates
this facility's sludge/solid capacity to be 12,595 tons/year
K.5.3 PLANNED ADDITIONS DELAYED UNTIL 1993
Through its discussions with regional and state officials, EPA has
identified several new facilities and additions to existing facilities that it
expects to begin operating after the beginning of 1993. The following
additions were reported in the TSDR Capacity Data Set as planned for 1989 to
1992, but are likely to be delayed until at least 1993:
Fort Barton Holdings Incorporated, Warwick, Rhode Island
Rollins Environmental Services, Baton Rouge, Louisiana (new unit)
Industrial Service Corporation (formerly Radium Petroleum
Company), Kansas City, Missouri
ThermalKEM, Rock Hill, South Carolina (new unit)
GSX Thermal Oxidation Corporation, Roebuck, South Carolina (new
unit)
Envirosafe Services of Texas, Devers, Texas
LWD, Calvert City, Kentucky (new units)
-------
K-21
K.6 PHONE LOGS
This section contains logs of each discussion with regional or state
officials that provided information used in this analysis. These calls are
grouped by EPA region, and ordered chronologically for each region. In many
cases, several calls were required to obtain the necessary information.
Supplemental information from state and regional contacts, including excerpts
from permits, are included at the end of regional sections. Calls to
facilities are presented separately at the end of this section. A list of
abreviations used in the phone logs is provided at the end of Section K.6
-------
K-22
REGION I
3/5/90 10:10 - Stephen Yee. (617} 573-9670 - left message.
3/6/90 9:45 - called Stephen Yee
1. Fort Barton Holdings, Warwick, RI
not built
being contested
currently conducting state hearing
Frank Battaglia is state contact 573-9603
permit not drafted
company appealing
capacity unknown
2 Environmental Waste Resources, Waterbury, CT
not an incinerator or RAF
sludge recovery (WWT)
no plans to change
3 Clean Harbors, Braintree, MA
no application submitted
application expected this summer
call Steve Dreezen, 292-5630
4. GE, Pittsfield, MA
PCB's only
no plans to go RCRA
5. Pfizer
on-site pyrolizer
TB scheduled for April
no problems anticipated
currently IS
may be public opposition
burns plant's pumpable sludges
2 RK units
4700 Ib/hr total (no physical form limits)
6. Polaroid, MA
currently on-site IS
will shut down: waste minimization and shipment off-site
call Gary Gosbee, 5740
closing within six months
burns unknown volumes believed liquids only
General Dynamics
proposed on-site RK
application expected this summer
being redesigned
capacity unknown
1993 +
-------
K-23
3/6/90 10:15 - Frank Battaglia (617) 675-9603 Busy
3/6/90 10:16 - Steve Dreezen (617) 292-5832
1. Clean Harbors, Braintree, MA
in process of siting
still far from permit
will need RCRA, TSCA and local permits
town strongly opposes
according to application a RK (40 ft long)
60 MBTu/hr max (50 nominal)
new unit at existing facility
many problems with site
1993+ if at all (doubtful)
2. GE, Pittsford
TSCA only
no planned changes
3 Polaroid, MA
will withdraw application
will close in six months
believed to be liquids only
volumes affected unknown
3/9/90 11:15 - Frank Battaglia, RI State Office
1. Fort Barton Holding, Warwick, RI
proposed greenfield
permit not issued, decision expected early summer
possible by end of 1992, 1993 or later more likely
call Mr. Terry Grey (401) 277-2797 for more details
capacity unknown
3/12/90 10:20 - Terry Grey. RI State Program (404) 277-2797
will return around 1:00
left message to call
3/12/90 11:40 - Terrv Grev (RI EPA) returned call
3/12/90 12:55 - Terry Grey. RI EPA. (401) 277-2797
1. Fort Barton Holding, Warwick, RI
permit hearing concluded
decision expected in May
may not be permitted
proposed 20 MBtu/hr RK
max throughout 30,000 tons/yr
plans to accept dioxins/furans
no PCBs/explosives
-------
if ac all, 1993+
3 '21 -90 10-35 - Stephen
left message
3 21/90 10--tO - Susan Green. CT. EPA
no longer at EPA
Transferred Co Jerry Sotolongo (617) 573-9680. Section Chief. CT RCRA
left: message
3.26.90 9:-o - George Dews. CT DOEnv. P. (203) 566-2264
In meeting, left message
3 2^ 90 1:25 - Jerry SotolonEa. CT State (617) 573-9680
1 Environmental Waste Resources
not burning sludges and solids
do blend fuels
burning would require state permits
call George Dews at CT EPA (203) 566-226*
3/28.90 10:15 - George Dews. CT DOEP. returned call
1 Environmental Waste resources, Waterbury
does not burn hazardous waste
fuel blender only
no cement kilns burn wastes in CT, closest is NY
3 29.90 1:20 - Jerry Sotolonga. CT State (,617) 573-9680
left message
-------
K-25
REGION II
3/5/90 10:20 - John Brogard (212) 264-8682
1. BDT call Marvin Frank (212) 264-9578
2. Rollins, Bridgeport, NJ
currently only 1 RK operating
permit (March 1989) covers additional unit replacement RRK
no dioxins/furans/PCBs
RRK being designed - sure thing
RRK will be on-line before 1992
Capacity for existing RK
RK 7000 Ib/hr total
Loddby 6875 Ib/hr total no breakout by physical from
AB 4800 Ib/hr total
3. GAF, Linden, NJ
very preliminary commercial incinerator
heavy opposition
passed siting commission
no application submitted
not possible by end of 1992
4. DuPont Chambers Works, Deepwater, NJ
application under review
50 percent commercial
will fax details on capacity
contact wants written request
hung up
3/5/90 1:50 - left message for John Brogard
3/6/90 10:30 - John Brogard I left fax # and message to call
3/9/90 9:20 - John Brogard (212) 264-8682
will send fax again since last one didn't come through
call John Scott, NJ DEP, (609) 292-9880, regarding Rollins,
Bridgeport
call Jim Dolen (518) 457-7269 (NY RCRA) or Jack Lavber (NY Air)
(518) 457-7454
1. University of Rochester, Rochester, NY
probably not RCRA
-------
K-26
2. RFE, NJ
nonhazardous
3 American Cyanamid, Bridgewater, NJ
exempt recycler
4 Blue Circle, Ravenna, NY
never heard of, ask state
5 CWM, Model City, NY
call Jim Dollen
6 Lehigh Cement, Cementon
call Jim Dollen
7 NJ siting commission, Millstone, NJ
never heard of
8 Envirocare, NJ
dead project
9 GE, Waterford, NY
PCS permitted
call Jim Dollen
10 Schenectachy Chemicals, NY
call Jim Dollen
11. BASF, Kearny, NJ
onsite
liquids only
constructed, permitted and operating
12. Pfizer, PR
call Cliff Ng, 9579
13 Phillips, ECG, NY
call Jim Dollen
14. Union Carbide
denied permit
on-site lab wastes only
small unit
15 DuPont, Deepwater, NJ
denied permit
will be redone
3/9/90 11:00 - John Scott (NJ PEP)
out till Monday
left message
-------
K-27
3/9/90 11:00 - Jim Pollen (NY RCRA Office) (518) 457-7269
of all existing facilities in NY, only GE, Waterford and Kodak.
Rochester burn sludges and solids
left list of facilities and described needs
he will call this afternoon
3/12/90 10:50 - John Scott (NJ PEP) returned call
3/12/90 10:55 - John Scott (6091 292-9880
1. Rollins, Bridgeport, NJ
multiple input ports
consists of RK
Loddby Burner (Liquids only)
After Burner (Wastewaters)
Loddby will be closed in near future
has received conceptual permit approval for proposed RR
RRK design is expected this month
current permit feed rate limits:
to RK - 7000 Ib/hr (could be all solids)
to Loddby - 6,875 Ib/hr (liquids only
to AB - 4,800 Ib/hr (liquids/gases)
estimated sludge/solid throughout is 1000 Ib/hr
total input limit: 15,575 Ib/hr
RKR could be up sometime in 1992
2. Call Jim Bridgewater on GAP, Linden, NJ
3. RFE burns nonhazardous wastes
4 Dupont, Deepwater, NJ
currently DuPont wastes only
has submitted application to become commercial
will probably modify existing RK system
call Anthony Fontana (same //) for more info
5 U . C . , NJ
has closed
6. NJ Siting Commission
Millstone Township Site unsuitable
State is looking for another site
may back off if DuPont goes commercial
no operator for site has been selected
call Susan Boyle, Assistant Director of Commission, for more info
(609) 292-1459
-------
K-28
3/12/90 1:20 - Jim Pollen (NY RCRA Program) (518) 457-7269
unavailable, left message
3/16/90 2:50 - John Scott. NJ PEP
1. Rollins, Bridgeport, NJ
max heat release from RK is 35 MBtu/hr; 90 MBtu/hr from Loddby
Air permit based on heat input limit
maximum total organic feed to RK, Loddby, and AB is 15,575 Ib/hr
1000 Ib/hr is estimated s/s throughput limit for proposed Rotary
Reactor
Part B allows 365 day/yr, 24 hours/day operation
no A, B, or C explosives or F024 permitted
estimated critical unit is positive displacement pump for
sludges/liquids up to 3000 Ib/hr
blending eliminates problems at low Btu/lb constituent limits
2. RFE, NJ
recovers precious metals by incineration
3. General Comments
not aware of any cement kilns burning hazardous fuels in NJ
contact Air office for more info on RAF exempt facilities: Joel
Leon (609) 984-3027
3/21/90 10:50 - Cliff Ng. NY RCRA (212) 264-9579
left message to call
3/22/90 9:00 - Clift Ne
1. San Juan Cement, PR
liquids only, primarily solvents
onsite and company capture wastes
possibly some commercial customers
not a TSD
not sure if units have closed
call Ton Moy @ 264-1785 (out till Monday)
call Carl Martinez (PR) (809) 767-8116
call Air Compliance Office, Kenneth Eng, 264-4711
2. Safety Kleen, RP
has been burning spent solvents for some time
thinks liquid only, not sure
-------
K-29
3/26/90 4:50 - Ton Mov. Region II. returned call
1. San Juan Cement, PR
Accept blended fuels from safety kleen
no storage permit
believe liquids only
no idea of capacity
2. Safety Kleen, PR
primarily a fuel blender
were planning to add unit
3/27/90 1:10 Richard Ho, returned call (Region II)
1. San Juan Cement, PR
3 kilns planning to close
not sure if already closed
4/23/90 9:45 Jim Pollen. NY RCRA (518) 457-7269
1. Chem Waste Management, Model City, NY
Preliminary application incomplete
Already a landfill
2 RKs rated at 50 mbtu/hr each
Could possibly be permitted in one year and constructed in one
year
2. Blue Circle Atlantic Cement, Ravena, NY
New York State requires permit for RAF
Has not responded to NOD
Not burning hazardous wastes
3. Lehigh Cement, NY
Demonstration permit has expired
Not currently burning
Had to report TB
May still be planning to burn
Call Sev Chetty at (518) 457-9254
4 Norlite, NY
May have stopped burning, failed TB
Has added new APCE and will try again
-------
K-30
UNITED STATCS IHVZUCWHWTAL FftOTXCTZOM AGtNCY, RSGJON II
&EPA
Gary Light
ICF Corp.
FROM
John N. Brogard, P.E.
MAXCOOi
QtfKl
U.S. EPA Region II/N«w York City
OATI
March 1990
MUMUM Of PAOU TO INCtUM TMtt COVtM SHtfT
INFORMATION POK SINOINO PACSIMILI MEtSAOBS
Ptnifax PX-100
FTS: 264-7613
(212) 264-7613
VUWICATM
MUM ft Ml
FTS: 264-2301
(212) 264-2301
»A01 i OF ? »AOM
X03/09/90 11:44 P.
-------
uune 13
TABLE 3.1-5
BURNER SUMMARY
*
Item tjuipmant NO.
No.
£542-6303-01
2.
4. -542-6307-01
6. 4542-6305-1,1
7. 4542-6403-01
9. 4542-6704-01
10. 4542-6702-01
I. 4542-6701-01
12. 4542-6707-01
13. 4542-6705-01
15. 4542-6706-01
16. 4545-6716-01
Otteriot ion
Liquid wasta spray
Location
Kiln
Thermal Liquid Clow Higher heating value Vi|(0!
Capacity Win. Max, Design Miri. H»x. Mm, i
MM etu/hr ib/hr Ib/hr 8tu/lb Btu/lB Btu/lb cj
900 3,600 2,000
0 8,000 0.8
PurpebU tludcje
Liquid waite
Hign freezer waste
.*l oil
Direct ourn
Heavy tludge wa?te
liquid waata apray
Liquid waata apray
Low NOx burner
Low NOx burner
Liquid watte
Fuel oil
Liquid watte
Fuel oi I
Kiln
Kiln
Kiln
KUn
KUn
Kiln
ABC weat
Ate Eatt
AK Ea*t
ASC tfett
AtC North West
ABC North u««t
ARC North EMt
ABC North Eaat
30
30
30
50
60
30
-
--
30
30
30
30
30
30
773
773
773
430
773
1,000
900
900
313
515
515
2S6
315
258
3,750
3,750
3,730
2,580
3,750
20,000
3,600
3,600
3,730
3,750
3,730
1,546
3.730
1,546
10,000
12,500
12,500
19,400
8,000
4,000
2,000
2,000
12,300
12,300
12,300
19,400
12,300
19,400
8,000
a, oco
8,000
NA
0
0
0
0
8,000
8,000
8,000
NA
8,000
NA
19,400
19,400
19,400
19,400
19,400
8,000
8,000
8,000
19,400
19,400
19,400
19,400
19,400
19,400
0,1
0.8
0.8
0,5
o.a
600
0.9
0.8
0.8
.0.8
0,8
O.J
0.8
0.5
Fluond«/fu«l Oil
ABC North
86
534 9,400 7,000 19,400 0.5
V-3.1-32
0928H 2360-005-605-5
-------
K-32
REGION III
3/5/90 1:15 - Gary Gross (215) 597-7940
1. Keystone Cement Co., Bath, PA
believes liquids only
call state offices
2. Medusa Cement, Wampum, PA
no information available
3. Pyrochem, Mason County. WV
application submitted (commercial)
_ currently dormant while plan is reevaluated
not before end of 1992
4 Westinghouse/Apts, Apple Grove, WV
no application submitted
probably canceled
5. Coplay Cement, Frederick, MD
no info call State coordinator
6. PPG no incinerator in PA
7 Zapata, on-site liquids only denied permit
8. Freeman, on-site liquids only denied permit
9 Union Carbide
U.C. wastes only
on-site S/S RK
33 MBTu/hr
2 years from permit
1992+
RAF facilities in general no data call state offices no changes since
beginning of 1989
3/6/90 10:40 - Patrick Anderson (PA) (215) 597-7937
replaced by Niel Swanson
call tomorrow
3/6/90 10:50 - John Humphries CMD/WV) (215) 597-0320
not in
try Dennis Zielinsku or Cynthia Burrow at state office
(215) 597-7546
3/21/90 10:55 - Patrick Anderson, PA State Coordinator
-------
K-33
replaced by Neil Swanson
call Mr Ron Lee tomorrow at (215) 597-3181
for Region III non-PA call John Humphries, Section Chief,
(215) 597-0320
Transferred to Gary Gross
call Ed Hammberbury at MD State Office (301) 631 3356
3/21/90 11:30 - Ed Hammerburg (301) 631-3356
left message to call
3/21/90 1:40 - Ed Hammerburg. MD DOEnv returned call
1. Lehigh Cement, Frederick, MD
has submitted state permit application
currently operating but not burning hazardous wastes
currently second tier priority: 8-10 months from decision
Jim Francis will call (301) 631-3343
2. Coplay Cement
never heard of
3/22/90 3:10 - Michael Martin. MD DOEnv (301) 631 3344
1. Lehigh Portland Cement, Frederick, MD
limited facility application submitted in 1988
specifies 20,000,000 gpy maximum liquids capacity
kilns have been operating for years
currently accept wastes from fuel blenders
thinks they've been burning hazardous waste fuels for years
no other cement kilns in MD burn hazardous wastes
3/26/90 1:4.5 - Mike Martin. MDE (301) 631-3344
1. Lehigh Cement, Frederick, MD
burn liquids only
began burning around end of 1986
burned 1.5 million gallons in 1988
burned close to 2 million gallons in 1989
Lehigh is the only cement kiln burning hazardous waste as fuel in
MD
-------
K-34
3/26/90 1:55 - Hon Lee, returned call
1. Medusa Cement, Wampum, PA
applying for storage permit
kilns already exist
no idea how much or what wastes burned
2. Keystone Cement, Bath, PA
burn liquid F003-F005 and some D001
permitted for storage
2 kilns operating (possibly 3)
Part B says maximum capacity is 19 mgpy
4/3/90 1:30 - Liz Michaels. Lehigh Portland Cement. Allentown. PA
(215) 776-2753)
won't provide information over phone
requires verification of my identity
-------
K-35
REGION IV
3/5/90 11:00 - Bettv Willis (404) 347-3433 out till Tuesday or Wednesday
Transferred to Evellvn Ponton (NC & SC)
1. Groce Labs, Greer, SC
no changes since beginning of 1989 (none planned)
no incinerator
2. GSX TOX, Roebuck (Abco, GSX)
1 unit operating - no liquids only since beginning of 1989
2nd unit on hold not before 1993
application in permit not drafted
3 ThermalKEM
a) permit under appeal for 1 unit which is operating under
interim status
42,000 BTU/hr
appealed by locals and ThermalKEM
no changes to operation since beginning of 1989
b) second unit (same as existing unit)
planned for 1992
will check on capacity
neither burns D/F/PCBs
4. GSX Pinewood
will check
5. SC Incinerator, Tyrell County, SC
will check
6. Owens Corning, SC
went non-hazardous
was liquid
7 Westinghouse closed - onsite unit
8 Century Furniture - onsite
Dupont, NC - on-site
will check on others from list (15)
Transferred to Chip Start, (responsible for KY and TN)
9 LWD, Calvert City
state missed deadline
has issued intent to deny permit for three IS incinerators
1 new unit 100 MBTu/hr"
will pursue more details
-------
K-36
10. LWD, Clay, KY
permitting efforts inactive
will check won't operate
11. CECOS, Louisville, KY
proposed new facility
state denied permit
won't happen
12. Pyrochem, Louisville, KY
won't happen
13 CWM. (SCA), Memphis, TN
major changes to design
will submit new application
NOD issued 3/89 no response
not before end of 1992
RK
14 IT (DOE), Oak Ridge, TN
permitted and operating
not commercial
munitions only
15. Aptus/Westinghouse
not commercial
not operating
closed 1983
16 DuPont, KY
on-site
liquids only
17 Kentucky Solite will check
cement kiln
18. M&T Chemicals
Ltd commercial
RK 18 MBTu/hr
small tin recovery only
19 Olin, Calvert City, KY (same as Brandenburg)
Ltd commercial, liquids only
131 gal/hr maximum
20. Pennwalt, Colt City, NY
liquids only
on-site
21. Rohm & Haas
proposed RK
Ltd commercial (Rohm & Haas wastes only)
after 1992
-------
K-37
22 Tennessee Eastman, Kingsport, TN
on-site
23 Velsicol Liquids only
call in morning for more info
AL/MS Lissie Ketcham
not available, call again
3/5/90 1:55 - GA/FL - Hugh Hazen
24 Florida First
proposed RK (commercial)
75 MBTu/hr
2nd round of NOD
No D/F/PCB
expect construction permit 1991 (1st, 4th)
possible by 1992
25. "State Officials" Taylor County, GA
very preliminary
public opposition
after 1992 at best
26. FL Env Reg. Commission, FL
has selected union county, FL
after 1992 at best
discussion only
27 Honeywell, Clearwater, FL
on-site liquids only
28. Mid Florida Mining, Lowell, FL
_ on-site liquids only (RAF)
considering non-hazardous solids
29 Olin, Norwest, FL
onsite only
liquids only
call John Griffin, FL (904) 488-0300
30. Resource Recovery of America, Miami, FL
fuel contaminated soils only
not for hazardous wastes
31. Oldover, Green Cove Springs, FL
liquids only
-------
K-38
3/6/90 11:25 - r404) 347-3433
left message for Evellyn Ponton
left message for Chip Stuart
left message for Hugh Hazen
Lissie Ketham not in left message
3/6/90 1:00 - (404) 347-3433
Evellyn Ponton not available
Chip Stuart not available
Lissie Ketcham not available
Reached Hugh Hazen
1. Florida First, Polk County, FL
Proposed greenfield, 75 MBtu/Hr RK
Capacity from application
Total capacity 38,640 tons/yr
Kiln Low Btu High Btu
Liq 3750 Ib/hr (8000 Btu/lb) 1500 Ib/hr (20,000 Btu/lb)
Sludge 6000 Ib/hr (8000 Btu/lb) 2400 Ib/hr (20,000 Btu/lb)
Bulk
Solids 10,400 (0 Btu/lb) 4200 Ib/hr (12,000 Btu/hr)
Contaminated
Solids 6000 Ib/hr (0 Btu/lb) 3000 Ib/hr (12,000 Btu/hr)
Secondary chamber
liquids to each of three nozzles
3000 Ib/hr (0 Btu/lb)
1200 Ib/hr (20,000 Btu/lb)
3/7/90 3:30 - Chip Stuart (404) 347-3433)
1. LWD, Calvert City, KY
Three existing units
unit 1, 30 MBtu/hr RX
unit 2, 37 MBtu/hr RK
unit 3, 100 MBtu/hr RK
two proposed units
unit 4. 100 MBtu/hr RK
unit 5, 100 MBtu/hr RK
call KY permit writer, Beth Antley for capacity details
^404) 347-7109
State office contacts:
KY Mohammed Aladdin, (502) 564-6716
TN Jackie Obeerah Baah, (615) 741-3424
2 LWD, Clay, KY
exists
-------
K-39
was municipal
won't ever operate
3 IT, Oak Ridge, TN
munitions only
4 Aptus/Westinghouse, Louisville, KY
closed 1983
5 Kentucky Solite, Brooks, KY
cement kiln
6. 01 in, Brandenbury, KY
no incinerator at Calvert City
company captive
liquids only
131 gal/hr total throughout
may be fraction commercial
7 Rohm & Haas, Louisville, KY
5 tons/hr permitted maximum (all forms)
company captive
8. Tennessee Eastman
on-site liquids and solids
two 100 MBtu/hr RKs
one 50 MBtu/hr LI
9 Velsicol, Memphis, TN
existing on-site (permitted)
liquids only
20 MBtu/hr
second unit never operated
Lissie Ketham unavailable
transferred to Evellvn Ponton
still checking on GSX, TOC, Roebuck, SC
still checking on ThermalKEM, Rockhill, SC
4:30 - Lissie Ketham still unavailable
3/8/90 1:45 - Evellvn Ponton, unavailable, left message
Chip Stuart
Tennessee Eastman exists and operates
company captive
burns sludges, solids and liquids
Lissie Ketham - unavailable
3/8/90 Beth Antlev (KY Permit Writer) (404) 347-3433
-------
K-40
LWD, Calvert City, KY
public notice of permit denial
two units operating
unit 3 is not allowed to operate
CWM, Memphis, TN
proposed greenfield facility
1993+ at best
3/9/90 10:10 - Evellyn.Ponton (404) 347-3433
1. GSX, Pinewood, SC
operating kiln
nonhazardous wastes only
2. DuPont, NC
denied permit
liquids only
on-site
3 DuPont, SC
currently operating
liquids only
on-site
4 GSX, TOG, Roebuck, SC
currently liquids only
RK proposed
permit not drafted, not active
1993+ at best
capacity unknown
5 ThermalKEM
still checking capacity
will call or fax data
3/9/90 11:40 - Lissie Ketham (404) 347-3433
not available, left message
3/9/90 12:15 - Beth Antley returned my call and left message to call
-------
K-41
3/9/90 1:00 - Beth Antlev (404) 347-7109
unavailable, left message Co call
3/9/90 1:20 - Beth Antlev returned call
1. LWD, Calvert City, KY
two units operating
second (and third) unit has two operating conditions specified
amount of time operating in condition I or II is at facility's
discretion, but must be reported
has faxed throughput limits for each condition
3/9/90 Lissie Ketham (Region IV) (404) 347-3433
1. United Cement Company
call Betty Willis
2. CWM, Emelle, AL
permit application submitted but rejected
application resubmitted
AL isn't permitting any new units
chances are good that Emelle won't happen
if at all, won't be until 1993+
3. Mississippi Thermal Treatment Corp.
no application submitted
call Jerry Banks at MS State Program for more info (601) 961-5171
4. DuPont, Axis, AL (not Mobile)
on-site liquids only
5. Akzo, AL
has been closed for some time
6. Kay-Fries, AL
was liquids only
closed sometime after, May 1988
7 Sony, AL
closed 8/16/88
8. USA Anniston Depot, AL
burned on-site munitions only
currently closed, may reopen
9 3 M Chemical, AL
currentLy generator only
either closed of operating exempt boiler
on-site wastes
10 Allied Chemical, Birmingham, AL
company captive batch incinerator
currently operating
-------
K-42
on-site wastes
11 Ciba Geigy, Mclntosh, AL
on-site corrective action wastes
entered system via 1985-86 permit modification
12. First Chemical
on-site
application submitted
construction to be completed in two years
13. M & M, Attalla, AL
exempt fuel blender
3/13/90 11:00 Evellvn Ponton (4041 347-3433
1. ThermalKEM, Rockhill, SC
liquid/sludge feed limit is 33 Ib/min
no solids limit specified
multiple hearth
2 . SC Incinerator
no info available
call David Wilson at SC State Office (803) 734-5200
3/13/90 11:10 David Wilson. SC State ProEram Office (803) 734-5200
unavailable, transferred to Shirley Fawcett
1. ThermalKEM
solids capacity not specified
concurred with 42,000 Btu
concurred with 33 Ib/min L/S
total throughout limit (L/S/S) is 2.625 tons/hr or assuming 85%
operating time, 19,500 tons/yr
no change since 1986 other than permit application for proposed
second identical unit which has been denied, is under appeal and
not likely by 1993
2. GSX, TOC, Roebuck, SC
still liquids only
requested permit for proposed RK.
state is generally opposed
1993+ is best guess
3. SC Incinerator, Tyrell County
no Tyrell County in SC
3/21/90 10:25 - Lissie Ketham (4041 347-3433
returns Thursday, left message
also left messages for Chip Stuart and Evellyn Ponton
-------
K-43
3/22/90 9:50 - Chip Stuart. Region IV. EPA, returned call
1 Kentucky Solite; Brooks, KY
no storage permit
call Mohamid Alloudin (502) 564-6716 (or Hanna Helm)
2. Kosmos Cement Co., Louisville, KY
has applied for storage permit
needs local permit
3 American Resource Recovery Corp., Memphis, TN
call Larry Fitchhorn, Region IV
Transferred to Larry Fitchhorn
1. American Resource Recovery Corp.
Transferred to Wayne Garfinkel
1. American Resource Recovery Corp.
Leo Romminowski is Project Coordinator
call Dale Osher (TN Permitting/Compliance) (615) 741 3424
facility has caused local uproar and may have changed
3/26/90 - Lissie Ketham. Region V (404) 347-3433
1. Allied Chemical, Fairfield, AL
Does accept wastes from off-site
burns wood preserving wastes K001, D004, D007, U051, and K087
not fully commercial
burns mostly on-site wastes
maximum capacity is 6 tons/day total
2. First Chemical
on-site wastes only
recently permitted
not yet constructed
will burn distillation bottoms and wastewaters
3. Koppers Company
on-site corrective action underway
was a wood treater
now closing SI
call Pat Anderson or Leo Romminowski
Transferred to Pat Anderson
1. Koppers
was burning K001 in boilers
was on-site only
fined $41,000 on 7/28/89
not currently burning any hazardous waste
3-2/6/90 - Mohammid Alloudin. KY State Permit Writer (502) 564-6716
-------
K-44
left message to call
3/27/90 1:45 - Mohammid Alloudin. KY State Permit Writer, returned call
1. Kentucky Solite
not restricted by waste form but believes liquids only burned
are permitted for storage
wastes pumped from blender, Environmental Conservation Systems
one aggregate kiln operating
4/20/90 11:50 Jerrv Banks. MS State RCRA, (601) 961-5171
1. United Cement Company, Artesia, MS
Litigation over
Air permit granted
Currently modifying injection system
Constructing truck unloading area for direct feed
Primarily liquids
Permit limits:
<30% solids
<86 gallons/minute
>8000 btu/lb
50% Hazardous fuel is more practical
2 Mississippi Thermal Treatment
Abandoned project
4/24/90 5:20 Glenn Mov. EPA
1. TherraalKEM
Operating under IS
Permit conditions appealed by TherraalKEM
Facility is rated at 42 Mbtu/hr
No overall or sludge/solid feed rate specified
Limit previously given was for lower chamber only
5/20/90 9:25 Richard Everhart. Jefferson County Air Pollution Control
officer, (502) 625-6000
1. Southdown Portland
Owns Kosmos Cement
Have local permits
Not yet burning
Will burn primarily clean solvents, xylene, thinners, and off-spec
oil
Believes liquids only
May burn tires
Have draft RCRA permit
No capacity limit
-------
K-45
UNITtD STATES ENVIRONMENTAL PROTECTION AGENCY, REGION IV
345 COURTLAJJD STR£iT, N.E.
ATLANTA, GA 3v>365
FACSIMLE TRANSMISSION SHEET
DATE: .j/y/yfl NO. OF PAGES (INCLUDE COVER SHEET)
/ /
TO: /d/U, °lv FAX
J 7
ADDRESS: (jw'* C,~h^ (//°T PHONE:
IF THE FOLLOWING MESSAGE IS RECEIVED POORLY, PLEASE CALL
IN OUR OFFICE AT FTS 257- 7/CJ ? OR COMMERCIAL (404) 347- 1 / C
SPECIAL NOTES OR INSTRUCTIONS
PLEASE NUMBER ALL PAGES
MACHINE TYPE FAX NUMBERS
HARRIS/3M FTS 257-5206
Modal 2225 COMM. (404) 347-5206
r/7 /TAn-^A
-------
13:29
0PM - REGION [
K-46
/-w£
,C lAMt
JLue
K/0
A-*+i't .i
CbiJ.lt} 3tT30
/{ 500
So AX? tp+c*+«i}
-------
34,25/96 39:33
j. S, E.p.fl. -
K-47
Urvtctd Ss»C4« Environmental Protection Agency, Region IV
Courtland Street, N.E.
Atlanta, GA. 30365
Facsi'ala Transmission 8htte
ct:
No. of Pages (Include Cover Sheet)
Fax Number i
tss :
Phon«: "Teal -
. che following mesaag* is receivad POORLY, please call (g\cvvv
- our office ac FTS 257- 34^3 or Commerical (404) 347-
icial Notts or Instructions
Number All Pages
me Type
1 2225
Pax Numbers
FTS 257-5205
Coma. (404) 347-5205
WASTK MANAGEMENT DIVISION
THE FAX, MAN,
AND NOTHING BUT
-------
V.At
K-48
SxaA
PART V - ZNdNZRAIXCN
Bcisting Unit
The Permittee shall maintain the facility in accordance with the
design plant and pacifications contained in the approved permit
application.
V.B. fEWUFWANCZ 9ZANDFVPD
The Permittee shall maintain the incinerator so that, whan
operated in accordance with the operating requireraants specified
in this permit, it will meat tha following performance standards.
V.B.I. Tha incinerator oust achiava a destruction removal efficiency
(EKE) of 99.99% for each principal organic hazardous constituent
(PCHC) designated in thia permit for each waste feed. DRE shall
be determined using tha method specified in R. 61-79. 264. 343 (a) .
v.B. 2. The Permittee most control hydrogen chloride (HC1) emissions,
such that the rate of enissions is no greater than the larger of
either 1.8 Xg/hr or 1% of the HC1 in the stack gas prior to
entering any pollution control equipment.
V.B. 3. The incinerator oust not emit partial late natter in excess of ISO
milligrams per dry standard cubic meter when collected for the
amount of oxygen in the stack gas in accordance with tha formula
specified in R. 61-79. 264. 343 (c) .
V.B. 4. Evidence that compliance with operating conditions specified in
permit conditions is insufficient to ensure compliance with the
above performance standarda may be "information" justifying
modification, revocation or reissuance of the permit 'pursuant to
R, 61-79. 270. 41.
v.c. LmnKncN or WASTES
The Permittee shall incinerate only those hazardous wastes
identified in the approved permit application and in accordance
with the terms of the approved permit application and this
psc&it.
V.C.I. The Permittee shall not Incinerate any hazardous waste containing
an Appendix VHI organic hazardous constituent of incinerability
index below 0.22 Xcal/gran.
v.c. 2. No waste or combination of wastes, as fed to the incinerator,
shall have a heating value greater than 42,000,000 Biu/hr. This
heating value should include solid, waste, liquid/sludge waste,
industrial gases and auxiliary fuel.
-------
V.C.3. ihe ash content of the *««te or combination of wastes as fad to
the incinerator shall be no greater than 29.9 weight
per cent.
v.c.4. ihe mwt*.^ halogen uuriteiit of the wast* or combination of wastes
as fad to the incinerator shall b« no greater than 27.2 weight
par oant.
V.c.5. Liquid/sludge feed rata to tha lower chamber measured as
specified in condition V.D.15., shall be no greater than 33
Ib/min.
V.c.6. Noninal flowrata of the waste industrial gasee to the lower
chamber, measured as specified in Condition V.D.15, shall not
exceed 100 cfm, or approximately 20% of the atomization air flow,
V.c.7. The Permittee shall test each batch of liquid/sludge and solid
feed, as fed to the incinerator, for the following metals:
antimony, arsenic, barium, beryllium, cadium, chromium, lead,
mercury, nickel, silver, thallium, and vanadium. Records shall
be made available to this Department upon Inspection or request.
A summary of metal concentrations for each quarter must be
forwarded to this Department within thirty (30) days after the
end of each quarter. Within 90 days after the end of one year of
tasting for vanadium, the Permittee shall submit to the State
Director a Risk Assessment for vanadium based on this data.
V.D. OFERATDIS CCWDTTICNS
The Permittee shall feed the wastes rteflcrifrert in Condition v.c.
to the incinerator only under the following conditions:
V.D.I. Combustion temperature of the lower chamber, measured as
specified in Condition V.D.15., shall hav« a set point of 2100 F,
and will be maintained above a minimum temperature of 1730 F.
This condition must be implemented within six (6) months after
the effective date of this permit.
V.D.2. Conbusticn temperature of the upper chamber measured as specified
in Condition V.D.15., shall be maintained at 2000 degrees F or
greater.
V.D.3. Combustion gas velocity indicator, measured as specified in
Condition V.D.15, shall be no greater than 99 psig, as measured
at the steam pressure to the scrubber ejector. The Permittee
shall install a continuous recorder for the steam pressure within
six (6) months after this permit is effective.
V.D.4. The duration of carton monoxide levels below 50 ppm, measured as
specified in Condition V.D.15, shall not be less than 32 minutes
per 60 minutes based on a rolling 30 second sampling time. This
condition must be implemented within six (6) months after the
effective date of this permit.
-------
K-50
SftRT IV - MBEAL EMISSION LIMITS
The total ccwbined waste feed rate to the lower chamber shall not introducs
the following metals as metals or metal compounds at rates higher than the
following rates.
Name of Maximum Allowable Feed race
Metal in pounds per hour
* Antimony 2.42
* Arsenic 0.99
Barium 10.0
Beryllium 0.0044
« Cadmium 11.98
*Chronium 26.3
«Lead 22.08
Mercury 0.6
SiIver 0.7
Thallium 1.3
N3 m»tals or metal ccropovnda exceeding the final specifications under 40 CFR
Part 266 shall be fed to the upper combustion chanber.
c ~'
-------
K-51
REGION V (312) 353-2000
3/5/90 2:35 IL. Juana Rojo. 996-0990
1. CVM, Sauget, IL
three units currently operating no change
TB for 4th unit was in 12/89
Air permitted granted with consent decree to upgrade all four
units
45 MBtu/hr RK with AB
tested for PCBs
tested for D/F
permit should be finalized by July/August 1990
planned for Superfund site wastes
Capacity (from TB conditions as permit)
Kiln
High energy fuel, 700 Ib/hr
Bulk solids 10,000 Ib/hr
Secondary chamber
Fuel 25,000 Ib/hr
44 MBtu max total
Call state (Rob Wedsin (217) 785-2891) returns Thursday
2. SCA, Chicago no change since beginning of 1989
3. Oglesby Cement no info available
4. Sun Chemical Corp., Bedford Park, IL
submitted application, permit drafted
company wastes only
much opposition
liquids and solids (all Sun plants)
schedule unknown, not built
Transferred - OH. Lisa Pierard (312) 353-4789
5. GSX, Cleveland, OH
permitted 1988
no changes since beginning of 1989 or planned
no D/F/PCB
four tons/hr permitted max
will fax data
6 Ross, Grafton, OH
permit being appealed by Ross
no change in capacity since 1989
no plans
-------
10.
11.
12.
K-52
Waste Tech, East Liverpool, OH
proposed commercial
permitted 1984 or 1985
appealed by state of WVA
undergoing design change
not by 1992 (1993+)
2 RK units (100 MBtu/hr each)
100,000 tons/yr biggest in country
foreign design
will fax data
Ohio Lime, Millersville, OH
RAF lime kiln
liquids only
withdrawing part B application for storage
Allied Chemical, Irontown, OH
generator only
no info
no application
could be RAF
CWM, OH (West Carrollton)
RAF
Liquids only
Ohio Tech, Nova, OH
application submitted
new, greenfield site
13 months + for permit
much opposition
1993+ at best
30 tons/hr max (application)
Thermaltron, Cleveland, OH
not RAF or incinerator
13 Sanatize Industries, Youngstown, OH
commercial
1993+
125 tons/hr maximum
14. PPG, Circleville, OH
new unit replacing old
on-site only
permitted and operational
liquids/sludges/solids
58 MBtu/hr
faxing capacity data
15 BP America Research, Warrensville, OH
on-site
-------
K-53
16 BP Chemicals, Lima OH
on-site
1^ Catalyst Resources, Oleria, OH
liquids only on-site
18 Lubrizol, Dainsville, OH
on-site
not yet permitted
19 RMI, Sodium
on-site D001 only - permitted
20 Lubrizol Wickliffe, OH
permitted
on-site
Transferred to IN. Hak Cho (312) 886-0988
21. Stauffer, Hammond, IN
modified industrial furnace
reactivated as incinerator
possibly commercial
draft permit scheduled 1991
1993+ on-line
22. ENSCO, Troy, IN
nothing submitted
dead project
23 Coplay Cement, Logansport, IN
storage permitted
trial burn approved
non-commercial
liquids only
24 BASF, Terre Haute, IN
very preliminary
not dead
1993+ at best
25 Amoco, Lake Charles
on-site S/S/L
fluidized bed
permitted Nov 1989
Transferred to MI, Lorna Jereza
26. Augusta Development, Lanawee County, MI
proposed
no application submitted
1993+
27 St. Mary's Peerless Cement Co , Detroit, MI
-------
K-54
scheduled for 1992 (on-line)
liquids only
28 Michigan Technology, Detroit, MI
no info
preliminary at best
29
Wayne Disposal is Augusta Development
30 Nortro/Petro Chem
no incinerator, tank treatment only
fuel blender, not burner
31. UpJohn
captive only
won't close
burns clean solvent and animal carcasses
32. DOW, Midland, MI
liquids only IS
on-site
changing over to RK
operating and permitted (recently)
1 "6 9s" RK for dioxins being built
construction to be complete 3/91
TB complete 9/91
final permit by 12/91
3/6/90 2:00 - Lisa Pierard
1 GSX, Cleveland
4 tons/hr permitted maximum sludges + solids combined
2 Waste Tech, Circleville, OH
greenfield facility
redesigning equipment
propose 2 RKs
each with: 100 MBtu/hr max
-100,000 tons/hr total
3 Allied Chemical, Ironton, OH
would take some time to track
4 PPG, Circleville, OH
58 MBtu/hr
will fax data on GSX, Wastetech + PPG
Wen Huang not available
Lorna Jereza, in training, left message
Jauna Rojo, in training, left message
3/6/90 4:00 - Amy Dragovich from Region V called and left message
3/6/90 4:30 - Amy Dragovich (217) 782-6762 no answer
-------
K-55
3/6/90 5:05 - Amv Dragovich (IL State)
CWM, Sauget was denied permit
has appealed
no details available
3/7/90 3:45 - Jana Roio out till Friday
3/8/90 2:05 - Rob Watsin (IL State) (217) 785-2891
will check on capacities for SCA, Chicago and CWM, Sauget
Sun Chemical
permit application under review
new facility
company capture liquids and solids
schedule unknown
call back around 3:30
3/8/90 2:15 - Lisa Pierard (312) 353-4789
call Thelma Codina, permit writer for:
GSX, Cleveland, OH
Waste Tech, East Liverpool, OH
Ross, Grafton, OH
3/8/90 2:30 - Hak Cho (312) 886-0988
not available, left message
-------
K-56
3/8/90 5:00 - Rob Watsin (IL State)
From Sara CAP Report:
Liquids Capacity Solid Capacity
TWI (CWM) Sauget (tons/yr) (tons/vr)
1987 17,472 8,736
1989 17,472 8,736
1995 32,340 71,400
2009 32,340 71,400
Liquids Capacity Solid Capacity
CWM (SCA) Chicago (tons/vr) (tons/vr)
1987 25,998 or 43,470 12,999 or 21,735
1989 25,998 or 43,470 12,999 or 21,735
1995 25,998 or 58,338 12,999 or 84,399
2009 25,998 or 58,338 12,999 or 84,399
TWI:
Unit //I 16 MBtu/yr
Unit #2 18 MBtu/hr
Unit #3 18 MBTu/hr
Unit #4 RK with unknown thermal rating
Call Hope Wright (same #) for capacity numbers from trial burn
report
call Jim Cobb (Air Pollution Group) for status of TWI unit //4
Mr Watsin is not willing to look up Ib/hr specifications from
applications
3/8/90 5:20 - Thelma Codina (312) 886-6181
GSX, Cleveland
sludges and solids only
modified drying bed with vapor burner
permitted maximum is 4 tons/hr
Ross, Grafton, OH
does not burn dioxins
3/9/90 11:50 - Wen Huang (312) 353-2000 (886-6191)
call Thelma Codina on Waste Tech, OH
Ohio Tech, Nova, OH
sludge/solid capacity not in application
62-65 MBtu/hr proposed
will call me back
-------
K-57
3/9/90 3:40 - Thelma Codina (312) 886-6181
1. GSX
slightly limited in waste codes allowed
maximum permitted capacity for combined sludges and solids is 4
tons/hr (no liquids accepted)
2 Ross, Grafton, OH
maximum permitted limit for combined sludges and solids is 6000
Ib/hr
upon successful TB, max sludge solid limit will be increased to
7500 Ib/hr
maximum liquid feed rate (all ports combined) 22,190 Ib/hr
upon successful TB, max liquid rate will be increased to 25,190
Ib/hr
second unit planned, no application submitted
3/12/90 10:25 - Thelma Codina (Region V) (312) 886-6181
1. Waste Tech, East Liverpool, OH
no TB yet
total permitted maximum is 22,000 Ib/hr
estimated as 50 percent solid, 36 percent liquid, 14 percent
sludge
permit is close to expiring
call Bob Babik, OH EPA (614) 644-2917
3/12/90 Jauna Roio. Region V Office (312) 886-0990
1. SCA (CWM), Chicago
Permitted feed limits for single existing unit:
(design capacity)
liquids 15,000 Ib/hr
sludges/solids 24,000 Ib/hr
no annual limit
just submitted new Part B for proposed 130 MBtu/hr RK
currently burn liquid PCB's in secondary chamber
permit was denied because of storage practices
will FAX TB feed rate data
3/13/90 1:40 - Jauna Roio (312) 886-0990
left message requesting CWM, Sauget capacity figures
3/15/90 8:45 - Jim Cobb, Region V State Office
1. CWM (SCA) Chicago
from 1983 Air Permit, (RCRA permit held up)
thermal rating more limited than throughout limit, consequently
high Btu/lb liquids more limited
call Harry Chapel (217) 782-6760 on IL CAP
-------
2.
K-58
total throughout estimated at 12,000 Ib/hr
storage capacity is not a problem
call Rob Watsin in Land Division
For existing unit:
120 MBtu/hr max heat release total
30 MBtu/hr non-liquids to kiln
3 MBtu/hr contained solids changed
90 MBtu/hr after burner limit
CWM (TWI) Sarget, IL
Unit #1
14 MBtu/hr max, 2000 Ib/hr
fixed hearth with secondary chamber
must burn some liquids to burnt ash
Unit
Unit #3
Unit #4
16 MBtu/hr, 2000 Ib/hr
very similar to Unit #1
burns liquids in secondary chamber
State requires and reports feed rates in an annual report
Identical to #2
currently accepting wastes
50 MBtu/hr RX with vertical secondary chamber (kiln 25
MBtu/hr, secondary chamber 30 MBtu/hr liquids)
35 ft long, 7 ft inside diameter
prototype "mobile" unit
many input ports
from TB plan:
To kiln: Aqueous wastes
Fuel oil
Sludges
drummed solids
bulk solids
Feed to secondary chamber:
waste fuel
fuel oil
666 Ib/hr
529 Ib/hr
657 Ib/hr
2,958 Ib/hr
4,540 Ib/hr
1,103 Ib/hr
455 Ib/hr
storage not a problem
not planning to burn dixons and furans
specified feed rates are simultaneous
no overall throughput maximum specified on Part B application
3/19/90 12:50
Jim Cobb. IL State Program
1. CWM (TWI), Sauget, IL
feed rates given for TWI units 1, 2, and 3 (2000 Ib/hr) are
estimates of maximum practical throughput based on general waste
Btu value (8000 Btu/lb) , and maximum thermal ratings
-------
K-59
real chemical wastes typically have Btu/lb' greater than 8000
3rd unit is permitted and has been on-line for about 2 years
feed rate estimates for unit 4 are based on TB which has yet to be
approved
3/21/90 11:45 - Lisa Pierard. Region IV (312) 352-4789
1. Allied Chemical, Ironton, OH
closing tank and drum storage area
not sure if closing burner
call Mike Mochelle, OH State Inspector
2. Ohio Lime
not going to happen
company yielded to public opposition
3/21/90 12:00 - Mike Mochelle (614) 385-8501
returns from vacation on Monday
no one else can help
3/21/190 2:10 Hak Cho. Region V EPA (IN)
1. Coplay Cement, Logansport, IN
industrial furnace
2. Stauffer Chemical, Hammond, IN
call Date Beel or Elane Greg at IN RCRA program (317) 232-8855)
call Gary Victorine (886-1479), EPA Permit Writer for IN
for facilities in IL, call George Hamper, IL Section Chief (886-
0987)
3/21/90 2:15 - Dale Beel. IN RCRA (317) 232-8855
out today, left message
Elaine Greg also out today
-------
K-60
3/21/90 2:20 - Gary Victorine. IN Permit Writer (312) 886-1479
1. Stauffer Chemical, Hammond, IN
still operating under RAF exemption
sulfuric acid regeneration facility
in process of obtaining RCRA permit but no physical changes
3/22/90 3:25 - Shamela Sherry Region V IN (317) 232-8852
1. Coplay Cement
burns solvents only
can burn sludges (if injectable)
no storage area for sludges
2 kilns operating
no permit for kilns
operate 2 blending tanks
2 storage tanks permitted last year
TB conducted in 1986
2. Lone Star Cement
has storage permit
burns liquids only
will look into capacities
3/26/90 9:30 Elaine GreE. IN DO Env Mgmt (317) 232-8866
1. Coplay Cement, Logansport, IN
obtains fuels from PatChem Fuels
filters fuel as unloaded and drops resulting "bags" of
sludge/solids into clinker cooler
has storage permit
is not allowed to accept sludge/solids, wastes must be pumpable
total waste feed rate is limited to 1800 gallons/hr (2 kilns
combined)
only sludge/solids burned are those removed from "liquid" fuels
2 Lone Star Cement, Green Castle, IN
Systech is fuel handler
burns sludge/solid filter cake (from filtering liquid fuels) in
"injection cannon"
currently IS storage
can't accept sludge/solids from off-site, only burns sludge/solid
removed from liquids
1 kiln has capacity to burn 3000 gallons/hr
no state permit but "Approval Letter"
3. Stauffer Chemical
call Mitch Mosner, 232-3221
-------
K-61
3/26/90 1:35 - Mich Moser. Ohio EPA, (317) 232-3221
1. Stauffer Chemical, Hammond, IN
plan to submit Part B for incineration
are currently operating as RAF
do burn sludges
capacity unknown
3/27/90 9:50 - Thelma Codinas. Region V (312) 886-6181
1 GSX, Alchem-Tron, Cleveland, OH
not currently operating
awaiting trial burn
awaiting state permit
state recently authorized
call Bob Babik (614) 644-2917
3/27/90 10:00 - Bob Babik. OH State RCRA
1. GSX, AlchemTron, Cleveland, OH
permit being reviewed by board
unit is constructed
call Ed Lim at (614) 644-2974
3/27/90 4:05 - Ed Lim. OH EPA (614) 644-2974
1. GSX, Alchem-Tron, Cleveland, OH
facility is constructed
permit expected in 1991
had been sludge drying pits
2 Southwest Portland, Dayton, OH
burns hazardous liquids as fuel
maybe some sludges
3 General Portland (Lafarge), Paulding, OH
burns hazardous fuels
believes liquids only
4/5/90 12:25 Juana Rojo. 312-886-0990
1. CWM, Chicago, IL
Permit limits: 15,000 Ib/hr liquids
24,000 Ib/hr sludges & solids
May include PCB capacity
Conducted trial burn in 1989
Will fax data
-------
K-62
4/5/90 4:45 Thelma Codina. returned call
1 Ross Incineration, Grafton, OH
Lower pretrial burn limits currently in effect (indefinitely)
TB was completed at higher rates
Ross is appealing permit conditions
4/24/90 4:00 Larry Estep. IL State RCRA permit worker (217) 782-9882
U075 and U121 prohibited from CWM, Sauget
SCA has been denied permit but can burn U075 and U121 under
interim status during appeal
4/26/90 2:00 Lori Stevenson. OH EPA (614) 385-8501
1. Allied Chemical, Ironton, OH
Undergoing complete closure of last TSD unit
-------
K-63
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, REGION V
/* t*r>A 230 South Durborn Strut
Otr/A CHICAGO IL 60604
fUA$t mtuf in §m ex /** o*t r
703-'^.^
MACHINE KR:
3 - ^3^ -**'
7^0
VERIFICATION NR: ""
ROM
L(5
-pi
353-
- 13
P I2> - OK'
, o
c -h
9AH
NUM«M o» p*AOtt TO majuDf TH« COVM cntrr
number tff
INFORMATION FOR SENDING FACSIMILE MESSAGES
VlfUnCATION
NUMMft
PANAFAX PX-100
J[EROX AOO
PTS: 886-9096Uuto)
COMB: ( 31 2) 886-9096
PTS:
Coma: (312)886-3096
FTS: 886-3096
COM: (312)886-3096
FTS: 886-3096
COM: (312)886-3096
PACE
OF
PACES
-------
K-64
Modification of me RC*A Permit Issued to PPG ! ndust r-es . - Ore /cvj lit
Inc., ID SO. OHO Qui 30: 639.
^^^^^^BM^^n^^^^^
The U.S. PA has determined that so^e of Attachment I Permit Conditions
Attac^~ert ii Waste Analysis Plan should he revised, clarified and/or a
m orcer to incorporate tne results of tne trial bur- submitted by P?G
Industries on ".ay 5. 1988. the following table Msts the permit conaiti
and waste analysis pia- that have been changed and the changes and/or a
which h^ve been made, words or phrases that have been added or revised
l i n^a, and words or phrajes that have been deleted are lined out.
Condition Addition
C,23.(^ "...shall not exceed 100 ppn by dry volume basis p- ^
SO-T.i'-ute ting weigngd rolling average anc shell j e^
rror, i to red. . .
Change
C.23.(b)(i) "Tne total feed rate,
waste fees ?«%e
thermal load to the. incinerator
4s J4R4ted to the f««§e
te §8.d
(3
shall De 9re&t^an 3 x 106 6TU/hr ar.d shall not
_
exceed 5 ylD BTu/nr on 10-minute tine average"
C.23.(b) . I i i i ) "The feed rate of gaseous
4A^«44A§ waste feed a«4
auxiliary fuel to the incinerator must be monitored.,.,"
C.23.(b)(iv) "..., whichever is greater lesser;"
C.23.(b)(vi) "... the rotary kiln shall «9t neither
exceed i-,999 6^.600T pounds per hour
424 eperat4fl§ «SWP a*er«8e) no*- 500 pounds
per charging cycle;"
C.23(b)(vii) "...may not exceed 200 lb per hr.
(3 »peFat4fl9 nea^ average^; and"
C .23 .(b)( vi 1 1 i) "...shall not contain any chemical
ee«st4t«e*ts constituent listed in 40 CFR
Part 261, Appendix VIII, which *«*e has a heat
of combustion lower tnan that of
carbon tetrachloride.
-------
K-65
AdditiQft/Chjnge
C . 2 3 . ( c ) "The temperature of Mln outlet gas shall be maintained
it 185^gr"br O'-eaieT] Tne temperature of the combustion
gas in the secondary combustion chamber,
prior to the seeeffda^y «4f
red rculating Hue gas injection, shall be
maintained at' a
(1799) ef i2942g (22992F), s«b4.et
te the festiUs ef the tf4a* b«f«s
1600°P or greater. if the tfa4* &B^« fit 92?2C
" the
e. 4
The temperature of tne combustion gas in the secondary
combustion cnamber j«*t prior to the
secemafy a4f reci rculating flue gas Injection shall
be monitored., 77"
Change
C.23.(d) "..., shall not exceed 31,999 27.000 standard cubic
feet per minute... ."
%
C.23.(e) ' "...must be greater than «Hfee (3) seven (7) per cent
by dry volume basis ...."
C.23.(g) "...shall be no less than 7.0 6.5 . "
Revision
C.23.(i) ' "The feed rates of lead, chrome and mercury shall not
eTceed 320 Ib /nr, 170 Ib/hr and 61b/hr, respectively."
C.23.(» Within six (6) months from the issuance of this
Permit modification, the Permittee shall submit to
the Regional Administrator a written implementation
plan for control of other toxic metals (antimony,
barium, silver, thallium, arsenic, cadmium and
berryllium) and hydrogen' chloride emission from the
incinerator. The implementation plan shall Include
all necessary steps the Permittee will take to comply
with the then-effective emission limits specified in
the U.S. EPA "Draft Guidance on Toxic Metals and
Hydrogen Chloride Controls for Hazardous Waste Incinerators
dated June 9, 1988, within one year from the Issuance
of this permit modification.
-------
C.20 Inspections. K"66
The Incinerator and associated equipment shall be Inspected in accordance
with the Inspection plan (permit attachment IV) and 40 CFR 264.347.
C.21. Inspection Records.
The Incinerator monitoring and inspection data must be recorded and the
records foist be placed in the operating log in accordance with 40 CFR
264.347(d).
C.22. Incinerator Closure.
The Incinerator 1s to be closed in accordance with 40 CFR 264.351. The
Incinerator closure is detailed 1n the closure plan (permit attachment
VI).
C.23. General Operating Require/rents for Incineration System.
(a) The carbon monoxide (CO) level in the flue gas leaving the electrostatic
precipitator shall not exceed 100 ppm by dry volume basis and shall be
monitored and recorded on a continuous basis.
(b) The waste feed operating and monitoring requirements are:
(1) The total feed rate, including the waste feed rate and auxiliary
fuel to the incinerator, is limited to the range of 34.8 million
Btu/hr to 58.0 million Btu/hr heat input (3 operating hour average);
(11) The feed rate of pumpable materials, including waste feed and
auxiliary fuel , to the Incinerator must be monitored and recorded
on a continuous basis;
(111) The feed rate of gaseous materials, including waste feed and
auxiliary fuel , to the incinerator must be monitored and record-
ed on a continuous basis;
-------
~~ K-67
(1v) The feed rate of nonpumpable material s,Including waste feed and
auxiliary fuel, to the Incinerator must be monitored and logged
on a periodic basis; not to exceed the charging cycle or fifteen
(15) minutes, whichever 1s greater;
(v) Only gaseous and aqueous liquids materials may be Injected into
the secondary combustion chamber;
(vi) The solid waste feed to the rotary Uln shall not exceed 6,000
pounds per hour (24 operating hour average);
(vii) Based upon the waste analysis plan, the total chlorine content of
the materials fed to the Incinerator (Including both the rotary
/
kiln section and the secondary combustion chamber) may not exceed
200 Ib per nr. (3 operating hour average); and
(v111) Based upon the waste analysis plan, tht waste feed shall not
contain any chemical constituents listed 1n 40 CFR Part 261,
Appendix VIII, which have a heat combustion lower than trlchloro-
monof1ouromethane.
(c) The temperature of the combustion gas 1n the secondary combustion
chamber, just prior to the secondary air Injection, shall be
maintain at a minimum temperature of 927°C (1700) or 1204*C
(2200°F), subject to the results of the trial burns. If the
trial burn at 927°C falls to achieve the performance standards
1n condition C.4, then the minimum required temperature shall
be 1204°C. The temperature of the combustion gas in the
secondary combustion chamber just prior to the secondary air
Injection shall be monitored and recorded continuously.
-------
K-68
EPA
UNITED STATES CXVItOMMEXTAL HOTECTION AGENCY, UCION V
230 South Dearborn Street
CHICAGO 1L 60604
FACSIMILE REQUEST AND COVI
d/PHONt
-703 - ^
Tto
OH 4s
MACHINE NR: ?
-------
K-69 F«v. al Express §3401151401
CWM Chemical Services, Inc.
11 700 S. Stony
Chicago, IL 60617
3 12-W 6-5700
August 22, 1989
Mr. Ctrl Bremer
waste Management Division, 5HR
United States Environmental
Protection Agency
230 S. Dearborn Street
Chicago, IL 60604
RE: CWM Chicago Incinerator, Trial Burn Results
Dear Mr. 8 rawer:
Please find attached a letter transmitting the preliminary results on the RCRA
Trial Burn performed at the Chicago Incinerator by MRI. To assist the USEPA
in maintaining Its critical permitting schedule, we are providing this key
Information from the burn which Indicates:
1) DRE - all runs greater than 99.
2) Participate emissions - all runs less than 0.08 gr/dacf.
3) HC1 removal efficiency - all runs greater than 99*.
4) Waste feed rates and process Information for all runs.
5) Heat Input rates for all runs.
6) Chlorine Input rates for all runs.
7) Metal feed rates and emission rates for all runs.
Note: Run 1 was disqualified.
Despite the best efforts of CWM, MRI and regulatory agencies, the final Trial
Burn report 1s not yet available. CWH 1s confident, however, that with the
data submitted herewith and a final report which MRI will complete and CWM
will submit by September 11, 1989, the USEPA can finalize those permit
conditions requiring Trial Burn data.
If any additional information 1s required, please contact me immediately.
Douglas H. Fisher, Manager
Health, Safety l> Environmental Compliance
DHF/mJr
Attachment
cc: Kurt Frey
Johan Beyer
Ed Kenney
Pred trunner
if CMmtt WUM M**»»n«nt. me.
-------
K-70
MIOW18T RfSCARCH IN3TI7U
428 Vo
-------
K'71
Mr. Douglas Fisher
Page 2
August 21. 1989
MIOWtfT
CH
presently undergoing QA review, so the results 1n the draft report may be
different from those shown 1n the attached tables, but any changes are
expected to be minor.
Sincerely.
MIDWEST RESEARCH INSTITUTE
Paul Goman
Principal Chemical Engineer
Approved:
Chatten Cowherd. Director
Environmental Systems Department
cc: K. FrtyCWM
J. Bayer.-CWM
-------
K 72
TABU 1. SUMMARY OF EMISSION PERFORMANCE
ORE m
Carbon tetrachlorlde
Tetrachloroethylene
1,2, 3-Tr 1 ch 1 orobenzene
Part 1cu late concentra-
tion (gralns/dscf)
corrtcttd to 7% Oa
HC1 Mission (Ib/h)
HC1 removed efficiency
(X)
Average 0. (X)
Plant CEM
Orsat
Average CO (pp«)
Plant CEM
MftI CEM
Run 2
> 99.9981
> 99.9980
99.9989
0.0795
1.42
99.92
9.7
10.0
5
1
Run 3
> 99.9984
> 99.9978
99.99986
0.0530
0.72
99.95
10.4
10.4
5
< 1
Run 4
> 99.9986
> 99.9982
> 99,999987*
0.0405
0.48
99.97
10.8
10.0
4
1
Run 5
> 99.9990
> 99.9981
99.99991
0.0315
0.42
99.97
10.5
10.4
4
< 1
* ORE for TC8 1n Run 4 1s uncertain, due to low surrogate recovery
efficiency.
-------
K-73
TA81E 2. SUMMARY OF INCINERATOR OPERATING DATA
Feed rates
Organic liquid feed (lb/«1n)
K1ln
SCC No. 1
SCC No. 2
Aqueous feed to SCC (QPM)
Fuel oil to SCC (QPM)
Sludge (Ib/a1n)
Drum solids (Ib/h)
Operating parameters
Kiln teap. ("F)
SCC tenp. (*F)
Scrubber Inlet te«p. (4F)
Red re. water to quench
(QPM)
City water to quench (6PM)
Red re. water to scrubber
(QPM), No. 1
No. 2
Scrubber Inlet pH
SCC pressure (1n w.c.)
Stack velocity (acfi)
Plant continuous aonltors
oVW
CO 2 (X)
CO (pp»)
THC (pp«)
HC1 (ppa)
Run 2
27
36
34
3.0
0.48
0
3,950
1746
2027
178
416
139
559
569
8.8
0.50
41,600
9.7
9.4
5
4
15
Run 3
27
26
M-
4.1
0.56
0
4,130
1755
1869
174
413
173
523
530
9.1
-0.40
43,400
10.4
9.0
5
2
17
Run 4
28
27
8-
5.9
0.48
0
^M9
-------
K-74
REGION VI
2/28/90 5:10
Maria Daniels. EPA Region VI
1. Chemical Waste Management, Port Arthur, TX
currently operating under post-trial burn conditions (90 days + 90
additional possible)
permitted feed rate limits based on trial burn:
Liquids to kiln
Liquids to Afterburner
Sludges to kiln
Solids to kiln
Nonenergetic Wastes
(X5000 Btu/lb)
10.000 Ib/hr
41,375 Ib/hr
Maximum mass feed to unit including fuel:
Energetic Wastes
(> 5000 Btu/lb)
3000 Ib/hr
8900 Ib/hr
5300 Ib/hr
3000 Ib/hr
50,270 Ib/hr
or 150,00 tons/yr
3/5/90 4:10 - Jim Sales (214) 655-6785
1. Rollins, Deer Park, TX
two trains
faxing data
2. American Envirotech (Lullint/Houston) , TX
application submitted
commercial
responding to NODs
not constructed
could be permitted by end of 1990
much opposition
faxing capacity data
3. Gulf Coast Waste Disposal Authority
withdraw application
won't be built
4. Ideal Cement Co., Saratoga, AR
no info available
no storage permit
5 Oglesby Cement Co , Houston, TX
no storage permit
no info available
Marine Shale Processors, LA
under enforcement
call Jerry Truitt, 6794
-------
K-75
7 Houston Chemical Services (HCS)
fluidized bed
constructed
public hearing extended
much opposition
not permitted
could be permitted by 1991
no dioxins/furans/PCBs
8. Thermal Kinetics, Lonester, TX
R&D permit only
9 Boxcrow Cement
no info available
10 Catalyst Resources
existing will shut down
liquids only
on-site
11. ENSCO, El Dorado, AR
two units
no change since beginning at 1989
second rotary kiln added in 1989
permitted and operating
also a fixed/transportable unit
Max practical throughout (based on current operators from on-site
inspector)
10 75 tons/hr (kilns 1+2 combined)
+ 25% (kiln 3)
- 14 tons/hr
PCBs yes overall facility practice
D/F no liquids 21,500 Ib/hr
permit doesn't limit capacity solids 12,900 Ib/hr
12. Rollins. Baton Rouge, LA
no change since beginning of 1989
missed deadline because of protracted LA process
many deny permit
currently under "Adjudicary Hearing"
if closed, appeal would allow operation for 2-3 years
13 Ash Grove Cement, Foreman, AR
no info available
No incinerator in the country (at least commercial) is permitted for dioxins
and furans
-------
K-76
3/6/90 2:30 - Maria Daniels (214) 655-6785
13 CWM, Port Arthur, TX
data already obtained
call TX Underground Injection Control board 655-7160
14. Envirosafe, Devers, Texas
faxing data
15 BASF, Freeport, TX
operating
not commercial
on-site
faxing
16. Celanese, Seabrook, TX
(missed deadline)
call Lydia Bolada (6785)
not in now
17. Mobay, TX
had on-site (small)
withdrew permit application
will resubmit
Transferred to Henry Ansgard wanted written request
18. Stauffer Chemical, Houston, TX
liquids and some pumpable sludges only
sulfuric acid regeneration
commercial energy recovery
19 DuPont, LaPorte, TX
on-site liquid injection
liquids only (maybe some pumpable sludges)
20 IT, Corp., Ascension Parish, LA
won't be built
lost state permit
21. Waste Tech, Lake Charles, LA
only PPG wastes
fluidized bed
mostly liquids, some sludges
3/7/90 4:55 - Jim Sales unavailable, left message
Maria Daniels unavailable, left message
3/8/90 11:55 Maria Daniels (214) 655-6/85
faxing data
-------
K-77
3/8/90 2:45 - Stan Burger (214) 655-6775, unavailable, left message
Transferred to Jim Sales
Houston Chemical
call state Facility Manager, (512) 463-8173
3/8/90 2:55 - Sandy Harwopd (TX state)
unavailable, left message
3/8/90 3:20 - Sandy Harvood. left me a message
3/8/90 4:30 - Sandy Harwood
call Lisa Ligas on Houston Chemical (512) 463-7999
3/9/90 12:10 - Lisa Ligas. Texas Water Commission (512) 463-7999
1. Houston Chemical Services, Bayport, TX
was owned by Quaker Oats
two giant FB incinerators for rice hulls
new owner proposed adding RK
hearing ended 2/9/90
permit decision expected 5/90
will be fully commercial
1 RK 90 MBtu/hr
2 FB each 230 MBTu/hr
2. call Kyle Shelton, 8278 on Rollins, Deer Park
3 call Wayne Harry, 8534 on CWM, Port Arthur
4 call Rex McDonald, 7969 on American Envirotech
5. call Office of Notification and Classification at 463-8175 on notices of
registration by cement kilns
6. never heard of Thermal Kinetics
7 call Troy Wappler, 465-2296 on Stauffer Chemical, of Houston
8. Hoesct Celanese, Pasadena, TX
operating
on-site
liquids only
-------
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 IV
CHAPTER 4
APPENDIX J APPENDIX M
U.S. Environmental Protection Agency
Office of Solid Waste
401 M Street, S.W.
Washington, D.C. 20460
May 1990
-------
TABLE OF CONTENTS
Page
Section -^-
Volume I
EXECUTIVE SUMMARY E-l
1 INTRODUCTION 1 i
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 and Dioxins . 1-3
1.2.2 California List 1-5
1.2.3 First Third Wastes . 1-6
1.2.4 Underground Injected Wastes . . 1-7
1.2.5 Second Third Wastes (surface disposed and
underground injected wastes) . 1-9
1.3 Introduction to the Third Third Final Rule 1 10
1.3.1 Surface-Disposed Wastes 1-10
1.3.2 Deepwell-Disposed Wastes . 1 11
1.3.3 Soil and Debris . . . . . 1 11
1.3.4 Mixed Radioactive Wastes . 1-11
2. 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
-------
TABLE OF CONTENTS (continued)
Section
2 . 1. 1. (3) Mulci-Source Leachate Data Sources 2-10
2 . 1.1. (4) Mixed Radioactive Waste Data Sources 2-10
2.1.1.(5) Other Data Sources 2-10
2.1.2 Capacity Analysis Methodology 2-11
2.1.2.U) Required Capacity 2-11
2.1.2.(2) Available Capacity 2-13
Results . . . . 2-14
2.2.1 All RCRA Wastes 2-15
2.2.2 Solvents . . 2-17
2.2.3 Nonsolvent RCRA Wastes Containing
Halogenated Organic Compounds (HOCs) 2-19
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
2.2.6 Underground Injected California List Wastes 2-34
2.2.6.U) 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
-------
TABLE OF CONTENTS (continued)
Section
2.2.9 (1) Effects of Previous Land Disposal
Restrictions
2.2.9 (2) Impacts of Third Third Final Rule
on California List HOCs
2.2.10 Third Third Promulgated Wastes
2 . 2 . 10 (1) Overview
2.2.10.(2) Surface Disposed Third Third Wastes
2. 2. 10.(3) Underground Injected Wastes Included
in Third Third Rule
2.2.10.(4) Soil and Debris
2.2.10 (5) Mixed Radioactive Wastes
Waste Code Specific Capacity Analysis for Third Third
Promulgated Wastes . .
2 1 Characteristic Wastes . ...
3.1.1 D001 Ignitable Wastes
3.1.2 D002 Corrosive Wastes
3.1.3 D003 Reactive Wastes ...
3.1.4 EP Toxic Pesticides (D012-D017)
3 2 Metal Wastes .....
3.2.1 Arsenic Wastes
(D004, K031, K084, K101, K102, P010, P011,
P012, P036, P038, U136)
3.2.2 Barium Wastes (D005, P013)
3.2.3 Cadmium Wastes (D006) . .
3.2.4 Chromium Wastes (D007 and U032)
3.2.5 Lead Wastes
(D008, P110, U144, U145, U146. (K069, K100)
3.2.6 Mercury Wastes
(D009/K071, K106,
3.2.7 Selenium Wastes
(D010, P103, U204,
3.2.8 Silver Wastes . ...
(D011, P099, PI04)
3.2.9 Thallium Wastes . . .
(P113, P114, P115. U214, U215, U216, U217)
3.2.10 Vanadium Wastes
(P1L9 and P120)
3.3
P065, P092, U151)
U205)
Treatment Standards for Remaining F and K Wastes
3.31 F002 and F005
3.3.2 F006 and F019 ......
3.3.3 F024 . .
3.34 F025
3.3.5 K001 and U051 , .
3.3.6 Waste from Pigment Production ...
K002, K003, K004, K005 , K006, K007 , and K008
3.3.7 Acrylonitrile production wastes K011, K013 and K014
33.8 Benzyl chloride distillation Wastes K015 . . .
2-50
2-51
2-51
2-53
2-55
2-59
2-62
3-1
3-13
3-13
3-17
3-20
3-25
3-34
3-34
3-42
3-44
3-47
3-50
3-58
3-65
3-68
3-70
3-74
3-77
3-77
3-79
3-85
3-87
3-88
3-90
3-97
3-101
111
-------
TABLE OF CONTENTS (continued)
Section
3 4
3.3.9
3.3 10
3.3.11
1.3.12
3.3.13
5 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
K025, K026, K035. K083
K029, K095, and K096
K033, K034, K041, K097, and K098
Disulfoton Production Wastes K036 and K037
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 K061
Ink Production Wastes K086
and
Treatment Standards for U and P Wastewaters
Nonwastewaters Excluding Metal Salts and
Organo-metallics ... . .
3.4.1 Halogenated Aliphatics
(U044, U074, U076, U077, U078, U079, U080, U083
U084, U131, U184, U208, U209, U210, U211, U226,
U227, U228, U243)
3 4.2 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)
3 4.3 Halogenated Phenolics . . . .
(U039, U048, U081, U082)
3 4.4 Brominated Organics
(P017, U029, U030, U066, U067
3 4.5 Miscellaneous Halogenated Organics
(P016, P023, P024, P026, P027, P028,
P058, P095, P118, U006, U017,
U025, U026, U027, U033, U034,
U043, U045, U046, U047, U049,
U075, U097, U121, U138, U156,
U222)
3.4.6 Aromatics and Other Hydrocarbons
(U019, U055, U056, U186, U220, U239)
3.4 7 Polynuclear Aromatic Hydrocarbons
(U005, U016, U018, U022, U050, U063,
U064, U094, U120, U137, U157, U165)
3.4.8 Phenolics
(P020, P034, P047, P048. U052, U101, U170,
U188, U201)
U068, U225)
U020
U041
U062,
U158
P057,
U024.
U042,
U073,
U192,
Page
No.
3-102
3-105
3-107
3-111
3-112
3-115
3-116
3-120
3-121
3-129
3-130
3-131
3-133
3-133
3-152
3-177
3-182
3-189
3-218
3-225
3-232
IV
-------
TABLE OF CONTENTS (continued)
Section
349 Oxygenated Hydrocarbons and HeterocycLics 3-242
(P001, P003,"P005, P088, P102, U001, U002,
U004, U008, U031, U053, U057, U085. U108,
U112, U113, U117, U118, U122. U123. U124,
U125, U126, U140, U147, U154, U159. U161,
U166, U182, U197, U213, U248)
3 4.10 Organo-Nitrogen Compounds 3-275
(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)
(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, Ulll,
U172, U173, U174, U176, U177, U178)
3 4.11 Organo-Sulfur Compounds . ... 3-312
(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 3-326
(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 . 3-334
3.5.1 Incinerable Reactive Organics and Hydrazine
Derivatives . . . 3-334
(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) ... . .... 3-342
3.5.3 Fluorine Compounds (P056, U134) . . . 3-346
3.54 Recoverable Metallics (P015, P073, P087) 3-349
3.6 Gases ...... . 3-353
(P076, P078, U115)
3.7 U and P Cyanogens 3-355
(P031, P033, U246)
3.8 Contaminated Soils . 3-357
v
-------
K-78
Sandoz, Baumont, TX
on-site pesticides
LI
awaiting TB
12:30 - Kvle Shelton not in
Transferred to Rex McDonald
1. American Envirotech
have responded to NODs
could be permitted by 1st, 4th 1991
two RK's proposed 130 MBtu each
not willing to look up throughput limits
3/9/90 12:40 - Kvle Shelton (512) 463-8278, not available
Transferred to Troy Wappler
1. Stauffer, Houston, TX
liquids only
no recent changes in capacity
2. Pennwalt, Baumont, TX
changed name to Atochem North America
on-site liquids only
3/9/90 3:10 - Kvle Shelton (TWO returned call
1. Rollins, Deer Park, TX
first permitted late 1987
no planned changes to capacity
trying to amend permit for dioxins and furans
2. Occidental Chemical, Engleside, TX
proposed on-site facility
company captive
vinyl chloride liquid wastes only
3/12/90 1:40 - Gail Artall. LA State Permit Office (504) 342-4685
will call back with capacity data on Rollins, Baton Rouge
3/13/90 2:15 - Gail Artall (504) 342-4685
left message to call
3/14/90 10:30 - Gail Artall. LA State
-------
K-79
transferred to Don Nugent
Rollins, Baton Rouge
will fax capacity data from permit
3/14/90 4:20 - Dan Johanson. AR State. Permit Coordinator (215) 655-6760
left message
Transferred to Lee Haves
AR Permit Section (502) 562-7444
Transferred to Stan Burger
Transferred to Mark McKorkel. Permit Writer
1. ENSCO, El Dorado, AR
call Cecil Harrell or Mike Bates at AR Permit Section //
(502) 562-7444
2 large RK's
1 boiler
1 transportable RK
2 ABs
2nd kiln permitted since 1986
call on-site inspector, Mohammed Abdulhared (501) 863-7173
more storage capacity than feed potential
Transferred to Mike Porta
1. Ash Grove Cement, Foreman, AR
are currently burning s/s
fully permitted by State (6/89)
1 container/revolution (< 80 Ib/container) maximum
kiln speed averages 1 RPM
wet process kiln
has heard of another Ash Grove kiln in OR or WA
no other kilns in AR burn s/s
2. Ideal Cement, Saratoga, AR
in process of obtaining permit to burn hazardous liquids
permit does limit waste form
3/16/90 10:05 - Mohammed Abdulhafed (501) 863-7173
not available left message
-------
K-80
3/16/90 10:05 - Mohammed Abdulhafid (5011 863-7173
1. ENSCO, Bacon Rouge, LA
fully RCRA/TSCA permitted (no dioxins/furans/explosives)
2 RKs with ABs (referred to as main unit with total thermal rating
of 129 MBtu/hr)
1 liquids only boiler
1 fixed mobile RK, 42 MBtu/hr
Permit only limits PCBs to 3700 Ib/hr
Second RK of main unit was added only 1 year ago and is designed
specifically for sludges and solids
capable of burning low Btu/lb wastes
first RK in main unit is used primarily for PCB caps
ENSCO is definitely shifting toward relatively more sludges and
solids
heat release limits feed rate more than mass feed rates
recently incorporated computerized continuous heat release
monitoring system (replaces random hand sampling)
hard to predict Btu/lb for RCRA codes
will investigate actual throughput limits and call me back
3/16/90 3:40 - Mohammad Abdulhafid returned call
1. ENSCO
F024 on permit
capacities
Practical estimates based on random selection of feed rate
records:
to mobile unit
3000 to 5000 Ib/hr sludges/solids
to main unit (primarily #2 RK):
6000 to 16,000 or 17,000 Ib/hr
according to waste analysis wastes
blended to between 6000 and 10,500 Btu/lb
optional feed blend is 8000 to 11,000 Btu/lb
//I kiln is used for PCB's with some RCRA s/s on campaign basis
Storage not a problem for s/s
occasionally, liquids back up
ENSCO is permitted for additional storage than currently
exists
wastewaters average 0 to 15 Btu/lb
RCRA permit assumed average of 10,000 Btu/lb
3/19/90 Kyle Shelton. TWX (512) 463-8278
1. Rollins, Deer Park, TX
Doesn't know when individual units came on line, suggests calling
Rusty Dunn at Rollins
could call Shannon Disarbo at TX Air Control Board
-------
K-81
4/2/90 4:30 - Wayne Harry. TWC. returned call
1 Chemical Waste Management, Port Arthur, TX
received final RCRA permit 6/7/88
call Tom Roth of UI Control Group (512) 463-8240
trial burn completed, results expected in 1 to 2 months
currently operating at slightly reduced capacity
maximum gas flow will be 219,000 ACFM
under Post-TB conditions 185,000 ACFM
4/3/90 2:00 - Mike Porta. AR State RCRA (501) 562-7444
1. Ash Grove Cement, Foreman, AR
transferred to Mike Bates, Section Chief
Permit Writer is Mohsen Kourehdar (501) 562-7444, ext. 267
transferred to Mohsen Kourehdar
Blender is Rineco Chemical Industries
2. Rineco Chemical Industries
no dioxins/furans accepted
currently is recycler, submitted Part B about 2 years ago
Ash Grove doesn't burn wastes below 6,000 Btu/lb, but can be 5,000
Btu/lb before blending
liquids decanted from drums into tank
solids removed from drums by hand or using a hydraulic hammer
solids fed to shredder
shredded solids packaged in buckets
salesman take sample for Btu analysis before accepting
Rineco contact: John Whitney (501) 778-9089
K048-K052 in Part A
API sludge would make a good fuel
will look into K048-K052 Btu content and call back
4/4/90 11:00 - Tom Roth. TWC. returned call
1. Chemical Waste Management, Port Arthur, TX
public hearings held
in final stages of public comment
call Ronnie Crossland (EPA) (214) 655-7160
4/4/90 11:10 - Ronnie Crossland. EPA (214) 655-7160
1. Chemical Waste Management, Port Arthur, TX
no migration variance approval proposed 2/16/90
comment period closed Monday
now responding to many comments
final decision hoped for by May 8
-------
K-82
4/20/90 4:20 Georze Hartman. (512) 463-8230
1. Envirosafe, Devers, Texas
Awaiting revised application
Not constructed
Proposed RK
Lots of opposition
1993+
4/24/90 5:15 Mohamid Abdulhafid. AR State Inspector for ENSCO
(501) 863-7173
1. ENSCO, El Dorado, AR
U075 and U121 (freons) damage refractory
Not prohibited by permit
Can blend with other wastes to mitigate problem
-------
K-83
UNITED STATES ENVIHOTMWTAi, FHOTtCTXOK AGENCY, IECXON VI
1445 Ross Ave. at Fountain Pltce
0alu$» TX
PACSIMIL REQUEST
PLEASE REMOVE ALL STAPLES
SIMILE
CONFIRMATION
""«"
w.
- Of
o
^ 6
»*n 6£KT
TIK£ SfNT
NUMSIK OFPAOtS TO MCLUDC W» C
s
ovmsxtFT
***» *
MFOKMUT1ON POft ttNOINO MCSIMtU MUSAOSS
.«»«»»««
FAKATAX KV3000
FTS: 255-2142 FTS: 255-2140
COW: (214) 655-2142 COW: (214) 655-214
PACE ^ or SPACES
-------
K-84
PERMIT NO. HU-50089-001
NAME: Rollins Environmental Servic»s (TX)
CONTINUATION SHEET 51 OF 11
Maxims
ht»t input.
MM BTU/hr
Maximum
waste feedrates,
Ibs/hr
Minimum combus-
tion gas exit
teaperature , * P
Maxlmua combus -
tion gas teaperature
upsec liait, T
Maximum volu-
n«cric flow
rat«, acfa (v«c)
Haximua combus-
tion zone pressure
rotationml sp««d,
Minimum combus-
tion gas 0~ concen-
tric ion. wt basis
Maxioua cocbus-
tion gas CO
concentration,
wet basis
Kaxivua coabus-
tion gas CO
concentration upset
lialt. wet basis
TABLE 111-3
Incinerator Train II
Operating Parameters
Kiln
No. 2
120
12,000
1.500
1,500
N.A.
Atmospheric
3
N.A.
N.A.
N.A.
Rotary
Reactor No. 2
33.5
12,000
1,200
1,200
N.A.
Negative relative
to seal pressure
N.A.
N.A.
N.A.
Afterburner No. 2
N.A.
8,000
1,800
1,800
60,000
Atmospheric
N.A.
5.0%
-------
K-85
PERMIT NO. HV-50089-001
NAME: Rollins Environmental Service* (TX)
CONTINUATION SHEET 50 0? l;s
TABLE III-2
Incinerator Train I
Operating Parameters
Maximum
heat input,
MM BTU/hr
Kiln
V9*J,
80
Rot*ry
Reactor No. 1
3$
Loddby
Liquid* Burner
100
Afterburner «1
N.A.
Maximun
waste feedrate,
Ibs/hr
Minimum combus-
tion gas exit
temperature, *F
Minimum
combustion gas
temperature upset
limit, *F
Maximum
volumetric flow
rate, acfm (wet)
Maximum
combustion
zone pressure
rotational speed,
13,200
1,400
1,400
12,000
1,200
1,200
5,230
N.A.
N.A.
4,950
1,600
1,600
N.A.
N.A
N.A.
57,250
Atmospheric Negative relative Atmospheric Atmospheric
to seal pressure
3 (MX)
Minimus N.A.
combustion gas 0.
concentration,
wet basis
Maximum N.A.
combustion gas CO
concentration,
wet basis
Maximal N.A.
combustion gas CO
concentration upset
limit, wet basis
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
5.0%
(1-hr rolling avg)
3.0%
(instantaneous)
100
H.A.
N.A.
500
-------
K-86
LOUISIANA OCPAROENT OF ENVIRONMENTAL QUALITY
OFFICE Of SOLID AND HAZARDOUS WASTE
HAZARDOUS MSTE MVIflON
POST OFFICE ICX »307
BATON ROUSE, LOjfKtANA 70804
TRANSMITTAL SLIP
ADDRESSEE:
ADDRESS :
!! PHONE:
I! PAGES TO FOLLOW:
ii -
!! DATE SENT: 3 /V ~
FO* ASSISTANCE (504) 342-
>»*>«««*
b$/87
-------
' " ou.
K 87 suvtcr TO
(3). However, any evidence of noncompllanee with these
performance standards may be grounds for revocation,
modlTTc'atton or reissuance of this permit pursuant to LAC
33.-V.323. 7/
x^"~
X
(5) The Permittee shall not incinerate wastes which are /radioactive,
F020, P021, F022, F023, F026, F027 (dioxin listed wastes),
explosives (unless rendered safe for burning through dilution, etc.
and approved for burning by the administrative 'or PCBs in
concentrations greater than 30 ppm. Wastes containing PCB's in
concentrations greater than 50 ppm shall not be incinerated unless
a TSCA permit has been obtained for the incinerator.
(6) Any hazardous waste, or blend thereof, which can not be
homogenized or destratified by agitation or recirculation must be
direct burned in the incinerator complex only under the following
conditionst
(a) Containerized liquids must be either directly educted Into the
afterburner or fed to the kiln after the addition of absorbent
material if necessary because of volatilization and/or BTU
content.
' (b) Bulk liquids must be directly burned through the Loddby
Auxiliary feed system or through the kiln sludge line.
(c) The feed rate must be adjusted such that phase change would
not result in upset of the incinerator operating conditions.
(d) The waste analysis plan shall include approved test methods
used, if other than those specified in SW-846, for establishing
the conditions and limits for characterization as to
homogenity, fcapabllity of stratifying or separating into
phases under nonflow or static conditions.
(7) The Permittee shall inspect and, if necessary, analyze each
hazardous waste shipment received from off-site at the facility to
determine whether it matches the identify of the waste specified
on the accompanying manifest or shipping paper.
2. Existing Rotary Kiln. LODDBY. Afterburner Incinerator Complex
a) Operating Conditions
(1) All feed to this incinerator, vents and any auxiliary fuels shall be
tested, measured, and recorded as required by LAC 33:VJ529 and
the Waste Analysis Plan, (Attachment 1).
36
-------
: 3 - ! 5 -' a 4 03:45
K-88 DRAfT
SUBJECT TO REVISION
(2) The maximum waste feed rate to the incinerator complex shall be
as follows:
POUNDS PER HOUR
la) Waste D- Thermalox waste water 9,498
(b) Waste to the afterburner 462
(c) Hazardous waste feed to be Loddby 21,732
and kiln and afterburner
(3) The maximum heat release for the incinerator complex (kiln,
LODDBY, and afterburner) stall be 95,600,000 BTU/HR, including
any vent gases and auxiliary fueL
(4) All waste feeds shall contain a combined' total of no more than
2619 Ib/hr of total chlorine.
(5) All waste feed shall contain a combined total of no more than 67.5
Ib/hr bromine.
(6) All waste feeds shall contain a combined- total of no more than 39,7
Ib/hr of flourine. , T
(7) All waste feeds shall contain a combined total of no more than 2$
Ib/hr of iodine.
(8) The atomized liquid feeds shall contain no more than 543 Ib/hr of
astu
(9) The viscosity of the hazardous waste feed shall be maintained by
preheat and steam/air pressure to insure proper atomization
through the burner nozzles.
The Permittee shall not incinerate any listed waste (Table l-LAC
33tV. Chapters 31 or 49) in concentrations greater than 100 ppm
with a heat of combustion less than that of carbon tetrachloridc
(.24 Koal/gr. or 432 BTU/lb).
(11) The incinerator shall operate at steady state within permitted
combustion temperatures and air flow prior to introduction of
hazardous waste. No fuel except natural gas, commercial fuel oil
or waste derived fuels specifically approved by LDEQ for the
Permittee shall be used in the start-up of the incinerator.
b) Process Conditions
(1) The minimum temperature of the combustion gases exiting the
afterburner shall be 1013°C U856«F). All hazardous waste feed*
shall be cut-off immediately if this temperature falls below tht
valve. The minimum temperature of the combustion gases exiting
the rotary kiln shall be 8S6OC i627Of. when burning hazardous
waste or prior to the introduction of hazardous waste, all
37
-------
32 ".4. ".990 08 '
K-89
UN2T£D STATES ENVJKOKHBCTAL MOTtCTlON AC»CY, KfiGIOW VI
1445 Ross Avt. tt Fountain Place
DillftS, TX 752C1-2733
ILE REQUEST AND COVER
PLEASE REMOVE ALL STAPLES
CONFIRMATION
NUMBER
S C-6. 7-g 3~
OMI SEKT
VI Or MOCS TO MCUIDC IMS COV1H SMf IT
INFORMATION WR ttUWNQ PAC8IMIU MtSSAOIS
PAKATAX KV3000
FTS: 255-2142 FTS: 255-2140
CCW: (214) 655-2142 COW: (214) 655-2140
PACE OF
FACES
-------
K-90
-------
K-91
POWIT HO. HV-50128-000
NAME: BASF Corporation
[H.A.2.]
Waste Description
CONTINUATION SHETT 3 of 42
TWC Vaste Class
Hazard
j. Hexanediol (HDO) Lights IH I
k. Butyl Acrylate (BA) Residue I
1. Ethylhexyl Acrylate (2-ZHA)
Residue 1
a. Hexamdiol (HDO) Heavies I
B. Facility Unite end Functions Authorized:
The permittee is authorized to operate the following facility units
for storage and processing subject to the limitations contained
herein. No land disposal is authorized by this permit. Processing is
limited to combustion of wastes for energy recovery and/or disposal.
All waste management activities are to be confined to authorized
facility units. References hereinafter in this perait to "TVC Perait
Unit No. II.B. . shall be to the facility units listed belerw:
1. Incinerator with waste heat boiler (IN701), identified in the
Notice of Registration (NOR) as Facility No. 19, for processing
of wastes described by Provisior. II.A.Z.a. and II.^A^2^e. -*..
atxiaua heat release rate 100 Billion BTUs per hour - peraic
application subaittal dated June 3. 1985;
2. Incinerator (Caustic Vashwater Incinerator), identified in the
NOR as Facility No. 20, for processing of wastes described by
Provisions II.A.2.b..f.. and h.. aaxiaua heat release rate 24
Billion BTUs per hour perait application subaittal dated June
3. 1983;
3. Tank (D7841), closed, maxiaua capacity 13,000 gallons, carbon
steel, above-grade, identified c.s tank D999 in che application
for storage of the waste authorized in Provision H.A.2.b.. y.
apd h, permit application subnittal dated June 3, 1985; and
4. Incinerator with waste heat boiler (IN4702), identified in the
NOR as Facility No. 4, for processing of wastes described by
Prevlgiem* II.A.2.a., d. and II,, A..2. t.-a.. aaxiaua heat release
rate 30 million BTUs per hour - perait aaendaent subaittal dated
May 13, 1985. The processing of waste described by Provision
I^.A.^.d.. Acrylic Acid Residue, is subject to the requirements
of Provision DC.F.I. The processing of waste described by
Prevision IT.A.2.1.. 2-Ethylhexyl Acrylate Residue, is subject to
the requirements of Prevision* III.F.2. and 3.
C. Authorization to operate this facility is contingent upon maintenance
of financial assurance pursuant to Provision IV.A.Land financial
liability requirements pursuant to Provision III.A.8. Authorization
to begin operation of new facility components is contingent upon
u
/n
-------
L s^Gf >
K-92
PBWIT HO. HW-50128-000 COBTINUATIOR SHKT 2 of 42
NAME: BASF Corporation
I. St»e and Lo/filEiflfl o^ Site
A. The industrial solid waste management facility is located on a 401-
acr* tract of land in Brazoria County. The site is in the drainage
area of Segment 1201 of the Brazos River Basin, North Latitude
29*00'00". West Longitude 95*24'00".
B. The legal description of the site submitted in the application for
Permit No. HW-50128 is hereby mad* a part of this permit as "Attach-
ment A.*
II. Facilities find Operations Authorized
A. Wastes Authorized:
The permittee is authorized to manage the hazardous and non-hazardous
industrial solid wastes listed in the Part B permit application dated
June 3, 1985 and revisions dated July 17, 1985, and November 19. 1985,
hereinafter referred to as the permit application submittals, and the
Part B permit amendment application submittal dated Kay 15, 1985 and
amendment revisions dated August 7, 1985, Hay 17, 1988, and January
28, 1989, hereinafter referred to as the permit amendment submittals,
described herein, subject to the limitations provided herein.
Wastes authorized for storage and processing are limited to those
generated on-site at this facility. Hazardous wastes authorized to be
managed under this permit are limited as follows:
1. The hazardous wastes must be in the Hazard Code Groups (as
prescribed by U.S. Environmental Protection Agency regulations in
effect upon date of permit approval) indicated below:
Ignitable (I) Acute Hazardous Waste (H)
Toxic
-------
V
K-93
PERMIT 90. HW.50128-000 COWTIWJATIOR SHEET 8 of 42
NAME: BASF Corporation
IIII.C.J
2. Maintenance and operation of the Caustic tfashwater Incinerator as
specified in Provisions ITT .1.1. -5. will be regarded as
compliance with the parforaance standards of Title 40 CFR Part
264.343.a.-d.
3. The permittee shall maintain and operate IMA702 so that, when
operated in accordance vith Provision* IT.C.I.-10. and Pravisions
IX..D.1. -10.. and saapled according to the requirements of
Provisions IX.F. ^-4^. the unit vill meet the performance
standards specified in Provisions IX.B.I.-4.
0. Incinerator IN701 Operating Requirements:
1. The permittee shall feed wastes described by Provision* II.A.2.a.
and ft. co the IN701 incinerator only under the following
conditions:
a. The temperature of the combustion gas between the furnace
and the boiler entrance shall be maintained at a minimum
160S*F at all times and shall be monitored and recorded
continuously. When any two of the three sensors in the
combustion chamber detect minimum temperature specified
above, the shut-off valve must automatically activate,
thereby closing off the waste feed lines. If any two of the
three sensors read more than 140*F apart, they must be
immediately checked to determine which is in error.
b. The maximum volumetric flowrate shall not exceed 208,800
actual cubic feet per minute (acfm). Volumetric flowrate
shall be monitored and recorded continuously, except as
specified in Provision III.0.4.
c. Combustion gas concentration of carbon monoxide (CO)
measured in the outlet of the waste heat boiler shall not
exceed 100 ppm, dry basis at any time. The CO concentration
shall be monitored and recorded continuously.
d. The waste feed rates to the incinerator are independent of
one another and may not exceed the following values:
Feed Rate
fted flbs/hrJ
Acrylic Acid Water 13,590
Off-Gas 89,226
Acrylic Acid Residue 600
Vacuum Vent/Off-Gas 8,370
Witrogen Vent/Off-Gas 900
-C-
-------
03-1-: 1990 2£:~-2
v
K-94
PERMIT NO. HW-50128-000 COWTUIUATIOW SHEET 9 of 42
NAME: BASF Corporation
(II1.0.1.J
. The permittee shall control fugitive emission* by
maintaining totally sealed combustion zone. Pressure in
the combustion zone may not exceed 16.1 psia for more thin
ten consecutive second*. Pressure in the combustion zone
oust be monitored and recorded on a continuous basis.
f. The total feed rate, including the hazardous and
non-hazardous waste feed rate, preheated air, and auxiliary
fuel to the incinerator is limited to a maximum of 100
aillion BTU/hr heat input.
g. During start-up and shutdown of the furnace, those wastes
described by Provision II.A.2.a. and d. vust not be
introduced into the furnace unless the furnace is operating
within the conditions specified in Provision III.D.I.a.
through iii-D-i.f.
h. Ash content of the waste feed shall not exceed 100 ppm by
weight.
i. The viscosity of the waste feed residue described in
Provision II.A.2.d. shall not exceed 350 Standard Saybolt
Units (SSU).
2. The permittee shall maintain and operate a waste feed cut-off
system for the IN701 Incinerator. This system must automatically
cut off those wastes described by Provisions II.A.2.a. and d.
under any of the following conditions:
a. When the operating conditions deviate from those specified
in Provision III.D.I.a.-e.: or
b. Upon:
(1) Loss of primary combustion air;
(2) Power outage;
(3) Shutdown of the primary mover;
(4) Loss of any atomizing medium for hazardous waste
burners; or
(3) Loss of flame at the burner.
-------
K-95
PERMIT NO. HW.50128-000 COKTIJIUATIOK SHUT 11 of 42
MAKE: BASF Corporation
[III.D.J
11. The permittee shall kacp a written operating racord aa described
in 40 CF8. Part 264.73. In addition to the specific requirements
of this paragraph, tha p«raictaa ahall al»o racord:
a. All occasions whan tha operating parameters specified in
Proviaion III.P.I, are exceeded and/or the automatic waste
feed cut-off is activated; and
b. All occasions when waste feed is cut off pursuant to Pro-
vision III.D.2. or III.D.3.
At a minimum, the permittee shall record:
(1) The date and time of the incident; and
(2) The reason for waste feed cut-off and, if applicable,
tha concentrations triggering cut-off.
12. The pemittee shall perform tha following:
a. The incinerator and associated equipment (pumps, valves,
conveyors, pipes, etc.) oust be subjected to thorough visual
inspection, at least daily, for leaka, spills, fugitive
emissions, and signs of tampering; and
b. The emergency waste feed cut-off system and associated
alarms must be tested at least weekly to verify operability.
13. Only natural gas may be used as an auxiliary fuel.
E. Caustic tfashvater Incinerator Operational Requirements:
1. The Caustic Washwatar Incinerator described in Provision II.B.2.
is exempt from all requirements of 40 Coda of Federal Regulations
(CFR) 264 Subpart 0 with the exceptions of 40 CFR 264.341 (waste
analysis) and 40 CFR 264.351 (closure), pursuant to 40 CFR
264.340
-------
K-96
PERMIT HO. HV-30128-000 CORTIHUATION SHIFT 32 of 41
HAKE: BASF Corporation
[IX.B.J
3. The unit shall not emit particulate matter in excess of 0.08
grain per dry standard cubic foot when corrected for the amount
of oxygen in the etack (a* in accordance vith the formula
specified in 40 CFR Part 264.343 (c).
4. Compliance vith the operating conditions specified in Provision
IX.C.I.-10. of this permit will be regarded as compliance vith
the above performance standards. However, any evidence that
compliance with the operating conditions or other permit
conditions is insufficient to ensure compliance vith the above
performance standards may be "information" Justifying
modification, revocation, or reissuance of the permit pursuant to
40 CFR Part 270.41.
C. Incinerator IN4702 Area Operating Conditions:
The permittee shall cease operation when changes in waste feed,
incinerator design, or operating conditions exceed limits designated
in this permit. The permittee shall feed hazardous wastes to the
incinerator unit only under the following conditions:
1. The incinerator is not in start-up or shut-down mode.
2. Incinerator operating instructions shall be posted so as to be
iroediately available to incinerator operators.
3. The temperature of the combustion gas measured in the furnace
shall be maintained at a minimus of the following temperatures:
Waste Teed Hourly average Instantaneous
Feeds including 1005'C 950'C
Acrylic acid residue
Feeds excluding 958*C 936'C
Acrylic acid residue
4. The maximum volumetric flow rate through the system shall not
exceed 38.844 actual cubic feet per minute at 529 *F and 16.5
psia as measured at the exhaust duct after the economizer and
before the entrance of the stack.
5. The combustion gas concentration of carbon monoxide (CO) measured
in the exhaust duct after the economizer and before the gas
stream enters the exhaust gas stack shall not exceed 100 ppm(v),
for acre than 6 minutes in any 60-minute period, and shall not
exceed 500 ppm(v) for any instantaneous value.
/O
-------
K-97
PERMIT NO. HV-30128-OOO
HAKE: BASF Corporation
[IX.D.4.)
COFTIHUATIOW SHZBT 35 of 41
1.6 Hexanediol Light*
1,6 Hexanadiol Heavies
Butyl Acrylate Ether
Acrylic Acid Residue
Butyl Acrylate Residue
2-Ethylhexyl Acrylate Residue
Acid Water
400 Ib/hr
400 Ib/hr
123 Ib/hr
935 Ib/hr
1339 Ib/hr
1307 Ib/hr
11,080 Ib/hr
5. The feed rat* of «ny combination of two or more individual waste
streams listed in Provision D.4. fed to the incinerator shall not
exceed 10,772 pounds per hour at any time.
6. The total feed rate of Butyl Acrylate Residue and 2-Ethylhexyl
Aerylate Residue when combined is no greater than 1955 lb*/hr.
7. The feed rate of 1,6 Hexanediol Lights and 1,6 Hexanediol Heavies
when combined shall not exceed 400 Ibs/hr.
8. The feed rate of POHC to the incinerator shall not exceed 519.1
pound* per hour.
9. The total ash content of wastes fed to the incinerator shall not
exceed 44.2 pounds per hour.
10. The combined heat of combustion and heat content of all streams
fed to the incinerator system shall not exceed 676 million BTU
per hour for any 5 second period.
11. Auxiliary fuel shall be either sveet natural gas containing not
more than 1.5 grains of hydrogen sulfide per 100 cubic feet and
not more than 30 grains of total sulfur per 100 cubic feet,
liquified petroltua gas, diesel oil, or No. 2 fuel oil. All
diesel oil or Re. 2 fuel oil shall be first run refinery grade
and shall not consist of a blend containing waste oils or
solvents. Us* of any other auxiliary fuel will require prior
approval of the Executive Director of the Texas Air Control
Board. The permittee shall determine the lover heating value and
total sulfur content of any auxiliary fuel used in the
incinerator.
E. Other Incinerator Area Monitoring, Testing and Inspection Requirement*
for IH4702:
1. Combustion temperature, total vsste feed rate, total stack
volumetric flow (combustion gas velocity), oxygen concentration,
and carbon monoxide concentration shall be monitored and recorded
on a continuous basis.
/o
-------
-:~ i-i. 1?9C D6:5-1
K-98
PEWIT HO. HW-50128-000 COHTIWJAnCW SHUT 34 of 41
NAME: BASF Corporation
[XX.C.10.]
g. High CO concentration in the stack gas of greater than 100
ppm (v) for more than 6 minutes in any $0-sdnute period, or
an instantaneous reading of 500 ppm (v).
h. High fuel gas pressure after regulator greater than 30 psig
i. Forced draft fan failure.
j. Loss of name.
k. Loss of draft in the combustion chamber producing a
reading of greater or equal to zero inches of water for 1
minute.
1. Instrument air failure.
m. Flow meter failure.
n. Pow«r outage.
D. Limitations on Wastes Incinerated in IK4702:
1. The total organically bound chloride content of the total waste
feed shall not exceed 5283 ppa(v).
2. The hazardous waste feeds to the incinerator shall not contain
greater than 100 ppa of organic hazardous constituents listed in
40 CFR Part 261, Appendix vm, having an individual heat of
combustion less than 8053 BTU/lb (formaldehyde).
3. The total average heat value of the waste material and natural
gas fired in the incinerator shall not be less than the
following:
BTU/lb of waste material
Waste Feed fad to Incinerator
Acid water only 4,800 BTU/lb
Feeds including 37.000 BTU/lb
acrylic acid residue
Feeds excluding 53,300 BTU/lb
acrylic acid residue
4. The feed rate of the individual vaste streams to the incinerator
shall net exceed the following at any time:
-------
K-99
REGION VII
3/5/90 5:10 - Joe Galbraith (913) 551 7051, left message
3/6/90 4:30 - Joe Galbraith
1. Aptus, Coffeville, KS
application under review
at least 1 year from operating permit
at least 1 1/2 years from operating
was PCB
62 MBtu/hr RK
capacity in application (TB plan)
10,000 Ib/hr sludge/solids max
hopes to burn dioxins and furans
2. Industrial Service, Corp., Kansas City, MO
big question
application under review
many deficiencies
much public opposition
could at best be operational in two years
RK 40 MBtu/hr
primarily LI
no dioxins/furans
no more than 2000 Ib/hr S/S
3 Safe-Tech, Chamois, MO
very doubtful
weak application submitted
state opposes
proposal is to convert municipal RK combuster for hazardous waste
at least two years away
4 Waste-Tech, Kimball, NE
fluidized bed
< 5000 Ib/hr - s/solids not likely
have "good faith" state permit
plan to construct this year
at least 1 year from operation
: Ash Grove Cement, Chanute, KS
Louisville, NE
12 cement kilns in region
not approved for hazardous waste
hasn't been demonstrated as "recycling"
contact considers use of cement in roads/bridges to be land
disposal
must meet PArt 268 standards
liquids > 5000 Btu/lb OK (enforcement policy 1983)
solids not addressed in enforcement policy of 1983
some may be burning solids, will come down to enforcement decision
s/s must at least be > 5000 Btu/lb, but that may not be enough
-------
K-100
HQ has not addressed cement kiln policy. (Attended meeting in
December)
If sprayed like liquids - OK
"cold end" entry not demonstrated
State officials have witnessed Ash Grove's system and given
tentative approval (6 Ib charges to middle of kiln)
will change with Boiler/Furnace Regulations
6. National Industrial Env. Services, KS
no application submitted
7 Other Cement Kilns in Region VII
Systech/Lafarge
Monach Cement
River Cement, Restus, MO
Continental Cement (claims to be able to burn 280 tons/day)
Dundee Cement
8. Atlas Environmental Services
preliminary design stage
RK for D003 explosives
* Region will not allow open detonation
commercial for explosives - possibly from around country
capacity unknown
could be on-line in 1992
3/9/90 1:00 - Joe Galbraith (913) 551-7051
left message to call
out today
3/12/90 - Joe Galbraith (Resion VII) returned call
1. Aptus, Coffeeville, KS
10,000 Ib/hr is permitted sludge/solid maximum
5000-6000 Ib/hr is more realistic
2. Safetech, Chamois, MO
withdrew permit application on Friday
3 Ash Grove Cement, KS
John Ramsey (913) 296-1610 of KS State Office is familiar
-------
K-101
3/14/90 John Ramsey. KS State (913) 296-1610
1. Ash Grove Cement
met yesterday
connected with Cadence, Michigan City, IWD, who markets fuel to
Ash Grove (12 blenders)
currently IS storage
have recently added many codes to application, arguing that
derived from rule results in excessive coding of fuels
have submitted WAP
On Ash Grove/Cadence Process:
6 gal drums fed half way along 300 ft wet-process kiln
induction draft prohibits leakage from seal
last summer (1989) process operating at 1 of 2 kilns
rotation and drop rate is less than 3 or 4 RPM
has demonstrated fuel value (stopped dropping, had to increase
primary fuel)
wet kilns better than dry (longer)
Both KS kilns are wet process
believes NE kiln is wet process also
KS has 4 other cement kilns
2. Heartland Cement, Independence, KS
recently permitted
under construction
dry process kiln
will inject powderized solids
3. Lefarge, Ferdonia, KS
Systech operates waste system
currently grind and slurry solids for injection
Also have pyrolizor:
holds 12 drums
drums heated, vapors ducted to kiln
residues may be burned
permitted for nonhazardous solid waste, trying for hazardous
waste permit
4. Monarch Cement, Bonner Springs, KS
wants to burn powderized K061
5 Lone Star Cement Co., Edwardsville, KS
not burning hazardous wastes
no notification of plans to burn hazardous fuels
-------
K-102
REGION VIII
3/6/90 4:10
Nina Churchman (303) 293-1500
Aptus, Tooele UT (Westinghouse)
permit under public notice
should go final in April
sure thing
construction begun
expected on-line 2nd 4th 1991
fully commercial
plans to burn dioxins/furans and PCBs
capacity: RK 120 MBtu/hr
51, 000 tons/yr max
from TB Plan
solids (0-9000 Btu/lb)
sludge (0-9000 Btu/lb)
liquid (12,700 Btu/lb)
aqueous (0-400 Btu/lb)
16,000 Ib/hr
4,000 Ib/hr
10,178 Ib/hr
3,000 Ib/hr
6.
USPCI, Tooele, UT
county already burns nerve gas from military base
in NOD cycle phase
plans To burn dioxins/furans/PCBs
from applications (TB plan) (5 specified)
aqueous wastes (0-6.25 MMBtu) 13,000-27,000 Ib/hr
pumpable sludges (0-2.4 MMBtu) 0-4000 Ib/hr
solids (0-2.4 MMBtu) 0-4000 Ib/hr
<75,000 TPY solids, < 55,000 TPY sludge/solids
CoWest/CISCO, UT
not sited
very doubtful
no application submitted
Rollins, Lynndyl, UT
site abandoned
application on hold
not active
not likely before 1993
Combustion Technology
no application submitted
not before end of 1992
Aptus, Salt Lake City, UT
no info, probably not real
-------
K-103
BFI/CECOS, Last Chance, CO
just talk
not by 1992
ENSCO, Grouse Creek, UT
-canceled project
-------
K-104
REGION IX - (General (415) 556-6322)
3/5/90 ":05 pm - Larry Bowerman (415) 744-1471
1. Omega Chemical Corp., Whittier, CA
no application
dead project
2. ENSCO, Phoenix, AZ
new commercial site
Part B submitted
state expects to permit within 1 to 6 months
facility will consist of 3 mobile units
Total: (Exists TSCA permit)
100 MBTu/hr
50,000 TPY Max (L+S+S)
could be available 1991
3 CA Thermal Treatment, Vernon, CA
proposed greenfield site
permitted 1988
under appeal
RK 42 MBTU/hr
22,500 TPY Max
liquids only + pumpable sludges only
not constructed
1991 at earliest
4. CWM, Kettleman Hills, CA
proposed greenfield RK
50 MBtu/hr
33,000 TPY Max (application)
some application deficiencies
could be permitted 1990
could be on-line 1992 at earliest
5 Disposal Control, Caselton, NV
no application submitted
very preliminary
6 Environmental Technologies, Las Vegas, NV
never heard of
7 Omega Recylcing, Mendota, CA
no application
not sited
8. Stauffer Chemical (now Rhone -Poulenc), Martinez, CA
submitted application
some deficiencies
under review
possibly permit proposal by end of 1990
upgrade of sulfuric acid regeneration omit
250 MBtu/hr
-------
K-105
210,000 tons/r (rated)
will limit to 140,000 TPY (tentative agreement)
liquids only
9 ENSCO, Mobile/Phoenix (Marcicopa) , AZ
same as 2
10 AM Waste
never heard of
11. National Cement, Lebeck, CA
cement kiln
not currentLy RCRA
will burn liquids only
50 MBtu/hr
51,000 TPY
12. American Environmental Management, Rancho Cordova, CA
no application
no info
PCB only
13. Basil, NV
never heard of
14 Burnzall, NV
never heard of
15. IT - Vinehill (In Martinez)
closed
16 Koppleman, NV
never heard of
* NV doesn't want a hazardous waste incinerator
17 Poly-Garb Inc , NV
never heard of
18. Sol Pro, Lillyblad, NV
dead or dormant
19. United Agro. NV
never heard of
20. ET Tech ' NV
never heard of
21. WFU Equipment, NV
never heard of
-------
K-106
22. Wolfskill, CA
dead or dormant project
nothing heard in 4-5 years
23. Shell Oil, Martinez, CA
on-site only
liquids + sludges
4 units:
one RM17 (liquids) unit
short-term 10-30 tons/month
35-140 ton/yr
three carbon monoxide boilers
each:
liquids, some sludges (e.g.
10 gal/min maximum
24 Chevron, Richmond, CA
pesticide incinerator
on-site only
liquids only
100 TPY
DAF float)
3/6/90 5:40
Larry Bowerman, left message
3/7/90 5:45
Larry Bowerman
will ask Nahid Zoueshtiagh to get back to me next week when she
returns regarding CWM, Kettleman Hills, CA
(23) shell oil RM17's burn liquids only
(9) will ask Jim Burkamp to check into ENSCO, Phoenix, AZ
capacity breakout
(3) CA Thermal Treatment
Russ Beckman wrote permit
liquids only RK
3/12/90 1:25
Nahid Zoveshtiagh (Region IX permit writer) (415) 744-1471
spoke to Larry Bowerman
he will have permit writers for CWM, Kettleman Hills, and ENSCO,
Phoenix, find capacities and get back to me
-------
K-107
4/26/90 1:45 Larrv Bowerman, Region IX
1 Omega Energy, Maricopa, CA
Is a fuel burner (CAD981577661)
2 Chem Waste Management, Kettleman Hills, CA
Proposed expansion to existing facility
RiC
3 Sol Pro LillyBlad, NV
No application received
May not be dead project
-------
K-108
REGION X
3/2/90 5:40 - Cathv Massimino (206) 442-4153
on travel for 2 weeks
Carrie Sikoiski, Chief, will call back
3/5/90 7:35 pm - Margaret Small (206) 442-2804
1. ENSCO, AK
never heard of
2. Environmental Security Corp., Grant County, WA
commercial
much opposition
application submitted, responding to NODs
will burn sludge/solids
3 Environmental Control, WA
no information
4 Colman Metals, OR
PCBs only
5. Penberthy Electromelt
no application submitted
small subpart X thermal treatment facility
accepts organic wastes
currently operating
capacity unknown
6. Rackelshaus (Now ECOS)
application submitted
call state office (206) 459-6316), Tom Eaton
will resubmit this summer
2-4 years away
34,000 TPY RK (from Environmental Impact Statement)
call Tim Norred (438-7019
7 Special Resource, WA
never heard of
8. Rabanco, WA
34,000 TPY
make cement blocks
1992 at earliest
3/7 -'90 - Tom Easton (WA State) (206) 459-6316, left message
-------
K-109
EPA HEADQUARTERS
3/19/90 11:30 - Dwight Hluscick returned call
(working on Industrial Boiler and Furnace rules)
proposed reg shouldn't adversely affect Ash Grove
no insurmountable applicability problems for other kilns
for dry process kilns
demonstrated for pre-calculator dry process kiln
possible for pre-heater dry process kilns
possible for dry process only kilns
other kilns trying Ash Grove Process
maybe South Bend (name uncertain)
Southeastern Portland
Ash Grove contact is Eric Hansen
kilns rotate at around 2 RPMs
kilns don't generally shut down for periodic maintenance because
of startup problems
more common for 1 long down time if market slumps
some kilns fire directly from trucks
requirements for storage permit is usually > 10 days but vary's by
state
rule will limit stack emissions, not Btu/lb
kilns will require permit which limits conditions based on volumes
of product/fuel feed
-------
K-110
COMBUSTION CAPACITY FOLLOWUP ON
PUBLIC COMMENTS TO SUPPORT LDRs
PHONE LOG
Caller: Gary Light
Name of Contact: Dana Doerfler, CWM
Phone Number : (618) 271-2804
Title :
Location : Sauget, IL
Date : 4/4/90
Purpose of Call: Determine sludge/solid incineration capacity of CWM's
Sauget, IL facility
Report on Discussion:
Three units can each burn about 500 Ib/hr sludges and solids.
Fourth unit, a RK, can burn about 2000 Ib/hr of high Btu wastes
sludges and solids and 10,000-15,000 Ib/hr of low Btu wastes (like
soil). Usually burn 10,000 Ib/hr on average.
Facility operates 24 hours per day, 7 days a week.
Any Followup Planned: None.
-------
K-lll
COMBUSTION CAPACITY FOLLOWUP ON
PUBLIC COMMENTS TO SUPPORT LDRs
PHONE LOG
Caller: Gary Light
Name of Contact: Steve Enger, CWM
Phone Number : (312) 646-5700
Title : Technical Manager
Location : Chicago, IL
Date : 4/4/90
Purpose of Call: Determine sludge/solid capacity of CWM's Chicago, IL
incinerator
Report on Discussion:
Btu is limiting factor, permit allows up to 30 million Btu/hr,
which can all be non-liquids, fed at no more than 3 million Btu
per charge
At 20,000 Btu/lb, max feed is 1500 Ib/hr.
Most sludges and solids average 6000-7000 Btu/lb.
Soils can be fed at even higher rate.
Entire capacity could be used for RCRA sludges and solids.
Any Followup Planned: None
-------
K-112
COMBUSTION CAPACITY FOLLOWUP ON
PUBLIC COMMENTS TO SUPPORT LDRs
PHONE LOG
Caller: Gary Light
Name of Contact: Rusty Dunn, Rollins Environmental Services
Phone Number : (703) 930-2420
Title : Environmental Manager
Location : Deer Park, TX
Date ; 4/15/90
Purpose of Call: Clarify sludge/solid incineration capacity and grinding
capacity prior to stabilization.
Report on Discussion:
Second Rotary Reactor won't be available for 2 more years. It is
not constructed.
Rotary kilns typically burn 50 to 70X sludges and solids,
operating at permit limits.
Can burn as much as 100X sludge/solids for some low Btu wastes.
Permit did not reduce capacity, no reason why TSDR maximum
capacity estimates would have changed.
Currently designing a new stabilization facility that will include
grinding. Could be available in 6 months.
Any Follovup Planned: None.
-------
K-113
COMBUSTION CAPACITY FOLLOWUP ON
PUBLIC COMMENTS TO SUPPORT LDRs
PHONE LOG
Caller: Gary Light
Name of Contact: Bill Ziegler, American Nukem (ThermalKEM)
Phone Number : (803) 329-9690
Title :
Location : Rock Hill, SC
Date : 4/23/90
Purpose of Call: Clarify comment on EPA underestimating ThermalKEM's capacity
by a factor of 10.
Report on Discussion:
TSDR was submitted prior to trial burn which raised maximum heat
release from 19 to 42 mbtu/hr.
Facility can burn 80-85X solids in its modified fixed hearth unit.
No mass feed rate limits in permit, only thermal rating.
Normally burn sludge/solid/liquid blends ranging from 5000 to 8000
Btu/lb.
Operate 24 hours, 365 days, at 85X.
Have modified kiln to increase solids capacity:
Added oxygen enrichment system.
Added ram feed system.
Now transfer wastes from steel drums to fiber packs.
Have added new APC equipment.
Changes allowed increase in permitted ash content.
Any Followup Planned: None.
-------
K-114
FUEL BLENDING CAPACITY FOLLOWUP ON
PUBLIC COMMENTS TO SUPPORT LDRs
PHONE LOG
Caller: Gary Light
Name of Contact: Norman Foster, Petro-Chem Processing
Phone Number : (313) 824-5832
Title :
Location : Detroit, Michigan
Date : 4/3/90
Purpose of Call: Obtain description of fuel blending practices.
Report on Discussion:
1. 80% of sludges handled in container process system (GPS)
Drums drained in N2 environment
Sludge/solid residue "liquified" through sheading and blending
Good for paint residues but not polymer residues, cartridges, or
wrags
Wastes generally meet 5000 btu/lb if organic and contain less than
30-40% water
no dewatering performed
2 Other 20% sludge/solids handled in Cadence system
solids removed from drum, shreaded, blended, and placed in 6-
gallon drums with typically more then 8000 btu/lb
3 Any problems with K048-52?
Permit doesn't currently allow K048-52
API sludge might be less than 5000 btu/lb, but Phase II regs would
eliminate this problem
API sludge could be dewatered using a centrifuge to meet btu
requirements
4 Other kilns are "blowing" solids into kilns like coal dust mixtures.
5 Capacity?
More equipment being added later this year
No current capacity problems
Kilns can take about 60 Ib/minute
CPS can handle 40 drums/hr
liquids/solid system about 30 drums/hr
Capacity by end of year should reach 100 drums/hr
-------
K-115
Polymers are example of high btu solid chat can be suspended in liquid
form. Can suspend up to 50% solids if particle size is small enough.
1 gallon of liquid equal about 7 1/2 Ibs + 50% solids
Resulting blend can be aspirated to kiln
Very fine particles result in fuel with consistency of milk shake
Must have mixing at kiln and there may be settling problems during
transport.
Any Follovmp Planned:
-------
K-116
LIST OF ABBREVIATIONS USED IN PHONE LOGS
AB : After Burner
APCE : Air Pollution Control Equipment
D/F : Dioxins/Furans
DO : Department of
IS : Interim Status
LI : Liquid Injection (unit)
MGPY : Million Gallons per Year
NOD : Notice of Deficiency (in permit application)
RAF : Reuse as Fuel (Facility)
RK : Rotary Kiln
RPM : Rounds per Minute
RRK : Rotary Reactor Kiln
S/S/L : Sludges/Solids/Liquids
TB : Trial Burn
TPY : Tons per Year
UIW : Underground Injection Well
WWT : Wastewater Treatment
-------
APPENDIX L
MISCELLANEOUS PHONE LOGS
-------
sr4,
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20460
OFFICE OF
SOLID WASTE AND EMERGENCY
5 /990
MEMORANDUM
SUBJECT: Status of Facilities Treating Energetic Chemical Wastes
FROM: Benigna Carroll, Environmental Scientist
Land Disposal Branch
Waste Management Division
TO: The Administrative Record
On March 29, 1990, I spoke with Chester Oszman, Environmental
Engineer, U.S. EPA, OSWER, Alternative Technology and Support
Section, Permits and State Program Division. He said currently
there are more than 175 facilities seeking permits (subpart X
applications under RCRA) of which he estimates 150 facilities are
seeking to treat energetic chemical wastes. Many of these interim
status facilities currently are treating these wastes by open
burning/open detonation (OB/OD).
Mr. Oszman said final permit decisions are due by November 8,
1992 (Sec. 3005C RCRA).
L-l
-------
i sn.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 204«0
} ,-) i
0"'CE OF
SOLID WASTE AND
MEMORANDUM
SUBJECT: Telephone Conversation with Charles A. Marvin, Vice
President, The Refractories Institute, Pittsburgh, PA
(412-281-6787)
FROM: Benigna Carroll, Environmental S
Land Disposal Branch
Waste Management Division
TO: The Administrative Record
On Tuesday, April 24, 1990, I spoke with Mr. Marvin on the
characteristics and amounts of used hazardous waste chrome refinery
bricks.
Mr. Marvin said he had no direct information on the amounts
of chrome refractory wastes. However, from his experience as a
ceramic engineer and from general discussions with members of the
Institute he estimated approximately 12,500 tons annually of used
chrome refractory bricks (and shapes) are hazardous (by EPA's TCLP
test) and are currently land disposed. He said this was based o
the following:
130,000 tons of new chrome bricks (and shapes) are
manufactured each year.
90 - 95% of the new bricks (and shapes) go into old
furnaces. Thus, 117 - 123.5 tons of used bricks are
generated each year.
Chrome brick varies in chrome (chromite with some
chromic oxide) from 5 to 50% by weight. Thus, some used
brick would not be hazardous by the EPA test. Some
chrome brick is also recycled.
The Glass Packaging Institute, which represents a
fraction of chrome brick users, estimates that 2,500 tons
of hazardous chrome refractory brick is annually
i
L-2
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disposed of in landfills. Given this estimate, Mr.
Marvin considered the chrome brick user groups/industries
as follows and thereby arrived at his estimate for the
total amount of hazardous chrome refractory brick needing
alternative treatment capacity:
Group/Industry Tons* Comments
GPI 2,500 Packaging glass companies
Other Glass & Fiber 5,000 Architectural glass and
glass fiberglass not part of
GPI. These facilities
could generate 2 to 3
times the amount of wastes
GPI member facilities
generate.
Steel Industry 5,000 Largest user of refrac-
tories. Most not hazar-
dous by EPA toxics test.
Cement Industry 0 Industry grinds up used
(kilns) refractories and incor-
porates them into the
cement.
======
TOTAL ESTIMATE 12,500 Amount needing alternative
treatment capacity.
*Amount of chrome refractory brick (shape) which is hazardous and
landfi1led.
Mr. Marvin added, that from his discussions, waste treatment
companies required bricks (and shapes) to be ground to a 1/2 inch
fineness before they would accept the waste. He said most
generators who currently land dispose these bricks (and shapes) do
not have grinding capabilities.
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BERYLLIUM WASTE CAPACITY FOLLOWUP ON
PUBLIC COMMENTS TO SUPPORT LDRs
PHONE LOG
Caller: Scott Reed
Name of Contact: Mr. Richard Davis, Brush Wellman, Inc.
Phone Number: (216) 443-1000
Title: Manager, Environmental Affairs
Location: Cleveland, Ohio
Date: 4/26/90
Purpose of Call: P015 (Beryllium) Recovery.
Report on Discussion:
Mr. Davis discussed generation of P015 Beryllium waste. Beryllium ore
is refined to various concentrations of beryllium, depending upon the end use
To refine beryllium to these concentrations, the metal is pulverized into a
powder and then resolidified using "vacuum hot pressing techniques" In the
event of a spill of this powder (which would be a P015 waste), the
contaminated portion would be reintroduced to the refining system. Beryllium
waste can also be present in the wastewater treatment sludge. Mr. Davis
indicated that Brush Wellman recovered this beryllium waste through acid
leaching and solvent extraction technologies. Mr. Davis indicated that the
national volume of this waste was quite low, due to the economic value of the
metal, and that Brush Wellman would accept any beryllium waste for recovery
purposes.
Any Followup Planned: No followup planned.
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P AND U WASTE CAPACITY FOLLOWUP ON
PUBLIC COMMENTS TO SUPPORT LDRs
PHONE LOG
Caller: Scott Reed
Name of Contact: Mr. Rick Stalzer, BP Chemicals
Phone Number: (216) 586-5311
Title: Manager of Environmental Affairs
Location: Illinois
Date: 3/26/90
Purpose of Call: Determination Of Actual P And U Volumes At BP America
Facilities.
Report on Discussion:
Mr. Stalzer disagreed with EPA's methodology of adjusting P and U waste
volumes to 100,000 gallons at the point of generation for purposes of the
capacity analysis. However, BP Chemicals was unable to provide any hard data
to contradict EPA's assumptions. Mr. Stalzer reported that when a spill
occurred, as much of the material as possible was recovered, while
unrecoverable waste was washed down a separate system with water for disposal
via deepwell. Mr. Stalzer indicated that the addition of water in cleaning up
these spills greatly increased the P and U volume due to the mixture rule.
Mr Stalzer also reported that lawyers for BP America and EPA were currently
working to determine whether these wastes qualified for the mixture rule
exception under RCRA Section 261.3(a)(2)(iv).
Any Follovup Planned: No followup planned.
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P AND U WASTE CAPACITY FOLLOWUP ON
PUBLIC COMMENTS TO SUPPORT LDRs
PHONE LOG
Caller: Scott Reed
Name of Contact: Mr. Gary Rowen, Hoechst Celanese Corporation
Phone Number: (201) 231-4134
Title: Director, Environmental Affairs
Location:
Date: 3/21/90
Purpose of Call: Discussion of P And U Volumes Requiring Alternative
Treatment At Hoechst Celanese Facilities.
Report on Discussion:
Discussed Hoechst Celanese's concerns regarding the mixture rule
exception under RCRA Section 261.3(a)(2)(iv). Mr. Rowen indicated that
Hoechst Celanese was concerned that EPA was reinterpreting the mixture rule
exception, disallowing deepwell injection facilities from qualifying for the
de minimis exemption. Mr. Rowen reported, as in their comment letter, that
currently 600 million gallons of de minimis losses were deepwell injected
under the exemption, and that if EPA reinterpreted this section of the
regulations, this volume would require alternative treatment.
Any Follup Planned: Discussed this issue with Randy Hill, EPA Office of
General Counsel. EPA is clarifying when the mixture
rule exception applies, and is not reinterpreting the
exception itself. Hoechst Celanese remains exempt.
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P AND U WASTE CAPACITY FOLLOtfUP ON
PUBLIC COMMENTS TO SUPPORT LDRs
PHONE LOG
Caller: Scott Reed
Name of Contact: Dr. John Schneller III, American Cyanamid Company
Phone Number: (504) 431-9511
Title: General Manager, Services
Location: Westwego, LA
Date: 3/21/90
Purpose of Call: Determination Of Actual -P And U Volumes At American
Cyanamid.
Report on Discussion:
Discussion with Dr. Schneller verified that the volume of P and U wastes
prior to aggregation with storm water runoff and washwaters was 3.3 million
gallons. This volume represented a mixture of P and U waste along with water
used to clean up the spill. Volume generated is unclear. This volume is part
of a waste stream that is not considered hazardous waste since it qualifies
for the mixture rule exception under RCRA Section 261.3(a)(2)(iv). This
volume will not require alternative treatment for the Third Third land
disposal restrictions.
Any Followup Planned: No followup planned.
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D003 TREATMENT CAPACITY FOLLOWTJP ON
PUBLIC COMMENTS TO SUPPORT LDRs
PHONE LOG
Caller:
Name of Contact:
Phone Number:
Title:
Location:
Date :
Scott Reed
Mr. Richard Fortuna, Hazardous Waste Treatment Council
(202) 783-0870
Executive Director
1440 New York Ave., N.W., Washington D.C.
4/19/90
Purpose of Call: Treatment Capacity For D003 (Reactive Cyanide) Waste,
Report on Discussion:
EPA received a comment from HWTC disagreeing with the proposed national
capacity variance for deepwell-injected D003 (reactive cyanide) wastes. HWTC
stated that it had identified 400 million gallons of available treatment
capacity. No information regarding this capacity was provided. Attempted to
contact HWTC to discuss this capacity on 4/19/90, however Mr. Fortuna was out
for the day and did not return my call. Was also informed that no one else was
available to discuss comments on the Third Third rule.
Any Follup Planned:
No followup planned unless HWTC returns phonecall.
Comment provided insufficient data for evaluation.
L-8
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Caller:
Name of Contact:
Title:
Location:
Date :
Pupose of Call:
CAPACITY FOLLOW? ON PUBLIC COMMENTS
TO SUPPORT IDRs
PHONE LOG
Amanda Mondragon
Guy V. Johnson
Senior Counsel, Environment Group
Dupont: Wilmington, Delaware
April 27, 1990
To determine the quantity of high-organic barium land
disposed at the Dupont facility.
Report on Discussion:
Dupont's research facility generated approximately
1000 pounds (120 gallons) of high-organic barium in
1989. Unless research demands change dramatically, it
is unlikely that the volume of high-organic barium
generated will increase in the near future.
L-9
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Caller:
Name of Contact:
Title:
Location:
Date:
Pupose of Call:
Report on Discussion:
CAPACITY FOLLOWUP ON PUBLIC COMMENTS
TO SUPPORT LDRs
PHONE LOG
Amanda Mondragon
Kim Boudreaux
Unknown
Ethyl Corporation: Baton Rouge, LA
April 2, 1990
To determine the quantity of high-organic barium land
disposed at Ethyl Corporation.
Ethyl Corporation landfilled approximately 30 tons
(7,200 gallons) of high-organic barium in 1989. Ethyl
Corporation sent their high organic-barium waste to
the Preoria landfill in Preoria, Illinoius (EPA I.D
ILD000805812).
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CHROMIUM REFRACTORY BRICK CAPACITY FOLLOWUP ON
PUBLIC COMMENTS TO SUPPORT LDRs
PHONE LOG
Caller: Gary Light
Name of Contact: Arline Sheehan
Phone Number : (202) 467-7000
Title :
Location : Washington, D.C.
Date : 4/19/90
Purpose of Call: To clarify required capacity for chromium-refractory bricks.
Report on Discussion:
1. What fraction of the 9,000 to 10,000 tons of chromium brick generated
annually are land-disposed?
Something less than 25X of the reported volume was landfilled,
(speaking only of the container glass industry).
Many other industries (e.g. cement kilns, incinerators) also
generated the brick.
2. Does GPI's estimate include the volume reportedly generated by Owens
Corning Fiberglass (OCF)?
Estimate intended to cover the entire container glass industry,
but would not cover volumes generated by other types of glass
manufacturers (e.g., flat glass manufacturers).
A representative of Ovens Brockvay, a unit of Owens Illinois, was
one of 6 glass industry representatives who contributed to the
generation estimates.
3 Why does OCF's comment indicate that each furnace overhaul produces 50
tons of chromium refractory brick, when GPI's reported that 300 tons are
generated per furnace overhaul?
Six industry experts concurred on the 300 ton estimate, and
perhaps OCF does not produce container glass.
4. Who is the chromium refractory brick recycler in Magadore, Ohio?
Universal Materials Incorporated, (216) 628-2692.
5 What portion chromium refractory bricks contain high levels of
phosphorous or silicates?
Not sure, thought none contained phosphorous.
Also not sure of silicate levels, but guessed that all of the
refractory bricks might contain significant levels of silicates.
Suggested that I refer to the recently submitted analytical data
which she thought contains constituent analyses for the brick.
Any Followup Planned: None
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CADMIUM BATTERY CAPACITY FOLLOWUP ON
PUBLIC COMMENTS TO SUPPORT LDRs
PHONE LOG
Caller: Gary Light
Name of Contact: Mike Margolis, Kinsbursky Brothers
Phone Number : (714) 738-8516
Title :
Location : California
Date : 3/28/90
Purpose of Call: Obtain description and capacity estimates of cadmium battery
recovery process
Report on Discussion:
Kinsbursky does not have thermal recovery, but breaks and draws
batteries and sells nickel and cadmium plates to primary metals
producers.
INMETCO, in Elwood City, PA has thermal process for Ni/Cd
batteries
Kinsbursky is fully permitted to process 80,000 Ib/month and can
readily expand.
Other Recyclers:
Any Followup Planned:
None
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CADMIUM BATTERY CAPACITY FOLLOUUP'ON
PUBLIC COMMENTS TO SUPPORT LDRs
PHONE LOG
Caller: Gary LiEht
Name of Contact: Mike Margolis, Kinsbursky Brothers
Phone Number : (714) 738-8516
Title :
Location :
Date : 3/28/90
Purpose of Call: Obtain names of companies that buy cadmium battery parts
Report on Discussion:
The following companies buy Ni/C battery parts:
1. Big River Zinc, IL, buys cadmium plates
2. Inmetco, PA, may also buy cadmium plates
3. INCO, Ontario, CA buys nickel plates.
4. Glen Brook, Rittle, OR buys nickel plates.
5. Contact also mentioned the following lead acid battery processors
GNB, Los Angeles, CA
RSR, Qinmetco, Los Angeles, CA
Comirco, Trail, British Columbia
GNB and RSR, Dallas, TX
St. Josephs, Jefferson City, MO
Exide Battery, Muncie, IN and Reading, PA
RSR in Indianapolis IN and NY
Sanders lead, AL
Any Followup Planned:
None
L-13
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CADMIUM BATTERY CAPACITY FOLLOWUP ON
PUBLIC COMMENTS TO SUPPORT LDRs
PHONE LOG
Caller: Gary Light
Name of Contact: Guy Lucie, Big River Zinc
Phone Number : (618) 274-5000
Title :
Location :
Date :
Purpose of Call:
Sauget, IL
4/5/90
Determine Big River Zinc's capacity for recovery cadmium
from batteries
Report on Discussion:
Big River Zinc does thermally recover cadmium from large
industrial NI/Col batteries, but possible not from small ones.
Cadmium plates are received from intermediary battery processors
and Big River Zinc does not accept intact batteries or Nickel
plates.
Big River is not permitted to break batteries.
Believes most breakers are in Europe and Far East where batteries
are broken and the cadmium plates are shipped back to U.S.
SAB Nife, a Swedish company that produces batteries in Greenville,
NC accepts its own batteries after they are worn out. These
batteries are then sent to Sweden for recycling.
SAB contact is Bo Norling at (919) 830-1600.
Big River Zinc produces 3 million pounds per year of cadmium
oxides for batteries and plastic stabilization.
Big River has capacity to process 1 to 1 1/2 million pounds of
cadmium plates per year.
Kinsbursky is the only breaker in the U.S. that Mr. Lucie is aware
of.
Any Follovup Planned: None
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CADMIUM BATTERY CAPACITY FOLLOWUP ON
PUBLIC COMMENTS TO SUPPORT LDRs
PHONE LOG
Caller: Gary Light
Name of Contact: Thomas Janeck, Horsehead Resources
Phone Number : (412) 774-1020
Title :
Location : Pennsylvania
Date : 4/27/90
Purpose of Call: Identify cadmium battery recovery technology
Report on Discussion:
HRD does not recover Cd from batteries or battery parts.
Do recover cadmium from EAF dust and zinc concentrates (zinc
lead, and cadmium are recovered).
Primary product is zinc.
Any Followup Planned: None
L-15
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Date:
Caller:
Contact:
Title:
Company:
Location:
Number:
Purpose:
GRINDING AND STABILIZATION CAPACITY FOLLOWUP CALLS
THIRD THIRD RULE COMMENTS
4/24/90
Gary Light
Donald Stone
Regional Environmental Manager
GSX
Columbia, SC
803-798-2993
To determine whether stabilization facilities have grinding capacity.
Report:
No grinding capacity, but pug mill used in stabilization process reduces
particle size and totally encapsulates wastes. Two screw conveyors that
overlap mix and push waste through shafts. Believes they have probably
stabilized lead slag and matte. Suggested calling Larry Johnson at 803-452-
5003 for technical and specific operating information. Maximum permitted
capacity is 135,000 tons per year.
L-16
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Date:
Caller:
Contact:
Title:
Company:
Location:
Number:
GRINDING AND STABILIZATION CAPACITY FOLLOWUP CALLS
THIRD THIRD RULE COMMENTS
4/24/90
Gary Light
Richard Hill
US PC I
713-775-7800
Purpose:
To determine whether stabilization facilities have grinding capacity.
Report:
No grinding capacity at present, but class 1, 2, and 3 mod system would
allow modification without major permitting modification process. Pug mills
haven't worked well, a rock crusher/grinder (such as a jaw crusher) is
required. USPCI has explored grinding with a smelter who wasn't interested in
arranging for grinding additions. Bruce Boggs in Atlanta office has
researched grinding technologies (404-424-1900).
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GRINDING AND STABILIZATION CAPACITY FOLLOWUP CALLS
THIRD THIRD RULE COMMENTS
4/24/90
Gary Light
Gina Hartwell
Dace:
Caller:
Contact:
Title:
Company:
Location:
Number:
Purpose:
To deternine whether stabilization facilities have grinding capacity
Report:
Currently no grinding capacity. Should talk to Gene Mathews, not
currently available. Left message for Mr. Mathews to call.
Peoria Disposal
Peoria, IL
309-688-0760
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GRINDING AND STABILIZATION CAPACITY FOLLOWUP CALLS
THIRD THIRD RULE COMMENTS
Dace: 4/24/90
Caller: Gary Light
Contact: Mark Ecsedy
Title:
Company: Environmental Waste Resources
Location: CT
Number: 203-755-2283
Purpose:
To determine whether stabilization facilities have grinding capacity
Report:
No shredding or grinding prior to stabilization.
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GRINDING AND STABILIZATION CAPACITY FOLLOWUP CALLS
THIRD THIRD RULE COMMENTS
Date: 4/24/90
Caller: Gary Light
Contact: Tim Welsh
Title:
Company: Frontier Chemical Waste Processes, Inc.
Location:
Number: 716-285-2581
Purpose:
To determine whether stabilization facilities have grinding capacity
Report:
Only stabilization is for D001, grinding is used for fuel blending.
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GRINDING AND STABILIZATION CAPACITY FOLLOWUP CALLS
THIRD THIRD RULE COMMENTS
Dace: 4/25/90
Caller: Gary Light
Contact: Rusty Dunn
Title: Environmental Manager
Company: Rollins Environmental Services
Location: Baton Rouge, LA
Number: 504-778-3549
Purpose:
To determine whether stabilization facilities have grinding capacity.
Report:
Rollins does not currently have grinding capacity for wastes destined
for stabilization. A new stabilization process is being developed that will
include a shaker screen, grinder, and pug mill to mix wastes with pozzolonic
stabilizing agents. This process will come on line in September or October of
this year.
L-21
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Date :
Caller:
Contact:
Title:
GRINDING AND STABILIZATION CAPACITY FOLLOWUP CALLS
THIRD THIRD RULE COMMENTS
4/25/90
Gary Light
Mike Joseph
Company: Erieway, Incorporated
Location: Ohio
Number:
Purpose:
216-439-1257
To determine whether stabilization facilities have grinding capacity
Report:
Erieway received RCRA permit in January, 1990. Conditions require
eliminating waste pile and reconstructing stabilization area. Stabilization
area will be closed for reconstruction. No grinding capacity now, except for
a small shredder. New process is being designed for 8 to 20 tons/hour
(different units). This process will include grinding, and could be on-line
by the end of 1991.
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Chromium Refractory Brick Capacity Followup On
Public Comments to Support LDRs
Caller: Gary Light
Name of Contact: Russ Bleakney and John Onuska, INMETCO
Phone Number: 412-758-2210
Location: Ellicot City, PA
Date: April 20, 1990
Purpose of Call:To obtain description and capacity data for INMETCO's chromium brick recovery
process.
Report on Discussion:
THE PROCESS
Mr. Bleakney described the system as a recovery process for iron, nickel, and chromium.
Chromium-bearing refractory bricks are crushed and fed to a rotary hearth kiln. From the kiln they are
sent to a submerged electric arc furnace (EAF) where they are melted and high chromium remelt alloy
"pigs" These "pigs" are then sold as scrap to stainless steel manufacturers. The nonhazardous slag
byproduct is (primarily alumina) is sold as road-base aggregate.
CAPACITY
Mr Bleakney estimated maximum crushing capacity at 40 tons per day or 1200 tons per month.
About 200 tons per month are required for currently processed wastes. Mr. Bleakney thought that the
EAF was the limiting process of the system, with about 1000 tons per month maximum and about 500
tons available capacity. INMETCO currently processes about 20 tons of chromium refractory brick per
month on average.
SPECIAL RESTRICTIONS
Phosphorous presents a problem because it is contained in product. Product specifications
require less than 0.055 % phosphorous. As a result, INMETCO generally accepts wastes with no more
than 0.1 % phosphorous (0.03 is ideal), but high phosphorous wastes can be mixed with low to limit the
phosphorous content of the product. The limit -is a matter of economics in that INMETCO would have
to charge more to accept high phosphorous wastes.
Economics also determine minimum chromium content requirements. The lower the chromium
content the higher the price to generators. At 5% chromium or less, INMETCO's fee is generally
higher than landfill disposal. Mr. Onuska pointed out that about 80% of the chromium can be
recovered regardless of initial concentration (he added that byproduct waste production is about three
times the volume input). INMETCO currently abides by a self imposed lower limit of 1.2% nickel
and/or chromium to justify legitimate recycling.
Silica content also effects costs and economic feasibility. For each pound of silica in the feed
stream, they must add a pound of lime to maintain basicity. INMETCO generally does not process
materials containing higher than 9% silica. Surface cleaning can generally eliminate silica problems
L-23
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since most of the silica is contained in surface residue.
There are many different types of refractory bricks used by glass industry (and others); Mr.
Onuska was aware of about 12 types and many more trade names! In general, INMETCO processes
"chrome magnesite refractories". Which are defined as those:
1. Contain more than 20% Cr2O3;
2. Contain more than 2% MgO;
3. Contain less than 60% A12O3;
4. Contain less than 9% silica (SiO2);
5. Contain less than 0.03% phosphorous (P2O5).
"Porous Chrome", and "Chrome Oxide" bricks can be processed, but in general they are recycled
by brick manufacturers to make lower grade products (e.g. fuse chrome) because of their high chromium
content. "Bonded chrome" can be processed but at a high cost due to high phosphorous content. Many
types of refractory bricks have not been tested.
L-24
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LEAD SMELTING CAPACITY FOLLOWUP CALLS
THIRD THIRD RULE COMMENTS
Dace: 4/24/90
Caller: Gary Light
Contact: Michael Sappington
Title:
Company: Lake Engineering (completed TSDR Survey for Sanders Lead)
Location: Atlanta, GA
Number: 404-257-9634
Purpose:
To determine capacity impacts if staging piles at secondary lead
smelters are considered land disposal, and/or these piles must meet
requirements for hazardous waste storage. Also, to clarify volumes and
management practices for slag and matte from secondary smelters.
Report:
Mr. Sappington indicated that Sanders had applied for an exemption from
the definition of solid waste for materials stored prior to recycling. He was
not familiar with recent activities at Sanders, and suggested I speak to Roy
Baggett, Environmental Coordinator for Sanders, at 205-566-1563.
Mr. Sappington said he was familiar with GNB's smelting operations in
Columbus, GA; Frisco, TX; and Los Angeles, CA. The TX and CA facilities are
currently operating under IS, and the GA facility is fully permitted. Contact
did not know capacities exactly, but said that GA produces 16,000 tons per
year of product and probably processes 28,000 tons/yr of batteries and 4000 to
5000 tons/yr of other wastes. Contact thought that all GNB facilities are
operating at close to capacity since lead prices are high, and that adding 5
to 10 percent would be stretching. Air permit is often binding constraint.
Mr. Sappington indicated that GNB informally assumes their staging piles
are exempt in permit application as in process raw materials storage. Many
states consider these materials to be wastes.
L-25
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LEAD SMELTING CAPACITY FOLLOWUP CALLS
THIPJ) THIRD RULE COMMENTS
Dace: 4/24/90
Caller: Gary Light
Contact: Roy Baggett
Title: Environmental Coordinator
Company: Sanders Lead
Location: Troy, AL
Number: 205-566-1563
Purpose: To determine capacity impacts if staging piles at secondary lead
smelters are considered land disposal, and/or these piles must meet
requirements for hazardous waste storage. Also, to clarify volumes and
management practices for slag and matte from secondary smelters. Also to
verify that none of the D006 in sanders' waste pile is actually cadmium
batteries.
Report:
D006 in WASTE PILE
Mr. Baggett confirmed that none of the D006 reported in TSDR Survey was
from cadmium batteries.
STAGING PILE STATUS
The staging pile is not exempt, but is permitted as hazardous waste
storage area (double liner, leachate collection and treatment system etc).
CAPACITY
Last week Sanders cut 1109790 Ib/day of batteries on average. Maximum
is 2,000,000 Ib/day. Capacity is limited by acid generation discharge from WW
treatment system, and blast furnace capacity (about equal). Each of four
units produces 80 tons per day of product operating at about 90X capacity
About 0.7 tons of product are produced per 1 ton of batteries, and plant
operates 365 days per year. (80 tons/day/unit) x (4 units) / (0.7 tons
battery per ton product) x (365 days/yr) - 166,857 tons/yr currently
processed. @ 90 X capacity, maximum capacity is 185,397;and available is
18,540 tons/yr.
SUVG and MATTE
Matte is often recycled as pig iron replacement, but slag is sent to hazardous
landfill. Slag contains 10 to 15X lead, and can be stabilized to meet
characteristic; but must first be crushed. Sanders expects to have onsite
L-26
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capacity to crush and stabilize all generated slag by May 8, 1990 (already
permitted) Will not accept wastes commercially.
L-27
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LEAD SMELTING CAPACITY FOLLOWUP CALLS
THIRD THIRD RULE COMMENTS
Date: 4/24/90
Caller: Gary Light
Contact: Gerald Dumas
Title: Environmental Affairs Director
Company: RSR Corporation
Location: Indianapolis, IN; City of Industry, CA; an- Middletown, NY
Number: 214-631-6070
Purpose:
To determine capacity impacts if staging piles at secondary lead
smelters are considered land disposal, and/or these piles must meet
requirements for hazardous waste storage.
Report:
RSR operates three secondary smelting, facilities: NYD030485288,
CAD066233966, IND000199653. Not in TSDR Data set because completed generator
survey? Main input material is auto batteries (with some industrial and other
batteries) and other lead-bearing materials (e.g. battery manufacturing
wastes)
STAGING PILE STATUS
All 3 facilities have considered exemption. NY has applied, and is still
waiting and IN has been denied because of other state litigation. Believes
problem with exemption is that states were given opportunity with little
guidance from EPA. States are reluctant to act. Wastes currently stored in
piles, too dense for tanks, could result in closure if prohibited by third
third. NY and CA have similar storage facilities: concrete slabs with run-
on/runoff collection and WWT. Materials are stored in bins. New storage
building being designed for CA. At IN facility, materials are stored in
building on concrete with collection system. Currently not certain if storage
in building satisfies storage requirements. If so, NY and CA would build
enclosures; but not possible by May 8, 1990. NY may still get permit or
variance. CA is under federal and state consent order and hasn't filed for
variance. Storage areas for intact batteries are currently IS.
CAPACITY
Faxing information
L-28
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LEAD SMELTING CAPACITY FOLLOWUP CALLS
THIRD THIRD RULE COMMENTS
Date: 4/24/90
Caller: Gary Light
Contact: Jeffrey Leed
Title:
Company: Exide Corporation (General Battery)
Location: Reading, PA; Dallas, TX; andMuncie, IN
Number: 215-378-0852
Purpose:
To determine capacity impacts if staging piles at secondary lead
smelters are considered land disposal, and/or these piles must meet
requirements for hazardous waste storage. Also, to clarify volumes and
management practices for slag and matte from secondary smelters.
Report:
Exide operates 3 secondary lead smelting facilities not in TSDR:
PAD990753089, TXD068999622, and IND000717959. Contact believes generator
survey was submitted for PA and TX, but IN was purchased and reconstructed
since 1987. Each facility has a permitted or IS storage area for spent
batteries or containers (used for intact batteries).
STAGING PILE STATUS
PA facility is regulated under reuse permit, for which application was
submitted more than two years ago. Waste pile area requires state DER permit
and may need RCRA permit. Storage pile is specified in permit, not sure of
impact of third third. Storage area has concrete surface with runoff
collection, is under roof, and is operated under negative pressure.
For IN facility, variance is granted but interpretation is unclear.
Currently believe exemption only applies to batteries broken on site
(indigenous to process). Off-site battery parts and other lead scrap not
exempt. Storage area has been included in Part B application submitted 2/90.
Permit would regulate storage area as waste pile in building (includes truck
wheel washing)
TX facility is currently under IS, Part B submitted 1986 (/). Staging
pile addressed as waste pile. Are awaiting state action before applying for
variance. Facility has been ordered to close by City of Dallas by 12/31/90
for noncompliance with recent zoning changes. Closure being appealed.
L-29
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L-30
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CAPACITY
PA facility data from generator survey (1986 data)
1986 volume processed (tons/yr)
Batteries 51,000
Non-hazardous materials 5,200
Hazardous wastes (offsite) 1,591
typical feed rate to furnace: 3340 Ib/hr
maximum feed rate to furnace: 3750 Ib/hr (i.e., 89X utilized)
TX facility data from generator survey (1986 data)
1986 volume processed (tons/yr)
Batteries 26,000
Non-hazardous materials 1,416
Hazardous Wastes 769
typical and maximum feed rate to furnace: 11,667 Ib/hr (i.e. , 100X
utilized)
IN Facility (estimated)
Goal within 1 year to process 20,000 batteries per day (- 95,000
tons/yr). More capacity is technically possible. Currently processing
between 8000 and 10,000 batteries/day (i.e., SOX utilized).
L-31
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SL\G AND MATTE
Some slag greater than 2.5X lead. Currently looking for ways to cycle
slag back to smelter. If possible, this will reduce capacity. PA facility
generates 8000 to 9000 tons to slag and matte per year, which is sent to an
out-of-state hazardous waste landfill. No crushing or grinding capacity is
available on-site-- no room for baghouses, and grinding produces dust
problems. Should use sane slag and matte ratios to determine generation at
other facilities.
L-32
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LEAD SMELTING CAPACITY FOLLOWUP CALLS
THIRD THIRD RULE COMMENTS
Date: 4/24/90
Caller: Gary Light
Contact: Ken Pike
Title:
Company: East Penn Manufacturing
Location: PA
Number: 215-682-6361
Purpose:
To determine capacity impacts if staging piles at secondary lead
smelters are considered land disposal, and/or these piles must meet
requirements for hazardous waste storage. Also, to clarify volumes and
management practices for slag and matte from secondary smelters.
Report:
STAGING PILE STATUS
Intact batteries stored on ground, but very few are stored before
breaking. Broken battery parts and other materials stored in fully permitted
totally enclosed material storage area (with runoff collection and WWT)
CAPACITY
Second furnace added to single facility. Currently operating at maximum
permitted capacity of 42,000 short tons/yr product. ( equivalent to about 4
million batteries) Could produce up to 60,000 tons/yr, but would require
permit mod.
L-33
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SLAG AND MATTfi
Slag and matte currently sent to hazardous waste landfill in Michigan.
Has unsuccessfully tried many thermal recovery techniques for slag and matte.
Proposed recovery standard would force facility to close. Fixation is
possible. About 20 to 25 tons/day of slag and matte generated 10 days out of
every 14 days. Equivalent of 15 to 202 product output generated as slag and
matte, believed typical of industry (using reverbetory furnace followed by
blast furnace). Exception may be RSR who replaced blast furnace with electric
arc furnace and generates slag that allegedly passes TCLP as nonhazardous.
Stabilization would require grinding to less than 1/2 inch in diameter,
current crusher (previously used to grind slag into cement aggregate for use
onsite) can't reach 1/2 inch diameter Readily available equipment (roll
clone crusher) would have to replace existing jaw crusher. Permit
modification would take about 18 months, and construction would take about 4
to 6 months.
L-34
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LEAD SMELTING CAPACITY FOLLOWUP CALLS
THIRD THIRD RULE COMMENTS
Date: 4/24/90
Caller: Gary Light
Contact: Glenn Hasse
Title: Vice President
Company: Schuylkill Metals
Location: Baton Rouge, LA and MO
Number: 504-775-3040
Purpose:
To determine capacity impacts if staging piles at secondary lead
smelters are considered land disposal, and/or these piles must meet
requirements for hazardous waste storage. Also, to clarify volumes and
management practices for slag and matte from secondary smelters.
Report:
STAGING PILE STATUS
MO facility has permitted waste pile. LA facility is under IS, and
variance petition has been in process since 1986. Problem is overburden of
state. Variance was granted for battery parts only before 1986, trying now to
get variance redefined for current operation. Believes currently exempt by
variance but not certain. State just called in Part B application. MO
storage area is about the same as LA. Would like national variance for waste
piles .
CAPACITY
New furnace added to LA facility added 60,000 to 70,000 tons/yr of
capacity to estimates in TSDR Survey. Currently 1002 utilized.
L-35
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SLAG AND MftTTfr
_MO generates about 30 tons/day and LA about 60 tons/day (30 to 70X
landfilled). Operates 7 days per week. No grinding capacity in industry or
at^landfills. Solidified "buttons" currently broken up with sledge hammers
prior to disposal. Both facilities dispose of slag and matte in on-site
landfills.
L-36
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STERLING CHEMICALS
February 14, 1990
Ms. Jo-Ann Bassie
Office of Solid Waste (OS-322)
U. S. Environmental Protection Agency
401 M Street S.W.
Washington, DC 20460
Dear Ms. Bassie,
Thank you for speaking with me on January 30 regarding Sterling Chemicals
comments that were submitted on January 8, 1990. I have enclosed excerpts of
these comments with the areas discussed with you highlighted. I trust that the
data provided will be carefully reviewed and used to justify the requested national
capacity variances (NCV).
My specific requests made in that conversation were:
1) A NCV for underground injection of D003a and D002 nonwastewater be
granted,
2) Resolution of the NCV/MTR problem with D003a and D002 wastewaters,
3) Once 2) is resolved, a NCV for D003a and D002 wastewaters,
4) Careful review of the Sterling comments.
I believe that the need for each of the above requests are well documented in
Sterling Chemicals' comments. Please contact me at (409) 942-3129 if you require
clarification of the data.
Sincerely,
David W. Dunn, P.E.
Environmental Affairs Manager
/pm
Attachment
cc: Francoise Brassiere - USEPA-ODW
Bruce Kobelski - USEPA-ODW
Mike Cook - USEPA-ODW
DWD005.1«
Sterna C^e^'Ca's nc L-37
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January 8, 1990
Page 15
Failing r consideration of the standard, Sterling Chemicals
requests a national capacity variance fee this class- of
hasardous waste. £44 discussion in &.A.3. above concerning
the questionable value of a varianca* f4hssv,aV AiHion gallon
vast* straaa for Starling Chaaicalt floos would raquira
further traatmant to »*at tJia propOM«t BOAT standards, and
tha Agancy lists only 2 Billion gallons p«r yaar of nation-
wida availabla capacity (Tabla III B.l.(c)).
Sterling Chemicals appreciates the opportunity to comment on
the proposed rule.
Very truly yours,
David W. Dunn, P.E.
Environmental Affairs Manager
Sterling Chemicals, Inc.
L-46
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APPENDIX M
ANALYSIS OF LARGE VOLUME UNDERGROUND INJECTED P AND U CODED WASTES
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APPENDIX M
ANALYSIS OF LARGE VOLUME UNDERGROUND INJECTED P AND U CODED WASTES
In support of the Third Third final rule, the Agency conducted a special
analysis of certain large volume P and U coded waste streams reported as
deepwell injected in the TSDR Survey. The purpose of this analysis was to
gather additional data on the generation, characteristics, and current
management of these waste streams. The Agency suspected that these streams,
as generated, were actually small volumes of hazardous wastes mixed with large
volumes of aqueous wastes, therefore making the entire mixture hazardous.
The following facility summaries document the results of the analysis
for each of the contacted facilities.
Aristech Chemical Corporation. The facility contact stated that
its P and U wastes are generated separately but share a common
collection system. Furthermore, he said that some of the P and U
wastes are "off-spec" products but most are spill residues. As
injected, he said the wastes are composed of small amounts of P
and U waste contaminated with large volumes of nonhazardous
process wastewaters (the contact was unable to provide the
percentage that was hazardous vs. nonhazardous). In addition, as
part of the facility's wastewater treatment system prior to the
well, insoluble organics are removed and recycled or reused as
fuel. Finally, he said the facility was investigating whether the
waste may qualify for a "de minimis" exemption.
American Cvanamid. The contact stated that as injected the stream
is 99 percent water and only hazardous because of the mixture
rule. She also said many of the U codes may qualify for the de
minimis exemption, but they carried the codes to be safe. She
said the waste is mainly generated from storm water, minor spills,
and backwashing the well's filters.
M-l
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Rubison Incorporated. The contact stated that the P and U coded
waste streams are mostly water as injected (although he did not
know the percentage) and that the wastes are hazardous because of
the mixture rule. He said the wastes are generated by minor
spills, process upsets, and as scrubber water He said they do
analyze the waste prior to injection and the concentration of P
and U code constituents are typically in the low part per million
range.
Calanese Chemical Company. Although this facility refused to
provide detailed information without a formal written request, the
contact stated that their underground injected wastes consisted of
very small portions of hazardous waste mixed with large volumes of
water
Cecos International. The facility contact stated that this waste
is rainwater drained from the surface of an active landfill (it is
not leachate which has percolated through a closed landfill) He
said the stream is virtually all rainwater and the concentration
of the U coded constituents is less than 50 parts per million.
The waste is received from offsite.
In addition, one CBI facility was contacted. The facility contact
stated that the waste stream reported as injected in the TSDR Survey was the
result of the cleanout of a surface impoundment and consisted mainly of
rainwater. He said they are still injecting wastes but that they are
exclusively mixture rule wastes consisting mostly of water.
Based on the information received from these facilities, EPA believes
that the actual volume of P and U wastes generated by these facilities is
significantly less than the volume reported as underground injected. The
Agency believes that 100,000 gallons per year is a reasonable upper estimate
of the volume of these P and U wastes that are generated prior to mixture with
other wastes.
M-2
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ecause the land disposal restrictions apply to wastes at the point of
ration, the Agency believes' that only the originally generated P and U
volumes should be used to estimate required capacity Consequently,
gency used 100,000 gallons per year per code as an upper estimate of the
required capacity for P and U wastes at these facilities.
M-3
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