HAZARDOUS HASTE MANAGEMENT IN THE NORTHWEST:
A STATUS REPORT
Prepared for the
U.S. Environmental Protection Agency Region 10
and the States of
Alaska, Idaho, Oregon and Washington
BY
LEE H. STOKES,
August 198]
-------
TABLE OF CONTENTS
PAGE
Executive Summary i-v
Introduction.
Methodol ogy 8
Hazardous Waste Generation 12
Disposition of Hazardous Waste 40
Polychlorlnated biphenyls
(PCB) 59
Projected Hazardous Waste Generation 72
Hazardous Waste Management Technology 87
Waste Management Capacity 103
Problems/Recommendations 114
References 121
-------
LIST OF TABLES
TITLE Page'
1. Registered Generator Status, Region 10, 1985 ' 15»
2. Categories of Major Generators, Region 10, 1985 15
3. Reported Hazardous Waste Generation by Major Sources, 1985 22
4. Reported Hazardous Waste Generation, Region 10, 1985
(Exclusive of NPDES Wastewaters) 24
5. Physical Composition of Hazardous Waste, Washington, 1985 24
6. Characterization of Hazardous Waste, Region 10, 1985 (Tons) 34
7. Characterization of Hazardous Waste, Region 10, 1985 (Percentage) 35
8. Treatment, Storage and Disposal Facilities, Region 10, 1985 42
9. Reported Disposition of Hazardous Waste Generated in Region 10,
1985, Tons 44
10. Import and Export of Hazardous Waste, Region 10 States, 1985, Tons 47
>1. Reported Handling of Hazardous Waste from All Sources at Region 10
Facilities, 1985, Tons 54
12. Annual PCS Waste Generation and Disposal Reported by 58 Electrical
Utilities, Region 10, 1985/1986 64
13. Estimated PCS Waste Generation Pattern, 58 Electrical Utilities,
Region 10 66
14. Estimated PCS Waste Generation, Region 10, 1985, All Sources 66
15. Estimated Effects of Variable Factors on Future Hazardous Waste
Generation, Region 10 74
16. Current and Future Hazardous Waste Management Technology, Region 10 88
17. Estimated Maximum Potential Landfill Ban, Region 10, Based on 1985
Generation Data (Tons) 100
18. On-site Hazardous Waste Management Facilities, Approximate Proposed
Permit Capaci ty. Region 10 105
19. Off-site Hazardous Waste Management Facilities, Approximate Proposed
Permit Capacity, Region 10 107
-------
LIST OF FIGURES
Title Page
1. Categories of Major Hazardous Waste Generators, Alaska 17
2. Categories of Major Hazardous Waste Generators, Idaho 18
3. Categories of Major Hazardous Waste Generators, Oregon 19
4. Categories of Major Hazardous Waste Generators, Washington 20
5. Hazardous Waste Generation, Region'10, 1985
-------
HAZARDOUS WASTE MANAGEMENT IN THE NORTHWEST
A STATUS REPORT
EXECUTIVE SUMMARY
AUGUST, 1987
Hazardous waste management data are collected and analyzed independently
and in somewhat disparate fashion by the Region 10 offices of the U.S.
Environmental Protection Agency and the pollution control agencies of the
northwest states. Accurate and comprehensive information regarding hazardous
waste generation and management will be needed soon if the industries and
governmental entities of the region are to establish a coordinated planning
program capable of identifying cost-effective means of compliance with new
statutory mandates. One important aspect of the emerging regulatory program
is the requirement that states demonstrate by 1989 that disposal capacity will
be available for all hazardous wastes expected to be generated in the next 20
years. Certification to that effect will be necessary if a state is to remain
eligible for remedial action funding through the provisions of the
Comprehensive Environmental Response, Compensation, and Liability Act.
An assessment of the status of hazardous waste and PCS waste control
programs in Region 10 was conducted in an attempt to characterize the
materials and current handling methods and to consolidate waste management
data from the four states (Alaska, Idaho, Oregon, Washington). The nature and
effectiveness of the data collection systems were also examined.
Hazardous Waste Generation
The most recent biennial reports (1985) and other documents were reviewed
so that sources and amounts of waste regulated pursuant to-the Resource
Conservation and Recovery Act and companion state laws could be determined.
Eight hundred eighty-two major generators produced reportable quantities of
hazardous waste during 1985 (Alaska, 23; Idaho, 30; Oregon, 206; Washington,
623). Fifty-seven percent of the generators were manufacturing plants and 29%
were trade, services or governmental organizations.
The Region 10 major generators reported 228,910 tons of hazardous waste,
exclusive of PCBs. Washington contributed 198,464 tons (86.7%); Oregon ,
26,813 tons (11.77.); Idaho, 2024 tons (0.91); and Alaska, 1609 tons (0.7%).
Small quantity generators produced an additional 11,000-12,000 tons of waste,
and 30,000-60,000 tons of unregulated hazardous waste from households were
sent mostly to public solid waste landfills.
Manufacturing industries accounted for 867. of the waste, the largest
fraction (37.51) coming from primary and secondary metals processors. Stone
and clay products industries produced 15.37. of the waste, transportation
equipment manufacturers 10.37., and the electronics companies 4.5%. Only about
two percent of the waste came from cleanup of contaminated sites in 1985 (in
1984, the figure was nearly 20%).
Almost one-half of the wastes were those regulated only by the State of
Washington (104,349 tons, 46%), such as cement kiln dust, furnace black dross
and potlining from the aluminum industry, boiler fly-ash from the wood
products industry and fluxing salts from magnesium reduction. The dominant
RCRA-regulated wastes were metals (147.), corrosives (97.), electroplating
sludge (8%), steel emission dust (47.) and non-chlorinated solvents (47.).
-------
Disposition of Hazardous Waste
The Region 10 states ship waste to one another and to facilities in other
states for treatment and disposal. Waste is also imported to the region for
disposal. Nearly 10,000 tons of waste were exported from the region in 1985,
while 3694 tons were imported; thus, the region was a net exporter of
hazardous waste. Alaska exported 10% of its waste to other Region 10 states
and 40% to states outside the region. Idaho exported one-half of its waste to
Oregon and Washington and 38% to states outside the region, but also imported
twice as much waste for disposal as was exported. Oregon exported over
one-half of its waste (15,000 tons), but imported nearly 66,000 tons for
disposal, most of which came from Washington.
Region 10 wastes are often subjected to a series of reportable management
processes; the reports of each management practice result in double or triple
counting of some wastes, and therefore the generator and facility reports
cannot be easily reconciled. Imported wastes cannot be specifically tracked
either. Thus, the waste facility reports document the handling of
substantially more waste than is generated in a given year.
On-site storage (for over 90 days) accounted for 107,000 tons of waste in
the region in 1985 and 75,000 tons were stored off-site. The predominant
storage method (by weight) was waste piles. Nearly 10,000 tons of waste
received on-site treatment and 49,000 tons were treated off-site. On-site
disposal of 63,000 tons of waste was accomplished, while 77,000 tons were
disposed of at off-site facilities. Over 100,000 tons of Region 10 wastes
were landfilled and 45,000 tons were impounded as a treatment process or final
disposal; 1111 tons of waste were deep well injected in Alaska.
PCBs
Wastes containing polychlorinated biphenyls were considered separately
since they are regulated by the Toxic Substances Control Act rather than as
RCRA hazardous wastes. A limited special survey of electrical utilities and
other waste generators provided new insight regarding PCS waste generation in
Region 10. Concentrated PCS waste oils (greater than 500 ppm PCB) were
apparently generated in an amount falling within the range of 450-550 tons in
1985. Mineral oil wastes with PCB concentrations from 50-500 ppm may have
totaled 1200-1600 tons.
Disposal of waste transformer carcasses was estimated to amount to
2000-4000 tons. PCB-contaminted soil, debris and miscellaneous equipment
constituted 2000-3000 tons of waste. The generation of high concentration PCB
oil wastes in Region 10 is expected to increase slightly until 1988, remain
fairly constant until 1991, and then decline precipitously due to several
regulatory-factors. The lesser-contaminated mineral oils, mostly present in
long-lived transformers, will remain in the waste stream in slowly declining
amounts for 15-30 years. PCBs are no longer being manufactured and have not
been distributed in commerce for some time; .however, remedial action projects,
particularly in Alaska, will generate PCB wastes for 10 years or more.
-------
Projected Hazardous Haste Generation
Several elusive factors affecting the future generation of hazardous
waste In the region were crudely estimated as part of this assessment.
Economic growth, waste reduction practices, PCB equipment phaseouts and
Implementation of remedial action (site cleanup) programs were projected to
produce a small net Increase In waste generation over the 1985 level during
the next 20 years. The routinely generated wastes (non-cleanup) are expected
to decrease somewhat in the next 15 years due to waste reduction programs, but
ultimately Increase from the 1985 base amount as a result of Industrial
growth; however, the projection of other quite different scenarios could be
easily justified.
Hazardous Waste Management Technology
The Region 10 hazardous waste streams were generally analyzed in terms of
the applicability of alternative technology because of the. Impending limited
national ban on landfill ing of wastes. One hundred twenty-six thousand tons
of Region 10 RCRA-regulated wastes (based on 1985 data) will be considered for
landfill ban by 1990 though the EPA regulatory process. Less than half of
that waste is being lanufilled now (other than Washington-regulated waste).
Including contaminated soils, up to 60,000 tons of hazardous waste per
year might be amenable to incineration; however, two-thirds of that waste
would probably require fuel-assisted burning due to low potential heat
content. Wastes to be Jandfilled could increase or decrease depending on
economic factors arising from the treatment standards (most not yet
established) associated with the landfill ban statute. Increased recycling
and treatment of some categories of waste are probable. However, alternatives
to landfilling will not be readily available for some wastes, and the
stabilization and encapsulation processes which might be applied to those
wastes would substantially increase their volume prior to landfilling.
Waste Management Capacity
A review of waste management facility permit applications revealed a
potential regional on-site capacity for waste storage to be nearly 280,000
tons, far more space than actually occupied in 1985. On-site treatment
facilities would handle over 30,000 tons of waste per year, other than dilute
aqueous wastes which can be treated in very large volumes. Proposed on-site
incinerator capacity totals 4700 tons per year. Permit applications for
on-site disposal reflect facilities capable of handling three trillion tons of
wastewater per year by injection well (Alaska only), 57,000 tons by landfill
or land application, and 34,000 tons by impoundment.
Existing and proposed off-site storage facilities would provide space for
250,000 tons of waste, mostly in piles and impoundments. Various off-site
treatment facilities could handle up to 400,000 tons of aqueous inorganic
wastes, solvents, toxic anions and oily wastes. No commercial incinerators
exist in Region 10. One formal permit application has been filed for
construction of an incinerator which would burn up to 50,000 tons of waste per
year, and plans for a similar (competing ?) project have been informally
announced.
1 i
-------
Off-site landfill capacity as proposed for 10-year RCRA permits would be
about five million tons. The lifetime of the Idaho commercial landfill is
estimated by the company to be exactly 20 years (2007); such a rate of fill
would require the annual intake of waste in volumes 4-5 times as great as in
1985.
The Oregon commercial landfill would be. full in 18 years (2005) at the
rate of fill experienced in 1985; in 12 years (1999) at the 1986 rate of fill;
and ^n 9 years (1996) at the rate of fill anticipated by the company.
However, note that the company owns much more land adjacent to the existing
facility which could be developed as landfill. The actual permit proposals
beyond the next 10 years cannot be anticipated.
Prob1 ems/Recommenda11 on s
Several problems were encountered when using the various hazardous waste
management data systems. Most of those problems relate to the unfamlliarity
of some generators with the reporting requirements and formats, the narrow
scope of required data, unsophisticated reporting systems in some states, poor
coordination of data collection processes in the region and the absence of a
suitable central data repository.
It is recommended that a regional or national hazardous waste data
management system be developed with the following features:
1. A.single report form to be used by all states (or as the core of any
state-developed form) to collect data both from hazardous waste
.generators and waste management facilities.
2. Surveys conducted at least annually and summary reports issued without
great lag time.
3. Clearly-stated reporting requirements, particularly with regard to
definitions of reportable wastes (for example, under what circumstances
are volumes of wastewaters reportable prior to treatment? Conversely,
when are treatment residuals reportable as newly generated wastes?)
4. An annual determination of the regulatory status of all potential
generators.
5. Verification of all generator and facility-reported data by state
agencies and EPA (staff augmentation required).
6. Characterization of wastes in terms of physical form and all relevant
chemi.cal components (within the limits of practical analysis) through
use of a more complex coding system.
7. Tracking of wastes throughout the country and reporting of treatment and
ultimate disposal of those wastes to the regulatory agency in the state
of origin.
8. The capability to account for stored wastes at the beginning as well as
at the end of a reporting period.
-------
9. More detailed description of waste treatment processes through a more
complex coding system.
10. The capability to compare the volumes of various wastes on an annual
basis and to determine the degree to which each generic means of waste
reduction Is employed by each category of industry.
11. The capability to determine the remaining permitted capacity of landfills
on an annual basis and "he practical throughput capacity of treatment
facilities.
12. The entry of all core data into a commonly accessible automated system.
It is further recommended that the Region 10 states, individually or
collectively, conduct intensive studies of waste management capacity and waste
reduction potential as soon as practicable. The advice and assistance of the
waste generating industries and waste management businesses should be
solicited to assure success of the investigations.
-------
INTRODUCTION
The production, distribution and use of potentially hazardous chemical
substances have dramatically increased in the United States during the past
forty years. The demand of a growing population for products and services has
resulted 1n the accelerated manufacture of chemicals whose properties are
dangerous under certain circumstances. New synthetic organic chemicals are
developed at a rate of over 1500 per year, and the total yearly volume of such
materials 1n commerce is at least three times the amount produced annually in
the early 1950's.
Our complex society has also increased the variety of routes through
which humans and their environment can be exposed to this expansive array of
useful but dangerous materials. A heightened awareness of the extent to which
such exposure can occur has resulted In the development of statutory national,
state and local programs designed to control the handling of hazardous
materials such that negative effects are reduced to a reasonable level. One
series of national statutes is aimed particularly at that part of the problem
related to the waste materials resulting from the production, use and disposal
of chemicals. Wastes are produced at each stage, from the extraction of raw
materials from the environment, through manufacture, distribution and use of
products, to the ultimate discard of unused portions of those products.
Persons who generate, transport, store, treat or dispose of hazardous wastes
are required to limit their activities and follow quite specific procedures
prescribed by law.
-------
The Resource Conservation and Recovery Act (RCRA) of 1976 and its
subsequent amendments establish a detailed framework for regulation of current
management practices applied to wastes considered to be hazardous due to a
variety of properties, ranging from flammability to carcinogenicity; the Toxic
Substances Control Act (TSCA) created a process to control the manufacture and
use of toxic materials as well as the management of the wastes associated with
some of those products; the Federal Insecticide, Fungicide and Rodenticide Act
*
(FIFRA) regulates the use of pesticides and, to a lesser degree, the disposal
of associated wastes; and the Comprehensive Environmental Response,
Compensation and Recovery Act (CERCLA) and its reauthorizing statute create a
nationwide remedial action program to rectify past disposal practices now
found to be unsuitable. Other components of the generic national
environmental legislation impact the management of hazardous materials as
well, e.g., the Clean Water Act, the Safe Drinking Water Act and the Clean Air
Act. All of the basic environmental protection laws establish roles and
responsibilities for the states and the U.S. Environmental Protection Agency
(EPA) to implement the Congressional mandate.
The Pacific Northwest states (Alaska, Idaho, Oregon, Washington), while
generally less industrialized than the country as a whole, are faced with a
significant and perplexing share of the national hazardous waste problem.
Those states, which comprise Region 10 of EPA, have created an initiative in
concert with the federal agency to determine the status of Region 10 hazardous
waste management practices and to stimulate cooperative interstate planning
for intervention with respect to any apparent deficiencies, whether imminent
or long-term.
2.
-------
The Initiative 1s driven by several factors. Including a need on the part
of the regulatory agencies to clearly understand the scope and nature of
hazardous waste generation in the region for program planning purposes; a
desire on the part of legislative leaders to assure public health protection
within their jurisdictions while reasonably controlling the cost of doing so;
concern on the part of the regulated community regarding the dynamic nature of
the programs; and certain statutory requirements for program evaluation.
While the study on which this report is based arose from that entire range of
concerns, the report responds largely to a specific requirement of federal
law. CERCLA provides both enforcement and financial means for cleaning up
"uncontrolled sites" upon which hazardous materials have been released in the
past. Eligible sites are those determined to be of high relative importance
on a national scale and thus placed on the National Priority List (NPL). Money
from a federal remedial action account ("Superfund") can be used by EPA and
the state environmental agencies to facilitate cleanup of sites for which no
responsible party can be found as well as those sites which require action
while responsible parties are being sought. If a state is to remain eligible
for "Superfund" participation beyond October, 1989, it must certify the
availability of treatment or disposal facilities for all of its hazardous
wastes expected to be generated in the next 20 years, regardless of the source
of those wastes. Specifically, Section 104(k) of the Superfund Amendments and
Reauthorization Act of 1986 states, in part:
-------
" Effective 3 years after the enactment of
the Superfund Amendments and Reauthorlzatlon Act
of 1986, the President shall not provide any
remedial actions pursuant to this section unless
the State In which the release occurs first
enters Into a contract or cooperative agreement
with the President providing assurances deemed
adequate by the President that the State will
assure the availability of hazardous waste
treatment and disposal facilities which —
(A) have adequate capacity for the destruction,
treatment, or secure disposition of all
hazardous wastes that are reasonably expected to
be generated within the State during the 20 year
period following the date of such contract or
cooperative agreement and to be disposed of,
treated, or destroyed,
(B) are within the state or outside the state in
accordance with an interstate agreement or
regional agreement of authority,
(C) are acceptable to the President, and
-------
The CERCLA certification problem aside, some other factors led EPA and
the Region 10 states to conclude that an assessment of the Region's hazardous
waste streams and management practices should be conducted. RCRA allows EPA
to authorize states to conduct hazardous waste regulatory programs in lieu of
direct federal administration when certain requirements of consistency are
met. In Region 10, only the programs of Oregon and Washington have been
authorized by EPA, although both Alaska and Idaho perform activities in
support of the federal program through cooperative agreements. Idaho operates
a parallel full regulatory program pursuant to state law, and Alaska is
expected to do so beginning in 1988 regardless of the status of
authorization.
Moreover, no such opportunity exists for the Region 10 states to conduct
TSCA-related programs on behalf of EPA, even though fragments of such state
programs exist, at least with respect to regulation of the management of waste
polychlorinated biphenyls (PCBs). Also, the RCRA and TSCA programs are
administered somewhat separately within EPA. While the independent regulatory
accomplishments of each agency are apparently high, this mixture of program
splitting on the one hand and temporary duplication on the other has produced
three quite predictable results: (1) the programs are not fully coordinated
on a regional basis, (2) program planning documents, periodic program
evaluation and status reports, and hazardous waste data displays are
constructed in a variety of formats, and (3) the EPA and State analysts arrive
at different conclusions due to the occasional submission of inconsistent or
conflicting data for the same time periods by some waste generators and waste
management entities. Further, questions arise as to the accuracy and
-------
comparability of Information secured by the agencies from hazardous waste
generators because the required reporting terminology 1s complex and nearly
foreign to those persons not exposed at length to the coded jargon. Persons
whose activities have been most recently covered by amendments to the federal
law represent small organizations, some of which are not sophisticated with
respect to environmental regulation. Data summaries derived from a multitude
of individual industry reports can be poor sources of planning information
unless considerable data verification is done.
The sequential implementation of various newly mandated regulations will
substantially affect the volume, character and ultimate disposition of certain
hazardous waste streams in the Region. Those effects must be calculated and
factored into any projection of future waste management patterns. Potential
amendments to the regulations in future years should also be anticipated so
that all likely waste generation and management scenarios can be developed for
planning purposes.
This report presents the findings of a survey of available literature
which describes the character and magnitude of hazardous wastes which have
been generated in Region 10 and how those wastes have been managed. It
compresses data relating to all four states into one document in consistent
terms and provides some limited analysis. As the time available for data
collection was quite short, the review was not exhaustive nor is the report
fully comprehensive. Nevertheless, it represents a step forward in
>
consolidating information. This assessment is not a market survey. The
information presented in this report is not purported to represent the
intentions of any private or commercial entity, nor are the data suitable as a
-------
basis for planning of specific facilities. Rather, the report Is to serve as
a reference for general policy development and as a stimulus for more specific
waste handling studies in Region 10. The objectives of the assessment follow:
1. Description of the characteristics and determination of the
magnitude of the various hazardous waste streams and PCB waste
streams in each Region 10 state.
2. Determination of the nature of the waste sources and generators.
3. Description of current management practices.
4. Determination of the current extent of interstate shipping of
hazardous wastes.
5. Estimation of the potential for further waste reduction.
6. Projection of the effects of current and anticipated regulatory
and economic factors on the future volume of the waste streams and
the employment of various waste management techniques.
7. Determination of the types of technology likely to be available
for handling of the region 10 wastes.
8. Estimation of available treatment/disposal capacity in Region 10
and the need for facilities in future years.
9. Determination of further data requirements for program planning.
-------
METHODOLOGY
The assessment of hazardous waste generation and management in Region 10
was conducted during the period extending from April 1 to July 1, 1987.
Information was collected by three general means: (1) review of written
reports and data, (2) interviews of persons knowledgeable of hazardous waste
management activities in Region 10, and (3) a limited survey of the public
electric power utilities regarding PCB waste management practices.
The primary available documents which describe the nature and magnitude
of hazardous waste generation and management are the biennial reports produced
by EPA, the Oregon Department of Environmental Quality (DEQ) and the
Washington Department of Ecology (DOE) pursuant to reporting requirements of
RCRA regulations. EPA assembles the reports relating to Alaska and Idaho
activities, because the regulatory programs in those states are not yet fully
"authorized" by the federal agency. The Washington DOE publishes a separate
annual report which provides detail and analysis beyond that required for the
federal reporting system. The Idaho Department of Health and Welfare,
Division of Environment (DHW) also produces an annual summary report of waste
generation and disposal practices in the state. A report was prepared for the
Alaska Department of Environmental Conservation by ERM, Inc. regarding 1983-84
hazardous waste generation, and an ad hoc task group reported on options for
handling liquid wastes on Alaska's North Slope.
The biennial reports are compilations of data submitted by regulated
hazardous waste generators and treatment, storage and disposal facilities
(TSDF's), the most recent versions pertaining to the activities occurring in
calendar year 1985. The current assessment (this report) relies largely on
those 1985 reports, although conclusions regarding trends and projections are
-------
based 1n part on information about activities in other years. The biennial
report data collection system Is fraught with problems which can affect
accuracy; some analysis of those problems Is presented in this report. Other
written references were reviewed on the subjects of waste minimization, PCB
management, existing and developing treatment and disposal technology,
regulatory effects, remedial action programs, and the TSDF permit issuance
process. Several special computer "runs" were made from agency data
processing files regarding permit applications and remedial action sites.
One new compilation of data was solicited for this report. The Defense
Reut1l1zat1on and Marketing Service exists for the purpose, among others, of
supervising and contracting for the disposal of hazardous wastes and PCB
wastes generated at active military installations. The subject wastes include
those produced by clean-up, projects on those active sites conducted under the
Installation Restoration Program (IRP) as well as those generated routinely
from ongoing military operations. Since much of that waste has been shipped
out of the Region for handling, and since many of the shipments include PCB
wastes and others not formally managed as "hazardous", data are not readily
available regarding management patterns. The Defense Reutilization Management
Office in Ogden, Utah, was asked to provide a data summary for 1985 pertaining
to the military installations in the states of Region 10. That information
was factored into the projections of future waste generation patterns along
with estimations of waste to be produced as a result of the remedial action
program of the Army Corps of Engineers which is directed toward various
inactive or abandoned federal sites. Discussions were held with EPA hazardous
waste program managers and staff (Regional Office; Operations Offices in the
states; Headquarters); program managers and staff of the four state
-------
environmental agencies; representatives of the municipalities of Anchorage,
Alaska, and Seattle, Washington; the Puget Sound Council of Governments;
Seattle Metro; the Alaska North Slope Task Group; TSDF managers; Industry and
utility representatives; and military and other federal facility managers.
Those Interviews, along with documented information, provided a basis for
estimating future hazardous waste generation and management patterns. Some
specific sources of information will be discussed in the following sections of
this report.
As TSCA regulations do not require submission of PCS generation reports
to EPA or the state agencies, a mail survey of public electric utilities was
conducted with the assistance of the PNUCC Utility Environmental Committee and
the Pacific Northwest Public Power Association. Respondents provided
estimates of past and future PCB generation and disposal volumes. That
information supplemented available national PCB data and local TSDF data such
that reasonable estimates of the future PCB generation pattern and management
facility needs could be estimated.
The 1985 hazardous waste generation and management data were divided (or
combined) into common categories as much as possible for display in this
report. As the state agency reports vary in level of detail, that exercise
required the application of assumptions and estimations; therefore, virtually
none of the reported values should be considered to be absolute.
The data produced in this fashion constitute a baseline from which
projections were attempted in consideration of the following additional
factors:
-------
1. Small quantity generator wastes
2. Household waste generation and disposal
3. Waste minimization programs
4. Regulatory effects
5. Economic growth
6. Remedial action programs
•
The projected generation pattern was then compared to the capacity of the
apparently available and proposed management facilities within Region 10 to
determine potential deficiencies. The applicability of various types of
treatment and disposal technology to the specific waste groups and volumes
produced In Region 10 was generally assessed. Discussion of each of the
aforementioned factors is presented in the following sections of this report.
Since most of the data presented in this report were extracted from
regulatory program reports which pertain to a prescribed range of chemical
substances, strict definitions of certain terms must be recognized; hence,
waste generation data displayed in this report describe only those materials
regulated by the agencies as "hazardous waste", and hazardous wastes are
discussed separately from PCBs. However, recognizing that waste management
problems and solutions are multimedia in nature (air, water, land) and that
the commercial application of facilities may involve non-regulated wastes,
this report also includes discussion of waste generation and management in a
broad sense.
-------
HAZARDOUS HASTE GENERATION
Wastes listed by EPA as hazardous at certain concentrations and those
with specific dangerous characteristics are tracked and regulated from
generation to final disposition by EPA or the state agencies under the
provisions of RCRA or companion state statutes. "Characteristic" wastes are
those which exhibit properties of ignitabi1ity, corrosivity, reactivity and
toxicity. Listed wastes include generic chemical groups from non-specific
sources; conglomerate wastes from spe-cific sources (mostly manufacturing); and
discarded commercial chemical products, off-specification products, container
residues and spill residues of those'materlals.
Originally, the federal program applied to all wastes in the amount of
2200 pounds (1000 Kg) or more produced in a month or accumulated at any time
by a person. Lesser amounts of extremely toxic materials were also
regulated. RCRA amendments adopted in 1984 reduced the regulated amount to
220 pounds (100 Kg). Those persons who produce 2200 pounds of waste per month
or accumulate that amount are referred to as "major generators".
At the outset of the federal program, all persons who expected to handle
regulated amounts of hazardous waste were required to register with EPA and
receive an identification number. Those numbers appear on manifests which
accompany each hazardous waste shipment and serve as identification of the
entities which generate, transport, store, treat or dispose of those wastes.
All regulated wastes generated in amounts of 220 pounds per month or greater
must be stored (if more than 90 days), treated or disposed of at a facility
approved for that purpose by the appropriate regulatory agency. Federal rules
require regulated facilities and registered generators and handlers of
hazardous waste to file biennial reports with EPA or state
-------
agencies. State agencies with "authorized" programs must compile the
Information and report to EPA.
Major generators must report the quantity of waste shipped from their
premises and 11st the destinations. Those who produce between 220 and 2200
pounds of waste per month or accumulate that amount are termed "small quantity
generators" (SQG); they are required only to report that they fall in that
category for the year in question, although their wastes must be handled by
approved hazardous waste facilities and shipments must be manifested.
(requirement began September 8, 1986). The regulations of the State of
Washington establish major generators as those who produce greater than 400
pounds of waste per month. Reporting and waste management requirements
therefore reach a larger fraction of the waste-generating community than in
the other three states.
Persons who reclaim materials on-site or ship certain wastes such as
lead-acid batteries and solvents off-site for recycling must only report that
they are exempt from further regulation. Those who generate no regulated
waste in a given year must so report. If no such wastes are expected to ever
be generated, a person can formally apply for removal of his name from the
list of registrants. Household wastes, though often containing materials
defined as "hazardous", are exempt from regulation and maintain that identity
regardless of amounts accumulated at any point from any number of sources.
Although some municipalities have established projects for periodic collection
of household hazardous wastes for treatment or permanent disposal, most such
wastes are taken (legally) to public landfills where their disposition may or
3.
-------
may not be "permanent". Most of those landfills are not "secure" in the sense
that no liners are required and, in most cases, no groundwater monitoring
system is yet 1n place.
SOURCES OF HAZARDOUS HASTE
This study examines waste generation and handling In Region 10 by
establishing 1985 as the base year from which to make projections; the most
current biennial reports relate to that year. Hazardous waste is produced by
a fairly broad spectrum of sources in the region, ranging from large
industrial plants to Individuals.
The reported number of registered generators in the region during 1985
was 2689. Table 1 displays the status of those entities as determined by the
biennial survey. Only 882 (33%) were major generators of hazardous waste.
Seventy percent of the region's major generators were in Washington (623), 23%
in Oregon (206), 4% in Idaho (30) and 3% in Alaska (23). Another one-third
of those who were registered produced no regulated hazardous waste in 1985
(much higher percentages in Alaska and Idaho), while 13% reported as small
quantity generators. Note that other SQG's exist in the region, but they did
not register. Ten percent of the registrants claimed exempt status and an
equal number either did not respond or reported that their businesses were
closed or had been sold. Most of the non-responders were transporters who
were not actually required to report.
-------
TABLE 1
REGISTERED GENERATOR STATUS, REGION 10, 1985 (NUMBER)
Major Generator
Small Quantity Generator
No Waste
Exempt
No Response
Closed or Sold
Total
AK
23
14
61
18
35
151
ID
30
58
163
43
5
299
OR
206
80*
250*
75*
10*
621
WA
623
188
452
138
195
22
1618
Total
882
340 .
926
274
195
72
2689
%
33
13
34
10
7
3
100
* Estimated
TABLE 2
CATEGORIES OF MAJOR GENERATORS, REGION 10, 1985 (NUMBER)
Source
Manufacturing
Chemicals
Metal work ing
Electronics
Wood Products
Prim. Sec. Metals
Petroleum Ref.
Transport Eqp.
Misc. Mfq.
Subtotal
Trade, Services, Govt.
Transportation
Mi 1 i tary
Mining
Electric Uti 1 ities
Subtotal
Total
AK
3
3
8
5
4
3
20
23
ID
1
1
3
1
3
9
10
7
1
3
21
30
OR
25
45
35
32
12
1
2
152
41
12
1
54
206
WA
43
80
30
23
21
8
43
92
340
194
41
• r*
3
283
623
REGION 10
69
126
68
56
33
12
43
97
504
253
65
49
7
4
378
882
-------
The major generators represent most elements of industrial and community
activities 1n the region, including manufacturing, trade, services,
government, military, transportation, mining (Including oil extraction) and
electrical utilities. Manufacturing companies (504; 57%) and trade, services
and governmental organizations (253; 29%) dominated the list of major sources
in 1985 (Table 2). The manufacturing category Included a large number of
metalworking companies (126; 14.2%); other categories most frequently
represented were chemicals (69; 7.8%), wood products (56; 6.3%), electronics
(68; 7.7%), and transportation equipment (43; 4.9%). The manufacturing group
most strongly dominated the list of sources in Oregon and Washington, where
74% and 55%, respectively, of the generators were of that type (Figures 3 and
4). Most other Oregon generators were in the trade, services, transportation,
and governmental sectors (no military or mining sources). The Washington
pattern was similar except for the presence of significant military sources.
In Alaska, a balance of source types was seen as is evidenced by Figure
1. Trade, services and government accounted for 35% of the generators, while
military, manufacturing, oil extraction and transportation had nearly equal
shares of the remaining number. The only manufacturing units producing major
amounts of hazardous wastes were related to oil refining. A greater number of
generators than that shown in the biennial report may have produced regulated
amounts of hazardous waste in 1985. A review of the individual hazardous
waste management facility reports reveals that the waste from about 20
additional generators was disposed of by injection well on the North Slope and
managed by that facility as hazardous waste. No generator reports exist for
most of those wastes, perhaps because the wastes were not tested for hazardous
characteristics by the sources and were assumed not to be regulated.
I 0 .
-------
Figure 1
Figure 7
Categories of Major Hazardous Waste
Generators
Number and Percentage of Sources
Alaska
Manufacturing
3 (13%) \
Military
4 (17%)
Mining
(including oil extraction)
/ 3 (13%)
Trade, Services. Government
8 (35%)
Transportation
•" 5 (22%)
-------
Figure 2
Categories of Major Hazardous Waste
Generators
Number and Percentage of Sources
Electrical Utilities
Idaho 3 (10%)
i Mining
1 / 1 (3%)
Manufacturing
9 (30%) -
oo
Trade, Services, Government
10 (33%)
Transportation
^ 7 (24%)
-------
CaTegories of Major Hazardous Waste
Generators
Number and Percentage of Sources
Oregon
Trade, Services. Government
41 (20%) \
Transportation
12 (5.5%)
Manufacturing
152 (74%)
Electrical Utilities
1 (0.5%)
-------
O
Figure 4
Categories of Major Hazardous Waste
Generators
Number and Percentage of Sources
Washington
Mining
3 (0.5%)
/ Transportation
41 (6.5%)
Military
45 (7%)
Trade. Services.
Government
194 (31%)
Manufacturing
340 (55%)
-------
The actual number of oil extraction (mining) generators in Alaska in 1985 may
have been 40-45.
Manufacturing plants made up nearly one-third of Idaho's generators, with
trade, services and government accounting for another one-third (Figure 2).
The largest number of manufacturers were electronics plants. Transportation
and electrical utilities constituted most of the final one-third of the
sources.
The major generators in Region 10 reported the production of 545,158 tons
of hazardous waste in 1985 (Table 3). Over 85% of that waste was from the
manufacturing sector (466,057 tons). Most of the remaining 79,101 tons came
for military installations (60,255 tons). Washington reported 514,713 tons,
which amounted to over 94% of the region's waste; Oregon generated 26,813 tons
(5%), while Idaho and Alaska added a miniscule 0.6% to the total. However,
that relationship was skewed substantially by the inclusion in the Washington
report of wastewaters which were treated on-site and discharged to surface
waters or were sent to municipal sewage treatment plants following
pretreatment. The ultimate discharge of those wastewaters in both situations
was regulated by permits issued pursuant to provisions of the Clean Water Act
(NPOES). As the RCRA regulations exempt such wastewater from reporting
requirements, no such wastes were reported in Oregon, Alaska or Idaho.
However, since Washington requires reporting of those streams as hazardous
wastes, they were included in the biennial report.
Some residuals resulted from pretreatment of the wastewater discharged to
public sewers, but those were reported separately. Much of the Washington
wastewater (136,400 tons) was produced by one aluminum reduction plant.
-------
rx>
INi
TABLE 3
REPORTED HAZARDOUS WASTE GENERATION BY MAJOR SOURCES,
1985
Tons Generated
Source AK
Manufacturing
Chemicals
Metalworking
Electronics
Wood Products
Prim. Sec. Metals
Petroleum Refining 13
Transportation Equipment
Misc. Manufacturing
Subtotal (Manufacturing) 13
Trade, Services, Govt. 225
Transportation 210
Military 65
Mining (incl. oil production) 1096
Electric Utilities
Other
Subtotal (Non-Manuf.) 1596
Total 1609
ID
142
264
607
166
47
1226
394
164
19
221
798
2024
OR
1009
2718
9071
1149
8774
3
6
22,730
2519
1290
273
1
4083
26,813
WA
27,204
58,513
608
1252
281,509
4993
28,127
39,882
442,088
6552
059
59,917
5
16
76
72,625
514,713
REGION 10
28,355
61,495
10,286
2567
290,283
5009
28,127
39,935
466,057
9690
7723
60,255
1120
238
76
79,102
545,159
-------
As that wastewater contained only one pollutant (hexavalent chromium) and
neither the effluent nor the sludge resulting from treatment are toxic, the
exclusion of all NPOES wastewaters from the Washington hazardous waste total
when comparing waste generation patterns Is easily justified. Non-wastewater
hazardous waste in the region totaled 228,910 tons. Table 4 details the
magnitude of hazardous waste generation from source groups 1n the four
states. Without wastewater, the remaining manufacturing wastes still
dominated (179,263 tons; 86%). Washington's 198,464 tons of waste also still
dwarfed that of the other states (86.77.); Oregon contributed 11.7%; Idaho
0.9%; and Alaska 0.7% (Figure 5).
Figure 6 shows the distribution of sources and amounts of hazardous
wastes in the region. Primary and secondary metals industries, mostly in
Washington, produced the largest fraction of the waste in 1985 (85,811 tons;
37.5%); stone and clay products companies (34,794 tons; 15.3%), transportation
equipment manufacturers (26,246 tons; 11.5%) and chemical plants (23,638 tons;
10.37.) also contributed substantial shares. Alaska's wastes were chiefly
related to -..-.e oil production industry; electronics companies produced the
largest percentage of Idaho's wastes; and Oregon's primary waste generators
were the electronics and metals manufacturing industries.
Although the figures presented in this report reasonably portray the
magnitude and nature of hazardous waste production in 1985, the pattern of
generation over time has not been and will not be stable. Trend analysis is
hampered by an inability to clearly differentiate between the actual
generation fluctuations and the changing regulatory scope. The reported
Washington wastes (non-wastewater), for example, have varied by 307. between
23.
-------
TABLE 4
REPORTED HAZARDOUS WASTE GENERATION, REGION 10, 1985
(EXCLUSIVE OF NPDES WASTEWATERS)
TONS GENERATED
Source
Manufacturing
Trade, Serv., Govt.
Transportation
Military
Mining
Elect. Utilities
Other
Total
AK
131
225
210
65
1096
1609
ID
1226
394
164
19
221
2024
OR
22,730
2519
1290
273
1
26,813
WA
173,293
6552
6059
12,463
5
16
76
198.464
REGION 10
197,262
9690
7723
12,801
1120
238
76
228,910
TABLE 5
1
PHYSICAL COMPOSITION OF HAZARDOUS WASTE, WASHINGTON, 1985
Inorganic
Tons %
Sludge
Liquid
Solid
Total
54,218
17,543
72,609
144,370
27.
8.
36.
72.
3
8
6
7
Organic
Tons %
7153
10,729
4241
22,123
3.6
5.4
2.1
11.1
I/O Mixture
Tons
21,471
6076
4424
31,971
10
3
2
16
%
.8
.1
.3
.2
82
34
81
198
Total
Tons
,842
,348
,274
,464
7.
41 .7
17.3
41 .0
100
1. Does not include NPDES wastewaters
-------
(N3
Ul
Figure 5 _ _..
Hazardous Waste Generation,
Region 10, 1985
(Exclusive of NPDES
Wastewaters)
Oregon
26.813 tons (11.7%)
/ Idaho
2.024 tons (0.9%)
Alaska
1,609 tons (0.7%)
Washington
198.464 tons (86.7%)
Total: 228,910 tons
-------
Figure 6
Hazardous Waste Generation,
Region 10, 1985
(Exclusive of NPDES
Wastewaters)
Stone and Clay Products
34,794 tons (15.3%) \
Transportation Equipment
26,246 tons (11.5%)
Military
12,801 tons (5.6%
Trade, Services, Government
9,690 tons (4.2%)
Transportation
7,722 tons (3.4%)"
Mining \ f
1,120 tons (0.5%)
Miscellaneous
317 tons (0.1%)
Primary and Secondary Metals
85.811 tons 137.5%)
Total: 228,910 tons
Chemicals
23,638 tons (10.3%)
Electronics
581 .10,286 tons (4.5%}
Metalworking
> i — 5,205 tons (2.3%)
Petroleum Refining
'5,009 tons (2.2%)
*»l I Other Manufacturing
3,501 tons (1.5%)
Wood Products
2,567 tons (1.1%)
DNon Manufacturing
31,648 tons (14%)
Manufacturing
197,262 tons (86%)
-------
the years 1982 - 1985, due in part to the regulation of additional categories
of waste. An equally important factor is the sporadic nature of waste
production from cleanup projects of various kinds. Total waste volumes from
those sources in Washington have fluctuated more than an order of magnitude
from one year to another. The volume of Idaho wastes for 1986 is already
known to have been about 33% less than in 1985, partially because of a
difference in site cleanup wastes. Some cleanup projects produce materials
that are regulated hazardous wastes and those are therefore reported by the
generators. Other cleanup wastes are not designated as hazardous, but are
nevertheless sent to hazardous waste disposal facilities. Those wastes are
not necessarily reported by generators.
Certain components of the major source waste streams and relevant
unreported or unregulated waste streams generated during the 1985 base-year
are discussed in the following paragraphs. Projections of future waste
production with respect to those components are made in a later section of
this report.
Recycled Hastes
The limited RCRA reporting requirements render impossible an estimate of
hazardous waste volumes destined for recycling. While a small fraction of the
waste reported by regulated generators is actually recycled rather than
treated or disposed of, most such wastes are not reported due to the
regulatory exemption. Some recycling of spent solvents and petroleum products
occurs in the region, but to a lesser degree than several years ago, prior to
-------
the failure of a major recycling facility in Washington. Reprocessing of
lead-acid batteries continues in Oregon.
The types of waste currently being recycled will probably not be shifted
to any other handling mode, so an accurate determination of the current
recycling volume is not instrumental in the assessment of treatment and
disposal capacity needs. However, the capability to add recycling capacity
may be important as conventional disposal methods are disallowed for certain
wastes.
Remedial Actions
A substantial portion of the reported regulated hazardous waste results
from remedial actions at NPL (Superfund) sites, RCRA-regulated cleanup
projects, state regulated or assisted site cleanups, and transportation-
related spill cleanups. As previously pointed out, some of those wastes are
not reportable by regulated generators, but are accounted for by the facility
reports.
A perusal of the Alaska and Idaho individual generator reports for 1985
allowed an estimate of the fraction of reported tonnage resulting from cleanup
of spills and remedial actions of some kind. Approximately 14% of the Idaho
wastes and 107. of the Alaska wastes fell into that category. Washington DOE
staff reported that about 1400 tons of waste resulted from cleanup projects in
1985 (0.7% of the non-wastewater total). Note, however, that the reported
value for 1984 was tenfold higher. No estimate is available for Oregon.
-------
Small Quantity Generators
Small quantity generators were not required by RCRA regulations to send
wastes to approved hazardous waste management facilities in 1985, nor were
they asked to report the specific amount of waste generated. Some SQG's
shipped waste to regulated facilities 1n 1985 anyway, and were required to do
so after September, 1986. It is important to know the approximate amount of
SQG waste generated in the region during the base-year so that it can be
factored Into estimates of waste production and disposal capacity needs.
National data indicate that 98% of the total number of generators are
SQGs, but that they produce less than 1% of the total waste; In Region 10,
the SQG's theoretically contribute a slightly smaller share, because the State
of Washington defines major generators as those producing 400 pounds or more
of waste, while RCRA establishes the cutoff at 2200 pounds. National data
also establish that three-fourths of the SQG's are located in Metropolitan
Statistical Areas, and that less than 15% are manufacturing industries.
About one-half of the SQG's are vehicle maintenance businesses, and 60%
of the total waste is lead-acid batteries (90% of which are recycled).
Solvents account for approximately 20%, and strongly acidic or alkaline wastes
amount to about 5%. Most SQG's ship waste off-site, where the most common
management method is recycling (2/3). One-fifth of the SQG's manage waste
on-site (mostly RCRA-exempt disposal to public sewers) and the remainder treat
on-site and then dispose of residuals off-site.
29.
-------
Through disaggregation of national data on the basis of urban population,
and adjustment for the Washington definition, one can estimate that the SQG's
of the Region 10 states generate about 11,000 tons per year of hazardous waste
other than batteries, 5400 tons of which are solvents and 1500 tons are
acids/alkalies. This method of estimation would assign over 7000 tons per
year to Washington SQG's, 3000 tons to Oregon, 600 tons to Idaho and 400 tons
to Alaska. Those figures seem high in relation to the amount of waste
produced by "major" generators, but that is to be expected, because the Region
10 states' major generators produce less waste than the national average on a
per capita basis.
An Anchorage, Alaska, SQG survey provides an estimate of 330 tons per
year of waste produced in that city. Only one-half of the potential SQG's
responded, and the estimate is probably low. However, the number is a
reasonable estimate of the actual waste total exclusive of batteries.
Projection of that figure to the total population of the region yields 12,000
tons, which is remarkably close to the 11,000 ton estimate derived from
national data.
Much of the SQG waste is recycled, but it is difficult to determine the
percentage. A study of King County, Washington, non-regulated hazardous waste
conducted for the Puget Sound Council of Governments (PSCOG) concluded that
about 5100 tons of potentially hazardous wastes were discarded (not recycled)
by commercial and industrial SQG's in 1985. Two-thirds of those materials
were weak bases which would likely not meet the standard test for hazardous
30,
-------
characteristics. The remaining tonnage (1700) might represent a good estimate
of the fraction of SQG wastes which were not recycled in 1985. Applying such
a factor to the 11-12,000 ton estimate of SQG waste in the region, one might
conclude that 3500-4000 tons of such waste were handled by public solid waste
management facilities. That amount can be added to the reported major
generator waste when considering possible disposal options.
Household Haste
Unregulated household hazardous wastes are diverse and quite voluminous;
most are taken to public landfills. The PSCOG study placed the household
hazardous waste of King County at 5896 tons in 1985. An extrapolation of that
figure to all of the households of the region provides an estimate of 35,000
tons. National studies have determined household hazardous waste generation
at about 40 pounds/household/year. Application of that factor would produce
an estimate of 56,000 tons for the region in 1985. Allowing for substantial
error, the actual amount may have fallen in the range of 30,000 to 60,000
tons. Perhaps one-half of that amount could be accessible for special
management if intensive urban collection programs are developed.
HASTE CHARACTERIZATION
About 700 specific chemicals have been listed by EPA as hazardous when
present in waste materials. Various other waste components, when present in
sufficient concentration, will produce hazardous characteristics. EPA and the
Region 10 state agencies have described specific waste sources and waste types
31 .
-------
which are regulated 1n addition to the EPA-listed chemicals. Thus, the total
number of chemical elements, compounds, and designated waste types reaches
well over 1000.
One hundred sixty-five of those specific waste types were generated in
Region 10 in 1985. Washington reported wastes with 103 separate substances or
waste types, 36 of which were present in amounts of one ton or more. Oregon's
total was 62, of which 52 reached a ton or more. Ninety-four substances or
waste types were produced in Idaho, but only 26 were present in the amount of
one ton or more. In Alaska, 36 waste types were identified, 21 amounting to a.
ton or more.
While it is important to determine the presence of each specific
substance and regulated waste type for analytical purposes, one must recognize
that many of the actual waste materials are mixtures of substances and that
the wastes may exist in different physical states. Applicable storage,
treatment and disposal techniques will depend on the nature of the waste (pure
liquid, dry solid, sludge, aqueous solution, emulsion, etc.). Unfortunately,
the standard EPA biennial data collection system does not provide such
information; however, the Washington DOE does request data from generators
regarding the physical state of wastes, and the 1985 DOE annual report
includes that information. It breaks down the wastes in terms of liquids,
solids and sludges, both organic and inorganic. That pattern probably
approximates the physical characteristics of wastes in the other Region 10
states except Alaska, where the predominant wastes are oily aqueous solutions.
32.
-------
The 1985 Hashlngton data are presented 1n Table 5 (page 24). Nearly
three-fourths of the wastes (exclusive of wastewaters) were inorganic, and
much of the remainder was inorganic/organic mixtures (16.2X). Solids and
sludges prevailed equally, totaling 41.0 and 41.TL, respectively. About
one-fourth of the materials were potentially combustible and 311 of those
combustibles were liquids.
In the Interest of considering applicable technology, it Is convenient to
group the wastes by general chemical character or by industrial source. The
methodology of this survey did not allow for detailed groupings based on
strict treat-ability factors, but a basic breakdown of the 1985 Region 10 data
was attempted. Tonnages of general waste groups are shown in Table 6 and the
percentage distribution is displayed In Table 7. Note that the State of
Washington regulates as hazardous some wastes not so classified by RCRA
regulations. Over one-half of the hazardous wastes reported by Washington
fell into that category. Those materials were found to be toxic by bioassay
techniques and some were also corrosive. Specifically, those wastes consist
of such materials as cement kiln dust, furnace black dross and potlining from
the aluminum industry, boiler fly-ash from the wood products industry, and
fluxing salts from magnesium reduction. Washington also designates PCBs below
50 parts per million (ppm) as hazardous waste. The State of Oregon also
regulates certain wastes based on bioassay techniques, but those were a
relatively minor factor in 1985 compared to the Washington situation.
Most of the waste groups in Tables 6 and 7 are not mutually exclusive,
i.e., a particular waste might fall into more than one category. For example,
certain corrosives are often contaminated with heavy metals and would be
-------
TABLE 6
1
CHARACTERIZATION OF HAZARDOUS HASTE. REGION 10. 1985 (TONS)
Major Waste Types
Metals
Non-Chlorinated Solvents
Chlorinated Solvents
Other Halogenated Organics
Misc. Organics
2
Ignitables (N.O.S.)
Corrosives
Reactives
3
Pesticides
Electroplating Sludges (CN-)
Petroleum Residuals
Steel Emission Control Dust
Steel Spent Pickle Liquor
Aluminum Coating Sludges
Misc. Inorganics
Washington Reg. Wastes
Total
AK
594
30
42
178
674
8
1
14
68
1609
ID
256
62
74
3
24
67
296
11
406
340
20
465
2024
OR
4314
675
2041
928
734
3040
5683
270
1026
3294
37
2998
115
34
1624
26813
WA
28106
8272
3228
23
282
2872
14643
148
3190
15049
6677
6342
4516
633
92
104,349
198,464
REGION 10
33270
9039
5385
954
1260
6653
20630
430
4622
18683
6748
9340
4631
667
2249
104,349
228,910
1. NPDES Wastewaters not included
2. Not otherwise specified
3. Including wood preservatives
-------
TABLE 7
CHARACTERIZATION OF HAZARDOUS HASTE. REGION 10. 1985 (PERCENTAGE)
Type
Metals
Corrosives
Electroplating Sludge
Steel Emissions Dust
Non-Chlor. Solvents
Ignitables (N.O.S.)
Petroleum Residuals
Chlorinated Solvents
Steel Spent Pic. Liq.
Pesticides
Misc. Inorganics
Misc. Organics
Other
Washington Reg.
Total
AK
37
0.5
0
0
2
42
1
2.5
0
0
4
11
0
100
ID
13
15
17
0
3
3
1
4
0
20
22
1
1
100
OR
16
21
12
11
2.5
11
0.1
8
0.4
4
6
3
5
100
1
WA
14
7
8
3
4
1.5
3
2
2
1.5
0.1
0.5
0.4
53
100
234
MA REG. 10 REG. 10
30 14 27
16 9 17
16 8 15
7 4 8
94 7
3
3
2
2
2
1
1
1.5
46
100
1. Washington percentage including wastes regulated only by Washington.
2. Washington percentage without wastes regulated only by Washington.
3. Region 10 percentage including wastes regulated only by Washington.
4. Region 10 percentage without wastes regulated only by Washington.
-------
regulated due to either factor. The designations chosen for the Tables are
based on the waste element or characteristic reported by the generator as
dominant 1n each waste (in some cases, 1t is simply the first of several waste
codes listed 1n the generator report). For ease of comparison of
RCRA-regulated waste generation in all four states, Table 7 includes waste
group percentages for Washington calculated with and without the wastes
regulated only by that state. Figure 7 graphically presents the distribution
of RCRA-regulated wastes in the region, exclusive of the wastes regulated only
by Washington.
As mentioned earlier, nearly one-half of the region's hazardous wastes in
1985 were the Washington-only wastes. Otherwise, the dominant categories were
metals, corrosives, electroplating sludge (usually containing cyanide), steel
plant emissions dust, and non^-chlorinated solvents, with lesser amounts of
ignitable materials not otherwise specified, petroleum residuals, chlorinated
solvents, steel plant spent pickle liquor, pesticides, and miscellaneous
organic and inorganic substances. The relative volumes of those wastes are
quite similar in all states except Alaska.
In Alaska, most of the 1609 tons of waste reported in 1985 was associated
with activities in the oil fields. Corrosive liquids with metals constitute a
large fraction of the wastes from those sources, along with aqueous oily
wastes and solvents from such practices as equipment and truck cleaning. Some
of the wash water is contaminated only by motor oil, gasoline or diesel, but
is classified as hazardous waste due to low flash point or high concentration
of lead. The report of the Alaska North Slope Task Group leads one to
conclude that regulated hazardous wastes generated in that state may well have
36.
-------
Figure 7
Characterization of Hazardous Waste,
Region 10, 1985 Non-chlorinated Solvents
Percentage by Weight (7%) steel Emissions Dust
Chlorinated Solvents \ / (8%)
(4%) \
Steel Pickle Liquor,
(4%)
\
Petroleum Residuals
(6%)
Ignitables (N.O.S.)
(6%)
Miscellaneous
(6%)
Corrosives
(17%)
Electroplating Sludge (CN-)
(15%)
-------
been closer to 6000 tons In 1985, rather than the 1609 tons shown in the
biennial report. That conclusion is based on representative testing of wastes
disposed of at the Prudhoe Bay Unit injection well. Hazardous wastes from
other parties (non-Unit) were received for disposal there (until August, 1985)
along with wastes assumed not to be regulated. The testing established that
about 35% of the volume of all non-Unit wastes was hazardous. If 35% of the
7500 tons of non-Unit wastes delivered to the injection well by August, 1985
was in fact hazardous, then those wastes must have been generated at a rate of
about 4600 tons per year at that time.
Alaska industries generate large volumes of non-hazardous wastes which
are Important when considering overall disposal options. In 1985, about
31,000 tons of oily wastewater were produced by oil exploration processes.
Those wastewaters, which were also injected into deep wells, are specifically
excluded from classification as hazardous by the RCRA regulations. Petroleum
refining also generated large amounts (20-30,000 tons) of process wastewater
which is treated on-site by an oil/water separator. Those waste streams are
either recycled or discharged under NPDES permit and are therefore not
regulated by RCRA.
Idaho's predominant 1985 hazardous wastes fell into the category of
pesticides (406 tons; 20%) but that will prove to be an anomaly. Well over
half of the pesticide wastes reported in that year came from a groundwater
treatment project involving spilled creosote; the bulk of the remaining
reported pesticides was pentachlorophenol-contaminated material from wood
treating operations. Otherwise, the leading waste categories in Idaho were
electroplating sludge, corrosives and metals.
38.
-------
The Oregon list Is led by corrosives (21%), followed by metals (16X) and
electroplating sludge (121). A substantial amount of steel plant emissions
dust was generated as well as an equal amount of 1gn1table material of
unspecified nature.
As previously noted, the reported Washington wastes were largely those
regulated only by that state (53X); metals constituted the next largest
category, followed by electroplating sludge and corrosives.
Overall, 1t Is apparent that the Region 10 hazardous waste streams
consist mainly of solid and semlsolld Inorganic materials which are fairly
stable chemically and are amenable to relatively uncomplicated management
options. However, a small, but very significant organic fraction also occurs
In various physical forms and sometimes 1s mixed.with Inorganics, Including
metals, presenting a complex management problem.
39.
-------
DISPOSITION OF HAZARDOUS WASTE
The handling of hazardous waste in the United States is a dynamic
process which reacts over time to a variety of influences—some economic, some
regulatory, and others, cultural. Materials now considered to be dangerous,
and therefore deserving intensive regulation and specific handling procedures,
were for all time prior to the 1970's managed in any way chosen by the persons
who owned them, sometimes receiving the same level of care as that accorded
municipal refuse and sometimes much worse. Many "superfund" sites in the
country stand as testimony to the latter condition.
Better and more coordinated strategies have arisen in the form of
national, state and local legislation designed to reasonably separate the
people and their environment from hazardous substances. The technical means
of doing so range from refraining from manufacture of hazardous materials to
destruction of such materials or their negative properties once their useful
life is complete. Between those extremes are various methods of hazard
reduction, including material reuse, recycling, treatment, stabilization and
isolation. Current public policy, voiced in some fashion by nearly every
state as well as the federal government, establishes a hierarchy of waste
handling options which descend in the following order, from most to least
desirable: waste minimization; physical, chemical or biological treatment;
incineration; solidification and/or stabilization; and secure landfill.
The policy, much more easily justified than implemented, is clearly
extant in Region 10, as the very "pecking order" shown above has been placed
in statute by the State of Washington, and exists in the hazardous waste
management planning documents of the other three states. All of the Region 10
40..
-------
POLYCHLORINATED BIPHENYLS (PCB)
Polychlorinated biphenyls (PCB) have been used In Industry for a variety
of purposes since 1929. Primary applications have been as electrical
transformer cooling liquids; capacitor dielectric liquids; heat transfer and
hydraulic fluids; dye carrier 1n carbonless copy paper; plasticizer in paints,
adhesives and caulking compounds; and filler in investment casting wax.
Most liquid filled transformers are cooled with mineral oil. This oil
can present a significant fire hazard in the event of a short circuit within
the transformer; therefore, oil-filled transformers are not allowed to be used
in hazardous locations such as buildings except when Installed 1n fire
resistant concrete vaults. Consequently, most transformers used in such
locations have been filled with non-flammable coolant liquids containing PCBs
as a major component. The liquids are known by the generic term "askarel" and
have been 1n common use since the 1930's in hazardous transformer
applications. Transformers with PCB concentrations greater than 500 ppm are
considered to be "PCB transformers".
An even greater number of transformers contain mineral oil with
relatively dilute PCBs. Those units were designed to use PCB-free mineral
oil, but now contain PCBs because of contamination that occurred in
manufacturing or servicing operations. Transformers containing oil
contaminated with PCBs at 50-500 ppm are considered to be "PCB-contaminated
transformers". The useful life of an undamaged transformer is usually about
40 years. Alternating current capacitors of various sizes have been installed
in electrical equipment ranging from large distribution systems to small
lighting fixtures (ballast). Nearly all of those units built before 1978
59.
-------
contain PCB liquids as dielectric fluid and most of the units are sealed.
Other types of electrical equipment, such as regulators, switches, circuit
breakers and cables also contain PCBs. PCB oils have been used In other ways
as well, Including such "non-contained" applications as sealing, coating and
dust control. Long term manufacture, cumulative use and gross environmental
distribution established PCBs as a ubiquitous contaminant in the United States
by the mld-1970's. That fact, along with the discovery of a spectrum of toxic
effects and potential carcinogenicity, prompted the inclusion of PCBs on the
list of materials regulated by the Toxic Substances Control Act of 1976.
Requirements of that Act and subsequent regulations have the following effects:
1. No further manufacturing of PCBs or distribution in commerce unless
exempted by EPA after July 1, 1979.
2. Authorization for use of large PCB capacitors located in restricted-access
electrical substations and in restricted-access indoor installations for their
useful lives; prohibition of the use of all other large PCB capacitors after
October 1, 1988.
3. The use of PCB transformers that pose an exposure risk to food or feed was
prohibited on October 1, 1985.
4. The use of network PCB transformers with higher secondary voltages
(greater than 460 volts) In or near commercial buildings will be prohibited on
October 1, 1990.
O'J.
-------
state agencies prefer destruction of hazardous wastes or their properties to
any attempt to perpetually contain them, but such destruction Is not
physically possible for some substances, notably the heavy metals. While most
wastes can be changed to a non-hazardous state, many of the available
processes leave residues which can only be managed by long-term Isolation and
immobilization.
Most of the generators in the region ship their wastes off-site within
90 days of generation, thus avoiding regulation as a storage facility. The
handling of hazardous waste beyond the point of generation is accomplished by
only a few organizations at a small number of facilities; that is, the number
of generators who store, treat or dispose of waste on-site is quite small, and
those who provide those services off-site are even fewer.
Regulated waste handling facilities must provide biennial reports of
activities. If those facilities are to continue handling hazardous wastes
beyond specified dates, depending on facility type, they need to secure
operating permits from EPA or an "authorized" state agency. The biennial
reports provide data on the number and nature of treatment, storage and
disposal facilities (TSDF's) in the region. Table 8 lists the numbers of
facilities in each state which handled hazardous waste in 1985. Eighty-eight
facilities were active in Region 10 (Alaska, 5; Idaho, 10; Oregon, 13;
Washington, 60). Several of those facilities conducted more than one type of
activity, so the columns in Table 8 do not sum to the total number of
facilities in each state.
41 .
-------
-pi
ro
TABLE 8
TREATMENT. STORAGE AND DISPOSAL FACILITIES. REGION 10. 1985
Number of Facilities
Storage
On-Site
Off-Site
Both
Subtotal
Treatment
On-Site
Off -Site
Both
Subtotal
Disposal
On-Site
Off-Site
Both
Subtotal
1
Total TSDF's
AK ID OR
1 76
2 3
2 1 4
3 10 13
1 3
2
1 3 2
1 1 1
1 1.1
5 10 13
WA
20
9
11
40
24
4
4
32
5
2
7
60
REGION 10
34
14
18
66
28
6
4
38
5
2
3
10
114
1. Columns do not sum to total number of facilities because some facilities conduct more than one
type of activity.
-------
Over half (34) of the storage facilities were generators who stored only
their own wastes. Fourteen establishments stored wastes only from others,
while 18 of them stored wastes generated both on-site and off-site. Treatment
was provided only for on-site generated wastes by 28 of the 38 facilities
which treated waste. Only 10 of them accepted wastes from other entities.
Similarly, disposal was accomplished exclusively on-s1te by five generators,
while an equal number of facilities disposed of wastes other than their own.
Most of the off-site treatment and disposal facilities are commercial in
nature, generally accepting wastes from all sources. No off-site treatment
facilities are found in either Alaska or Idaho; no commercial off-site
disposal facility exists in either Alaska or Washington, although recycling
and treatment operations function in both states, 1n some cases acting only as
"middlemen" for out-of state facilities. One landfill accepted hazardous
waste from one generator in Washington in 1985, and the Arco Prudhoe Bay Unit
in Alaska accepted hazardous waste from other parties at its injection well
until August, 1985.
Two major commercial landfills are operated in the region: Chem-Security
Systems, Inc. (CSSI), near Arlington, Oregon; and Envirosafe Services of
Idaho, Inc. (ESII), near Grandview, Idaho.
Destination of Region 10 Hastes
The disposition of wastes generated within Region 10 is shown in Table
9, including the amount of waste handled by each method. The reported tonnage
of waste handled in each state is higher than the amount reported as generated
43.
-------
TABLE 9
REPORTED DISPOSITION OF HAZARDOUS WASTE GENERATED
IN REGION 10, 1985, TONS
Method of Handllnq AK
In-State Storage
Container 112
Tank
Pile
Impoundment 112
Other
Subtotal 234
In-State Treatment
Tank 5
Impoundment
Thermal
Other
Subtotal 5
In-State Disposal
Injection Well 1111
Landf 1 1 1
Land Appl .
Impoundment
Other
Subtotal 1111
Shipped out of State 790
Total 2140
ID OR WA
70 2369 6917
43 3580 6426
148,729
6150
9
113 5949 168,231
60 354,021
4022
2437
11 379 1927
71 4401 358.385
230 7055 39474
1445
28982
1
230 7055 69902
1810 9097 70094
2224 26502 666,612
1,2
TOTAL
9468
10049
148,729
6272
9
174.527
354,086
4022
2437
2317
362.862
1111
46759
1445
28982
1
79298
81791
697,478
1 . Does not include RGB's
2. Includes 316.249T of wastewater which is treated and
discharged under NPDES permit, directly or through POTW's.
44.
-------
because: (1) waste from small quantity generators is included, (2) sequential
storage, treatment and disposal of the same waste sometimes results in double
or triple counting, (3) wastes generated in a prior year, and still in storage
at the end of a reporting year are counted in the facility reports, but not in
the generator reports, and (4) the delay between the date of shipment from a
generator and the date of handling by a facility near the first of a calendar
year can cause an imbalance in generator and facility reporting. The
methodology of this survey did not allow for reconciling those differences.
Nearly 700,000 tons of waste generated within the region were handled in
some fashion during the year. Ninety percent of the waste handling took place
in Washington, where wastewater treatment comprised one-half of the regional
total. Storage accounted for 175,000 tons of waste—again, mostly in
Washington.
In-state management of Alaska wastes was accomplished by storage and
deep well injection. Idaho landfilled (in-state) about 230 tons of its waste,
approximately one-tenth of the amount generated in that state. Oregon's
handling methods for its own wastes were quite evenly balanced among storage
(5949 tons), treatment (4401 tons) and disposal by secure landfill (7055 tons).
Import - Export
Possibly the most controversial hazardous waste management issue in any
region of the country, other than specific facility siting proposals, is the
matter of interstate transport of waste. Region 10 has its share of activity
45.
-------
in that regard, as all four of the states export hazardous waste and all
except Alaska Import substantial quantities for treatment and disposal. The
states of the region "trade" wastes not only among themselves, but also with
many states outside the region. The import/export matrix is shown in Table 10.
Within the region, Washington exported the most waste (70,128 tons) in
1985, but also imported a large amount because commercial treatment facilities
exist there. Washington generators shipped 62,405 tons of regulated waste to
Oregon and 2692 tons to Idaho (Figure 8). Over 5000 tons were sent outside of
Region 10. Washington imported 5506 tons of waste from Oregon, 443 tons from
Idaho and 32 tons from Alaska. The 32 ton figure for Alaska is based on
reports from generators in that state; facility reports from Washington show
253 tons of waste from Alaska. Problems related to waste definitions
apparently exist and the reporting inconsistencies were not reconciled during
this survey. No waste was imported by Washington from outside the region.
Thus Washington is a net exporter overall; a net importer with respect to
Alaska; a net exporter to Idaho; a net exporter to Oregon; and a net exporter
to the states outside the region.
Oregon, due to the presence of a major commercial waste disposal
facility, imported a large quantity of waste. By agreement between the
facility operator and the Oregon DEQ, wastes are accepted from only certain
states outside Region 10 (2760 tons in 1985). Oregon received 62,405 tons of
hazardous waste from Washington in 1985, 608 tons from Idaho, and 101 tons
from Alaska. Exports included 5506 tons to Washington and 143 tons to Idaho
(Figure 9). Nearly 9100 tons were shipped outside the region. Oregon is,
therefore, a net importer overall by a factor of six, and a net importer from
all three of the other Region 10 states, but is a net exporter to states
outside the region.
46.
-------
TABLE 10
IMPORT AND EXPORT OF HAZARDOUS WASTE
1
REGION 10 STATES, 1985, TONS
Shipped to:
Alaska
Idaho
Oregon
Washington
Shipped Out
of Region 10
Total Export
Imported from:
Alaska
Idaho
Oregon
Washington
Imported from
Outside Region 10
Total Import
Net Import
AK
16
101
32
641
790
0
0
0
0
0
(790)
ID
0
608
443
759
1810
16
143
2692
934
3785
1975
OR
0
143
5506
3448
9097
101
608
62405
2769
65874
56777
WA
0
2692
62405
5031
70128
32
443
5506
0
5981
(64147)
REGION 10
0
2855
63114
5981
9879
3694
(6185)
1. Does not include PCBs
2. ( ) = negative Value
47
-------
FtgurmB
Export of Hazardous Waste, 1985, Washington
CO
Tons Generated
Tons Exported: 7t,
-------
Export of Hazardous Waste. 1985. Oregon
Tons Generated: 2M13
Ton* Exported:
-------
Ul
o
Figure 10
Export of Hazardous Waste, 1985, Idaho
Tons Generated: 2,024
Tons Exported: 1810
-------
Export of Hazardous Waste. 1985. Alaska
Tons Generated: 1.609
Tons Exported: 790
-------
Idaho has a commercial landfill which receives waste from the other
Region 10 states and from many states outside the region. In 1985, Idaho
imported 2692 tons of hazardous waste from Washington, 143 tons from Oregon
and 16 tons from Alaska. Nine hundred thirty-four tons came from outside the
region. Exports included 759 tons of waste to states outside the region, 608
tons to Oregon and 443 tons to Washington (Figure 10). Thus, Idaho is a net
waste importer overall by a factor of 2; a net importer from Alaska; a net
exporter to Oregon; a net :iiporter from Washington; and a net importer with
respect to states outside the region.
Since Alaska has no commercial waste disposal facilities, no hazardous
wastes were imported there. Alaska shipped 32 tons to Washington, 16 tons to
Idaho, and 101 tons to Oregon (Figure 11). Over 640 tons were sent outside
the region. The state is, of course, a net exporter to all of the other
Region 10 states.
The 10,000 tons of waste exported from the region comprised 4.37. of the
total hazardous waste generated, exclusive of NPDES wastewaters. Imports to
the region amounted to 3694 tons. Region 10 is, then, a net exporter of waste
to the rest of the country. The materials sent out of the region for
treatment and disposal were distinctive in that they tended to be organic,
usually liquid, and represented waste groups which require very specialized
handling (particularly: product recycling, re-refining and high efficiency
incineration).
-------
Hazardous wastes Imported to the region were broad spectrum and were not
voluminous compared to in-region generated wastes (1.6%); however, since some
of the RCRA-regulated wastes from outside the region were destined for Idaho,
their relationship to wastes generated 1n that state was markedly different.
Non-Region 10 waste sent to Idaho was 1n the same order of magnitude as waste
generated there, and as will be seen later In this report, that volume was
eclipsed by the quantity of Imported PCB waste.
When Imports from all sources are viewed In relation to waste generated
In-state, Idaho and Oregon receive the "lion's share". Idaho Imports twice as
much as It generates, and Oregon gets four times Its "share". Note, however,
that Idaho exports most of the waste that 1t generates.
Waste Handling - All Sources
Table 11 details the handling of hazardous waste (exclusive of
wastewater) from all sources In 1985 according to location of the activities.
In this portrayal, however, the Washington NPDES-regulated wastewaters were
not included. "Tank" treatment refers to a variety of methods, whether
physical, biolological or chemical, in which the treatment takes place within
fabricated, confined facilities. "Impoundment", as it applies to both storage
and treatment, means an earthen facility, below or above ground level.
Well over one-half of the storage occurred on the site of generation
(Figure 12). The on-site storage was nearly all in the form of waste piles,
and containerized wastes were typically stored at off-site
-------
TABLE 11
REPORTED HANDLING OF HAZARDOUS WASTE FROM 1,2
ALL SOURCES AT REGION 10 FACILITIES, 1985, TONS
Method of Handling
Storage
Container
Tank
Pile
Impoundment
Other
Subtotal
Treatment
Tank
Impoundment
Thermal
Other
Subtotal
Disposal
Injection Well
Landf 1 1 1
Land Appli .
Impoundment
Subtotal
Total
Grand Total
on-site
off-site
on-site
off- site
on-site
off- site
on-site
off-site
on-site
off- site
on-site
off- site
on-site
off-site
on-site
.off-site
on-site
off site
on-site
off -site
on-site
off- site
on-site
off-site
on-site
off-site
on-site
off- site
on-site
off-si te
on-site
off-site
on-site
off-site
AK
75
37
. 122
197
37
5
5
496
615
496
615
698
652
1350
ID OR
3
1 37 1 400
1 1500
60 2300
10 1400
725
725
197 4425
11 3625
60
16,500
11
627
71
17,127
11
4740 65,200
11
4047 65,200
268 4436
4058 85,952
4326 90,388
WA
2753
5474
1853
8530
91,729
57,000
6150
9
102,485
71,013
4854
31,806
2437
1927
9218
31,806
32,026
7448
1445
28,982
62,453
7448
174,156
110,267
284,423
TOTAL
4365
7012
4213
9940
91,729
57,000
6997
725
9
107,304
74,686
4919
31,806
16,500
2437
1938
627
9294
48,933
496
615
32,037
76,695
1445
28,982
62,960
77,310
179,558
200,929
380,487
1. Does not include NPDES waste waters or RGB's over SOppm
2. Includes imports
3. On-site, off-site distribution estimated
54
-------
Figure 12
Location of Hazardous Waste
Management Facilities, Region
10, 1985
Storage
181,990 tons
Treatment
58,227 tons
Disposal
On-Site
9,294 tons
(16%)
On-Site
62,960 tons
(44.9%)
On Site
107,304 tons
(59%)
Off-Site
77.310 tons
(55.1%)
Off-Site
48,933 tons
(84%)
Off Site
74,686 tons
(41%)
140,270 tons
-------
facilities while awaiting final disposition. Eight-four percent of the waste
treatment was accomplished at off-site locations, all In Oregon and
Washington. On-s1te treatment occurred to a relatively minor extent in all of
the stat_i except Oregon, which reported none. Fifty-five percent of the
final disposal in the region was done at off-site facilities, primarily in
Oregon. Washington industries landfilled a large quantity of material on-site
(32,036 tons).
Alaska
The primary handling method practiced in Alaska was injection into a
deep aquifer at one North Slope disposal site. The well was used to dispose
of large volumes of non-hazardous oil production and process waters, and
received hazardous waste from the Prudhoe Bay Unit at which the well is
located. Hazardous waste from other parties was taken until August, 1985.
Over half (615 tons) of the 1111 tons of hazardous waste reported to be
disposed of through the well came from off-site generators. Those off-site
generators and several others also sent larger volumes of wastes not reported
by the generators as hazardous; as previously mentioned, it is likely that
about 4600 tons of those wastes were, in fact, hazardous by definition.
Approximately 15% of the reported wastes were stored for at least 90
days, mostly on-site. Virtually no treatment of waste occurred in the state.
Idaho
Two hundred eight tons of waste were stored in Idaho during 1985. A
small quantity of material (70 tons) was treated on-site. The presence of a
commercial landfill attracted 4047 tons of hazardous wastes for disposal (all
off-site).
-------
Oregon
Storage facilities In Oregon handled over 8000 tons of hazardous waste
1n 1985, about half on-slte and half off-site. Treatment of corrosives by
Impoundment (16,500 tons) was accomplished at the Arlington facility (all
off-site). The same facility landfilled approximately 65,000 tons of
hazardous waste (exclusive of PCB waste) off-site plus a small amount
generated on Its own premises. Slightly less than 62,000 tons of the total
waste handled at the Arlington site originated in Washington.
Washington
Nearly 329,000 tons of waste were handled by various facilities in
Washington. About 208,000 tons were stored, three-fourths in waste piles
(half on-site). Over 50,000 tons of waste were stored in containers and
tanks, mostly off-site. "Tank" treatment was applied to about 46,000 tons,
while 12,000 tons were treated by other means. Disposal, which totaled almost
70,000 tons, was done mostly on-site (89%). More than 30,000 tons of waste
were impounded.
Current Methods
The most common methods of management employed in the region for toxic
metal solutions and sludges were chemical precipitation, filtration and land
disposal. Corrosives were handled primarily by neutralization and landfill.
Toxic anion solutions have usually been dealt with by chemical oxidation
(cyanides) and by landfill (most other anions). Inorganic residuals and
sludges were all landfilled or placed in long-term storage in waste piles.
Discarded commercial chemical products were landfilled.
57..
-------
Some non-halogenated solvents were sent to fuel blenders; others were
evaporated, distilled, reprocessed or landfllled. Halogenated solvents were
recycled by distillation and condensation or disposed of by evaporation and
landfill. Reactive wastes were usually landfllled or treated thermally.
Paint residuals were often landfilled, although some corrosive paint wastes
were neutralized, halogenated paint wastes were distilled for recovery, and
the metals were precipitated from some others. Pesticides and remedial action
cleanup wastes were mostly landfilled.
-------
5. All radial PCB transformers and lower secondary voltage network PCS
transformers In use In or near commercial buildings must be equipped with
electrical protection to avoid transformer failure caused by high current
faults.
6. All radial PCB transformers with higher secondary voltages (above 480
volts) in use in or near commercial buildings must be equipped with protection
to avoid failure caused by low current faults.
Transformers and capacitors occasionally fail and leak, sometimes causing
contamination of equipment and soil. On an annual basis, about 3% of the PCB
transformers can be expected to leak or will be associated with a spill.
Approximately 2% of large capacitors will lose fluid each year, usually by
fairly violent rupture, thus more widely scattering the contents than do
transformers. Proposed TSCA regulations incorporate requirements for cleaning
up areas contaminated by spill of materials containing 50 ppm or greater
PCBs. In the past, various regional policies have required cleanup to levels
in the 25-50 ppm range in contaminated soil. National standards were
published in April, 1987 for cleanup of recently contaminated materials.
Other specific standards will be determined on a case-by-case basis.
The RCRA amendments of 1984 and EPA regulations establish disposal rules
pertaining to PCB wastes. Disposal of liquid wastes with a PCB concentration
greater than 500 ppm is allowed only in an incinerator approved by EPA or by
an approved alternative treatment method providing an equivalant reduction.
Liquid wastes containing PCBs with concentrations of 50-500 ppm may be
disposed of by any of three methods:
-------
(1) EPA approved Incinerator, (2) EPA-approved high-efficiency Industrial
boiler, (3) EPA-approved alternative treatment method achieving a level of
performance equivalent to an approved Incinerator or boiler.
Transformer carcasses which have been drained and flushed may be
landfllled. Large capacitors are usually shipped Intact to an Inclncerator.
Very small non-leaking capacitors (three pounds fluid or less) may be placed
in municipal landfills. Waste materials contaminated at less than 50 ppm PC8s
are not controlled by TSCA, but are regulated as a hazardous waste by the
State of Washington when generated at the rate of 400 pounds per month or
batch.
Approximately 121,000 (askarel) PCB transformers are currently In use in
the United States; there are about 20 million mineral oil transformers of
which perhaps 7.5 million contain 50-500 ppm PCBs. Just less than 3 million
large PCS capacitors are still in use. When those national estimates are
disaggregated on the basis of electrical energy use in each northwest state,
Region 10 appears to have about 7000 PCB transformers, over 400,000
contaminated mineral oil transformers and 180,000 large PCB capacitors. Based
on population rather than electrical energy use, those regional estimates
would become 4500; 280,000; and 110,000, respectively.
PCB Waste Generation
Based on national data, Region 10 would be expected to have had about
7000 tons of askarel is use in 1985. PCB waste ..1 generation (greater than
500 ppm) would have been approximately 850 tons in 1985, if the region
-------
produced an equal percaplta share of the national total. Obviously, crude
dlsaggregatlon of national data Is, at best, an imprecise means of estimating
current and future PCB waste generation, but 1t is a checkpoint for other
methods.
Electrical Utilities
The primary PCB waste source in the region is the electrical utility
Industry. Direct information reganing that source was secured through a mail
survey of Region 10 utilities conducted 1n the fashion described in the
methodology section of this report. The companies were asked to report the
quantities of PCB oils, capacitors, transformers, and soils and other solids
which were disposed of 1n the most recent year of record. Estimates were also
requested of the percentage of PCB materials already removed from their
systems, the number of years remaining in their PCB disposal programs, the
probable peak year for waste disposal and the population served by the
utility. They were also asked for an opinion regarding the need for PCB
disposal facilities in the northwest region.
Responses were received from 58 utilities of wide variety in size which
serve a total population of approximately three million (1/3 of total
population). The composite report of annual PCB waste generation and disposal
is presented in Table 12 (data relate to 1985 or 1986). One hundred
seventy-three tons of waste PCB oils over 500 ppm were handled, along with 524
tons of waste oil with 50-500 ppm PCBs and 175 tons of oils with less than 50
ppm PCBs.
63.
-------
TABLE 12
1
ANNUAL PCB WASTE GENERATION AND DISPOSAL
2
REPORTED BY 58 ELECTRICAL UTILITIES, REGION 10, 1985/1986
Tons
Over SOOppm 50-500ppm Less than SOppm
Oil
Incineration 143 415
Chemical Treatment 30 109 7
Landfill 51
Fuel blenders 117
Soils, Debris,
Misc. Equipment
Incineration 3 5
Chemical Treatment 0.2
Landfill 77 129
Capacitors
3
Incineration 309
Transformer
Carcasses
Landfill 265 446
1. All incineration outside Region 10; some landfill outside Region 10.
2. Serving a total population of approximately 3 million; population of
region is about 8.8 million
3. Including oil; weight of oil approximately 30% of total
64.
-------
Eighty percent of the high level PCS oil was incinerated (out of region)
and the remainder was chemically treated. About 807. of the 50-500 ppm oil was
also shipped for .incineration, while 20% was chemically dechlorinated. The
largest portion of the Washington-regulated waste (less than 50 ppm PCS oils)
was sent to fuel blenders; some was landfilled.
Three hundred fourteen tons of capacitors were shipped for incineration.
•
Contaminated soil was landfilled (206 tons) or incinerated (8 tons).
Transformer carcasses totaled 711" tons; all were ultimately landfilled or
recycled. The survey data were extrapolated to the entire region on the basis
of population served, which is highly speculative. By this method, each value
in Table 12 is tripled.
"The questionaires were divided into.three groups according to size of
population served to facilitate analysis of the responses regarding furthur
disposal patterns (population greater than 100,000 * large; 20,000 - 99,999 *
medium; less than 20,000 =small). Through these groupings, weighted averages
of estimated percentage of PCB waste disposal completion, remaining years of
disposal program and peak future year for waste disposal could be computed.
Weighted averages were determined because the waste disposal programs of the
large utilities will establish and dominate the actual pattern for the region.
The results are reported in Table 13. The indication is that the waste
PCB disposal programs of the electrical utilities are just under one-half
completed (individual programs ranging from 0 - 99% complete); an average of
11.4 years of PCB disposal remain (range = 0-30 years); and the peak disposal
65.
-------
TABLE 13
ESTIMATED PCB WASTE GENERATION PATTERN
58 ELECTRICAL UTILITIES, REGION 10
Number of % Disposal Years of Peak Year
Companies Complete Disposal Remaining for Disposal
(Ave.XRange) (Ave.XRange) (Ave.XRange)
Large Companies
8 51 (15-97) 13 (4-20) 1988 (1987-1991)
Medium Companies
16 34 (5-100) 11 (0-30) 1989 (1987-1990)
Small Companies
34 54 (0-99) 7 (1-25) 1988 (1987-1990)
Weighted Averages
47 (0-100) 11.4 (0-30) 1988
TABLE 14
ESTIMATED PCB WASTE GENERATION, REGION 10, 1985
(ALL SOURCES)
Tons
Over 500 ppm 50-500 ppm
Transformer Oil 450 - 550 1200 - 1600
Soils, debris 2000 - 3000
Misc. Equipment
1
Capacitors 800 - 1200 10 - 20
wi th oi1
Transformer 1000 - 2000 1000 - 2000
Carcasses
1. Oil approximately 307. of total weight
66.
-------
year will be 1988. Informal questioning of utility representatives resulted
In the conclusion that the rate of PCB waste generation Increased markedly
from 1985 to 1987, will remain steady until about 1991, and will then decline
(rapidly for high-level PCB oils, and slowly for low concentration oils). The
timing of the peak is determined by regulatory requirements phasing out
non-substation capacitors by 1988. Under current regulations, the electrical
protection requirement for grid network askarel transformers is assumed to be
tantamount to a phaseout by 1990.
Thirty-nine of the 58 respondents in the utility survey commented
regarding the need for PCB management facilities in the northwest.
Twenty-eight of them felt that an incinerator of some sort should be made
available within Region 10. A facility sited in Alaska was suggested by four
companies and three proposed mobile incineration. Two respondents thought
that the utility industry (association?) should operate its own disposal
facility. Seven companies wanted to have dechlorination facilities available
in the northwest, and three people recommended facilities specifically
designed to handle wastes with PCBs of less than 50 ppm. Two responses
related to a need for more recycling and scrapping operations geared to
handling PCB-contaminated equipment.
Other Industry
Manufacturing industries use certain electrical equipment which does not
belong to the utility companies. Waste PCBs from those sources are difficult
to determine. Discussions with industrial representatives and review of
national data and limited regional records place the generation rate at about
one-third of that produced by utilities (perhaps one-half or more for
contaminated soiIs).
67 .
-------
Military Installations
The Department of Defense manages PCB waste from active military sites
through various contracts issued by the Defense Reutilization and Marketing
Service to operators of commercial disposal facilities. The Service was
requested to provide data pertaining to PCB waste generation and disposal in
Region 10 in 1985. Wastes included transformers, capacitors, liquids, soil
and debris, all of which totaled 700 tons. Nearly all of the waste came from
Alaska and Washington. About 450 tons of PCB waste were contaminated soils
from active Alaskan military facilities. Over 600 tons of waste were shipped
outside of Region 10 for disposal. Idaho disposal facilities received all but
a small fraction of the remainder of the waste from DRMS.
DRMS reports that the PCB waste materials from Alaska will Increase each
year until 1991, and then decrease substantially. The wastes from Washington
and Idaho active military sites have already peaked and are now decreasing
each year.
The Corps of Engineers operates a program to clean up inactive and
abandoned sites in federal ownership in Alaska. That program, funded through
the Defense Environmental Restoration Account, deals with hazardous materials
of all kinds, including PCB wastes. Over 350 sites have been identified for
possible cleanup. Many mining operations and World War II communications
facilities operated on-site power generators; their equipment contained
substantial quantities of PCB oil, some of which still exists within intact
electrical equipment and some of which was spilled on the soil. In many
cases, other hazardous materials are present as well.
68.
-------
While a reliable determination of PCB waste generation for any particular
year 1s not possible, EPA staff estimate that the total waste production from
this program could well surpass 500 tons per year, much of which will be PCB -
contaminated soil, equipment and oil. The amount will depend primarily on the
cleanup standards ultimately Imposed. A 501 difference in the cleanup
standard (PCB concentration allowed to remain) could produce a tenfold
difference in the amount of soil to be treated at a site.
Regional PCB Waste Estimation
Table 14 presents a synthesis of the PCB waste generation pattern from
all sources 1n Region 10 in 1985. The following estimates were made: Total
PCB oil over 500 ppm, 450-550 tons; PCB-contaminated mineral oil, 1200-1600
tons; soil and miscellaneous materials, 2000-3000 tons; capacitors with oil,
800-1200 tons; and transformer carcasses, 2000-4000 tons. The potential error
in the original extrapolation is quite high, but the ranges presented should
be reasonably accurate.
A projection of PCB oil waste generation from all sources was made, based
on the foregoing information. As shown in Figure 13, the hypothetical
generation pattern for high concentration oils includes a general peak around
1988 followed by a precipitous decline near 1990, reflecting the likely
removal of most grid network askarel transformers and certain large
capacitors. In contrast, the low concentration oils will remain in the waste
stream for up to 30 years, although most will be gone by the end of the
century.
69.
-------
in
C
O
1600
1400
1200
1000
800
600
400
200
1985
50-500 ppm
500+ ppm
1987
p
*
!*** *
1993
1989 1991
Year
Figure 13
Hypothetical PCB Oil Waste Generation,
Region 10
1995 2005
-------
PCB waste disposal volumes within Region 10 are a matter of record.
Total disposal (all by landfill) In the region In 1985 reached approximately
17,000 tons, over 13,000 tons In Idaho. Since 10,000 tons of that waste came
from outside the region, the rate of disposal bore no relationship to the
Region 10 waste generation.
71 .
-------
PROJECTED HAZARDOUS WASTE GENERATION
Hazardous waste generation In future years will be determined by a broad
range of factors. Among the most apparent factors expected to affect the
volume of waste produced are economic growth, regulatory changes,
implementation of waste minimization practices, and remedial action programs
(CERCLA; RCRA corrective actions; state-imposed or assisted projects; leaking
underground storage tanks; military programs).
Economi c Growth
Basic economic analysis is beyond the scope of this survey. Moreover,
prediction of economic growth has been shown to be an Imprecise practice in
past years even when attempted by experts armed with industry-specific data.
It will suffice for the purpose of this exercise to borrow an annual growth
rate value from the projections offered by the Northwest Power Planning
Council in its 1986 electric power plan. At the risk of oversimplification,
one might reduce those projections to a low forecast of 0.21 per year growth
in manufacturing and services, a high forecast of 2.7% growth and a mid-level
growth forecast of 1.6%. Even if one of those values ultimately describes the
actual growth of the overall economy, there will be, of course, quite
different rates of growth (or decline) for each economic sector.
It is fairly safe to assume, however, that substantial growth will occur
over a period as long as that in question here (20 years) in most of the
sectors which produce the bulk of the hazardous waste in Region 10.
Possessing no basis for refinement, the midlevel estimate of 1.6% growth per
year will therefore be applied across the board beyond 1986 in calculating
future hazardous waste generation as it is affected by the economy.
-------
The economic growth rate will be assumed to be the same In all four states,
although Alaska may have the greatest potential for growth beyond the 1985
base year because the oil production industry had already declined
substantially by then; it will very likely recover to some degree. The
projected effects of economic growth are shown in Table 15 along with other
factors affecting waste generation.
Haste Minimization
"Waste minimization" is that set of practices which decreases the volume
or toxldty of wastes and reduces the need for treatment and disposal of that
waste. Those practices include waste exchange, recycling, reuse and
reduction. "Waste reduction" refers to the more limited process of avoiding
the production of waste through in-plant practices. The distinction is
important only for the purpose of improving communications and determining
compliance with RCRA.
Congress established a policy through the RCRA amendments to the effect
that where feasible, the generation of hazardous waste is to be reduced or
eliminated as expeditlously as possible. The RCRA regulations require that
waste generators report their waste minimization practices and certify that
those practices produce the best public health result economically
attainable. Actually, the regulations seem to require true waste reduction
relative to product output level. They also establish those activities as the
first priority in dealing with the hazardous waste problem.
73.
-------
TABLE 15
ESTIMATED EFFECTS OF VARIABLE FACTORS ON FUTURE
HAZARDOUS WASTE GENERATION - REGION 10
1985 Base
1
240.000 Tons
Increase (Decrease) From Prior Listed Year (Tons)
1986 1987 1988 1989 1990 1995 2000 2005
Cleanup Waste
(Including PCB)
2000 50,000 (25,000)
0 (20,000)
Economic Growth
3800 3900 4000 4100 4200 25,000 30,000 35,000
Haste Reduction
(7200) (7000) (6800) (6600) (6400) (30,000) (10,000) (9000)
PCB Waste
(Electric Utilities)
4000
2500
(500) (3500) (2000) (1000)
Net Change
2600 49.400 (27.800) (2500) (2700) (8500) (2000) 25000
1. Includes small quantity generator waste
2. PCB waste not in base; 1985 base tonnage added to 1986 factor
3. Not in base; 1985 base tonnage added to 1986 factor; oil and transformer carcasses only
-------
In practice, however, waste reduction has been clearly subordinated to
more traditional "end of pipe" treatment and disposal techniques, due to
several notable disincentives: lack of capital, unfamiliar methods, lack of
information, technical limits of process, product quality concerns, and the
need to revise environmental permits when waste streams are rechanneled.
Nevertheless, strong incentives for waste reduction will probably eventually
prevail, such as the increased cost of waste management, TSDF siting
difficulties, permitting burdens and corrective action requirements, financial
liability of hazardous waste generators, shortages of liability insurance, and
public perception and pressure.
Waste reduction techniques for manufacturing plants fall into a few basic
categories: (1) product substitution; that is, the manufacturers can choose to
develop a different .product which has the same practical function as a current
product but requires no hazardous raw materials, (2) raw material substitution
in the production of the same product, (3) product reformulation, so that less
of a hazardous component is used, (4) spill control in manufacturing plants,
(5) optimization of process controls (timing, measuring, automation,
computerization), (6) process redesign or modification, such as change in
equipment to allow reuse of materials or in-line recycling, and (7) industrial
good housekeeping, to stop waste and avoid cross-contamination of materials.
The technological means to reduce waste are part and parcel of each
production process itself. In view of the multitude of physical plants, no
two of which are alike, and the current dearth of comprehensive data, an
accurate forecast is virtually impossible. However, anecdotal information
indicates that large waste reductions from most sources are technically and
•5.
-------
economically feasible. Such evidence has led the Minnesota Waste Management
Board to conclude that hazardous waste produced In that state can be reduced
by about 501 relative to 1984 by the year 2000. Missouri has estimated actual
reduction at four percent 1n 1987. New Jersey expects a 12% reduction over a
six year period, relative to production. A 16% reduction was forecast In New
York for 1988 alone, based on a study of 34 waste types, 24 of which would
experience no reduction at all.
Existing literature reviewed by the U.S. Congress Office of Technology
Assessment revealed that In 314 case studies of actual waste reduction
programs, 110 sources used In-process recycling, 30 used plant operation
changes, 96 used altered process technology, 19 changed process Inputs and
three changed the end product. Fifty-six also added new management practices
for the remaining wastes.
The EPA Office of Solid Waste has estimated potential nationwide
reduction potential for 22 industrial categories. Possible reduction
percentages for some of those industries of particular interest in Region 10
are;
Electroplating (20-48%)
Metal finishing (18-33%)
Paint manufacturing (18-33%)
Petroleum products (12-30%)
Printed circuit boards (18-48%)
Wood processing (13-40%)
Metal parts cleaning (30-48%)
Paint application (28-43%)
76.
-------
Some of the Industries listed above have already reduced waste streams by as
much as 75X; the potential reduction figures shown would apply to the amount
remaining at this time.
No rigorous analysis of the yet unrealized waste reduction potential In
Region 10 has been attempted by anyone. Such information will not come easily
under any circumstances. Industry is free with general information about past
success, but not about certain methods. Very often, technology is either not
transferable or is considered proprietary because it involves production
processes. Moreover, recognition of a high potential for waste reduction Is
thought to build a stronger case for government-imposed quotas, an eventuality
considered by all Industries to be unfair and impractical.
Most northwest waste generators express optimism for success of voluntary
programs. Informal contacts with industrial representatives made by the
Oregon DEQ have revealed a consensus that substantial waste reduction has
already occurred in that state, but that much more is possible. In
particular, it was suggested that the volume of solvent-contaminated materials
(mostly aqueous solutions) can be economically reduced by up to 807.. The
electronics and transportation equipment industries seem to be •-'olng quite
well in implementing programs. While a high potential for waste reduction is
generally acknowledged, a comprehensive industry-specific analysis is not
available. Certain reduction and recycling practices are likely to be most
applicable to various waste groups, however, and some of those practices are
listed in Table 16 along with disposal options in the following section of
this report.
77.
-------
Nhen projecting future waste management facility needs, the pertinent
question 1s not how much reduction can be realized, but rather, how much wl 11
be realized? Neither the federal government nor the states of Region 10 have
adopted clear and aggressive programs to secure waste reduction, but several
specific policy options have been identified. Assuming that some of those are
placed into action soon, the results should at least approximate the predicted
national norm. Thus, for the purpose of this analysis, an average value
gleaned from state and federal agency estimates will be used. That figure
seems to fall somewhere between 30X and SOI reduction over the next 20 years,
the largest part of which should occur in the first 10 years. Therefore, when
calculating the effect of waste reduction on the future Region 10 waste
generation pattern, three percent per year for ten years followed by two
percent per year for the next ten years is assumed to be a rational scenario
(Table 15).
Remedial Action Programs
Future remedial action projects will produce unknown quantities of
formally designated hazardous waste and other materials which will be managed
as hazardous waste. Such projects will respond to a variety of occurrences
and programs ranging from incidental transportation-related hazardous material
spills to the complex national "superfund" effort directed toward past
pollution problems. Other projects will result from the independent programs
of industries and other private landowners, from RCRA compliance actions, and
from cleanups at sites in federal ownership. State regulatory and financial
assistance programs will spawn still more cleanups.
-------
The specific nature and volume of the future composite waste stream from those
projects Is yet to be determined. Each site win require special study and
remedial action. The regulatory programs are essentially In their Infancy.
Some general conclusions can be drawn, though, about the potential need for
off-site handling of hazardous wastes 1n Region 10 relative to past activity
levels.
Cleanup projects overseen by federal and state agencies in 1984 produced
45,000-50,000 tons of wastes which were taken to approved hazardous waste
disposal facilities. The bulk of that year's cleanup materials (about 42,000
tons) came from one project in Washington (arsenic-contaminated soils, etc.).
In 1985, off-site disposal of waste from formally regulated cleanup projects
fell in the range of only 2000-3000 tons. No estimate is available for 1986.
The off-site disposal of such materials in 1987 is expected to be very high
again, largely due to the activation of major projects in Washington, viz..
soil removal at the Western Processing superfund site (possibly 50,000 tons)
and removal of demolition material from one of the Commencement Bay sites. It
can be readily seen that annual waste generation from cleanup projects is
highly dynamic. The "CERCLIS list" includes over 1000 sites in Region 10
which are to be studied to some degree regarding possible remedial action.
Sixty-five percent of those sites are known to have toxic substances present.
Heavy metals have been observed at 34% of the sites and are alleged to be
present at another 57. of sites. Organics are known or suspected at 25% of the
sites; 21% may have oily wastes, 21% probably have solvents, and PCBs are
known to exist at 107. of the sites (307. in Alaska). Liquids are present at
over 60% of the sites, solids at about one-half of the sites, and sludges at
approximately one-third. Contaminated soil could be a problem at more than
40% of the sites.
-------
Studies of candidate sites, to date, have resulted in the placement of
only 27 sites on the National Priority List. Eleven more sites have been
formally proposed for inclusion. Twenty-eight of the sites are in Washington,
six in Oregon, four in Idaho, and none in Alaska. The sites range from 0.5 to
15,000 acres in size; however, with the exception of the two Commencement Bay
sites in Washington (each 15,000 acres), the Bunker Hill site in Idaho (13,400
acres) and the proposed Ault Field site in Washington (2075 acres), none is
larger than 455 acres. In most cases, the seriously contaminated areas are
much, smaller than the site boundaries would suggest.
Schedules for studying each NPL site will depend on funding priorities
and many other factors. Formal investigation periods are typically two years
long and none of those pertaining to large projects is yet complete, although
some remedial actions have taken place. Actual cleanup of the current NPL
sites will likely be staggered throughout the next decade and some years
beyond. In very general terms, it appears that the actual cleanup phase of
the superfund projects in Region 10 will center around the mid-1990's. Waste
disposal should accelerate from 1989 to about 1995 and then reduce
substantially.
The types of hazardous materials present on the sites represent many of
the RCRA waste categories, but seem to be dominated (in volume) by toxic
inorganic substances. Some such materials will probably be stabilized in some
fashion and remain on-site, especially so for projects which will deal mostly
with dry heavy metals. Other materials, particularly the toxic organics, will
30.
-------
be treated on-slte or taken to approved off-site TSDFs. Current EPA policy
regarding CERCLA wastes requires that all such materials taken off-site,
whether classified as hazardous wastes or not, must be handled at RCRA or
TSCA-approved facilities which are in compliance with regulations.
No estimate of waste to be produced from RCRA facility compliance actions
1s possible, but those sources will probably increase for a few years.
Cleanup projects at active non-military federal facilities (Hanford, INEL,
etc.) have not been clearly described either, but several hundred small sites
might need attention. Cleanup wastes from active military sites in the region
will increase each year until about 1991 and then decrease quickly (the 1991
level may be about twice the 500 tons produced in -1985). Abandoned and
inactive federal sites could yield over 1000 tons per year for at least 10
years, mostly in Alaska.
A specific federal program is being implemented to deal with leaking
underground storage tanks. Most of the tanks in question contain petroleum
products, but other materials are also involved. Ultimately, tank owners will
be required to upgrade their equipment and, in the meantime, responsible
parties must clean up spills. The inventory of tanks shows 47,000 in
Washington, 27,000 in Oregon, 10,000 in Idaho and 7000 in Alaska. One-quarter
or more of those tanks can be expected to be leaking by 1990. Little waste
from spill cleanups is expected to reach RCRA TSDFs. Two primary reasons for
that conclusion are suggested by regulatory personnel. One is that the
standard practice for handling contaminated soil is to expose it to the
atmosphere, evaporate the volatile materials, and return the soil to its
original place (this process might violate RCRA rules if certain toxic
residuals are left in high concentration). The other factor relates to the
normal practices for treating contaminated groundwater. Spillage of large
-------
amounts of liquid, such as the Curtis Road site In Boise, Idaho (over
2,000,000 gallons of gasoline) Is captured, pumped and reprocessed as product;
however, some spills might result In a small amount of liquid or solid waste
disposal.
Estimation of waste types and volumes and prediction of waste management
methods to be selected for CERCLA projects are possible for only a few sites
at this time, according to EPA site managers, and no purpose would be served
by detailing those here. Discussions with those site managers and others lead
to the conclusion that the annual volume of materials from CERCLA and
non-CERCLA sites which will be taken to.approved TSDFs will not often exceed
the amount reported in 1984; in fact, far less than that amount will be
generated In some years.
The average rate of potential landfill disposal will probably fall near
the center of the broad range bounded by the reported values for 1984 and 1985
(from 2000 to 50,000 tons). For the purpose of estimating future commercial
landfill needs for cleanup wastes, a rough median value from those extremes
was arbitrarily chosen as an annual increment for off-site disposal until 1995
(25,000 tons per year)even though a general increase is actually expected from
1988-1995; however, in the interest of conservatively estimating available
disposal capacity, the highest number will also be considered when comparing
that available capacity to potential waste generation. A much lower figure
will actually result if a large percentage of the CERCLA wastes meet the
criteria for the landfill ban in 1988 (landfill ban discussed in "Technology"
section of this report).
-------
Regarding the fraction of hazardous materials on remedial action sites
which will require management other than on-site stabilization or off-site
landfill, prediction is also difficult. However, enough information exists to
project a general range of volume of materials from all cleanup sites which
might be amenable to incineration. Waste soils and other solids and sludges
with significant organic contaminants could reach 20,000 tons per year, though
incineration is an unlikely treatment method for any more than 5000 tons per
year. Washington and Alaska are expected to generate far more than the other
two states and perhaps nearly equal amounts.
Regulatory Change
The amount of material required to be managed as hazardous waste can be
dramatically'altered by future amendments to state and federal laws and
regulations. New listings of materials as hazardous wastes are possible at
any time. Though most of the following types of waste are not likely to be
fully regulated in the foreseeable future, they are under continued scrutiny.
Waste motor oil from automobiles and industries is regulated only in that
combustibles with total halogens in excess of 4000 ppm may be incinerated only
in equipment meeting RCRA hazardous waste standards; other used oils meeting
certain specifications can be burned in any boiler or in industrial furnaces;
off-specification used oil may only be burned in industrial boilers or
furnaces. Although much of the used oil is recycled in some fashion, a full
listing of those materials as hazardous wastes would add greatly to the
potential need for RCRA-approved waste management facilities. Waste oil
generation in Region 10 is estimated to be at least 60,000 tons per year.
83.
-------
Mining wastes associated with extraction and beneficiation processes are
exempted from regulation as hazardous waste by federal law. Any change in
that exemption could affect millions of tons of materials nationally.
Certain dioxin-containing wastes not currently covered by the hazardous
waste criteria might be added to the list. Since much of that waste is now
handled as hazardous waste by choice, further listing would have little effect
on facility needs.
Some of the wastes associated with oil production could conceivably be
defined as hazardous in the future. Such wastes might include produced water
separated from crude oil streams, liquid wastes from wel1-workovers, and
drilling mud and cuttings. Alaska generates up to 10 million tons of these
materials annually. '
Regulatory changes other than waste definition can also affect future
hazardous waste generation. For example, the adoption of increased disposal
taxes and fees, disallowance of certain management techniques, and development
of waste reduction incentives could all result in a lower waste generation
rate. No forecast of specific amendments is possible.
Summary
Estimates of the major variable factors affecting the future rate of
hazardous waste generation are shown in Table.15. Note that the chosen values
represent an effort to predict only the order of magnitude of such factors so
that the future generation pattern can be projected. Substantial variability
34.
-------
will actually be seen year by year. Figure 14 displays a very generalized
waste production pattern based on the factors previously described.
The known Increase In cleanup waste 1n 1987 followed by the assumed high
levels from those sources for several years maintains the projected generation
rate above the 1985 base through the end of the century. Without the cleanup
wastes, the generation rate Is projected to decrease slightly from the 1985
base by 1988, reach a low point around 1995 and rise above the base level
after the year 2000. Considering the large degree of uncertainty associated
with the variables used to construct the projection, the depicted fluctuations
are quite hypothetical. The only conclusion which can be tentatively drawn 1s
that economic growth might eventually override the benefits of waste
reduction, and therefore, the volume of waste to be managed in Region 10 will
likely increase to some degree over the next 20 years.
85.
-------
CD
290,000,,
tons
240,000
tons
(1985 Base)
190,000
tons
With cleanup waste
Without cleanup waste
1985 1986 1987 1988 1989 1990
1995
2000
2005
Figure 14
Generalized Projection of Future Hazardous
Waste Generation, Region 10
-------
HAZARDOUS WASTE MANAGEMENT TECHNOLOGY
A few basic treatment and disposal techniques have been commonly applied
to the management of solid and liquid hazardous wastes for many years. Among
them are physical phase separation, neutralization, precipitation, biological
treatment, Incineration and landfilUng. Other more specialized methods have
been used less frequently.
Recently adopted disposal standards have prompted the emergence of a
growing number of new waste management concepts and variations on the
established processes. The new technology runs the scale from simplicity to
high sophistication. While the need for new technology is partially spawned
by recent regulatory change (notably RCRA waste treatment and disposal
requirements), the practical application of that technology has been slowed to
some degree by the companion rules which control Its use. The EPA Hazardous
Waste Engineering Research Laboratory is attempting to test, assess and
certify the capabilities of numerous proprietary treatment systems and
prospective commercial facilities in time to assure the availability of enough
waste management capacity to meet compliance deadlines.
Region 10 hazardous waste generators have entered a period of constant
assessment of the dynamic waste management industry as they plan their
response to regulatory and economic dilemmas. Current management practices in
the region are fairly well known and were discussed in general in a foregoing
section of this report. A somewhat more comprehensive view of those current
practices is presented by Table 16. Also shown is a more detailed breakdown
of waste types and estimated 1985 generation tonnages as well as a listing of
waste management methods known to be available at this time (not necessarily
in Region 10). A basic classification of waste reduction and recycling
potential for each waste type is also offered.
87.
-------
TABLE 16
CURRENT AND FUTURE HAZARDOUS WASTE
MANAGEMENT TECHNOLOGY. REGION 10
oo
oo
Waste Type
NONHALOGENATED
SOLVENTS AND
OILY ORGANICS
Oily water,
emulsions
Est. Generation Current
1985, Tons Methods
3500 Deep Well
injection
Fuel blending
Available
Methods
Emulsion breaking
Oil /water separation
Fuel Incineration
Reduction
Potential
XX
Separation
streams
Recycling
Potential
X
Fuel
blending
Separation sludge, 6361
Slop oil emulsion,
Tetraethyl lead
sludge, oily sludge
Solvents, 3600
Still bottoms
Polymeric solid 30
Adhesives 10
Ink Solvents 200
and sludges with metals
Land treatment
Distillation
Landfill
Incineration
Landfill
Evaporation
Landfill
Activated sludge
Distillation
Landfill
Fuel incineration
Fuel Incineration
Rotary kiln
Incineration
Rotary Kiln
Incineration
Rotary Kiln
Incineration
Polymerization
Incineration
Stabilization
XX
Fuel substitute
XX
Substitution
XX
Distillation
Fuel blending
X
X
Substitution
X = low potential; XX = medium potential; XXX = high potential
(continued)
-------
co
Waste Type Est. Generation Current
1985, Tons Methods
HALOGENATED
ORGAN I CS
Solvent 5000
liquids
Aqueous solutions 500
Solid, sludges 800
INORGANIC
RESIDUALS
Aluminum proc. 7448
black dross
Boiler fly-ash 6000
(wood products)
Fluxing salts 10,000
(Mg. reduction
Recycling by
distillation,
condensation
Evaporation
Evaporation
Deep well
Injection
Landfill
Landfill
Landfill
Soil amendment
Waste pile storage
Available
Methods
Carbon adsorption
Rotary Kiln
Incineration
Liquid Injection
Incineration
Carbon adsorption
Rotary kiln
incineration
Liquid Injection
incineration
Rotary Kiln
Incineration
•
Water leaching
Reduction Recycling
Potential Potential
XX
Separation
of Internal
streams
XX
Separation
Internal streams
X
X
X
X
XXX
X
X
X
X
X
(continued)
-------
Waste Type
Est. Generation Current
1985. Tons Methods
Available
Methods
Reduction
Potential
Recycling
Potential
Graphite anode
with lead
(Cl production)
Asbestos
with lead
Other
250
100
400
Landfill
Landfill
Steel furnace
XX XX
Membrane cell Steel furnace
process
Steel anodes
Membrane cell
process
TOXIC METAL
SOLUTION AND
RESIDUALS
Electroplating
and metal
finishing
-solutions
Precipitation
and landfill
More efficient
precipitation
methods
XX
Process subst.
Evaporation
Reverse Osmosis
Ion exchange
Ion transfer
XX
Electrolytic
metal
recovery
-sludges
Steel emissions
control dust
Spent pickle
liquor (steel)
18,683
9340
4631
Landfill
Landfill
Precipitation
and landfill
Cement
Pozzolanlc
Cement
Pozzolanlc
Cement
Pozzolanic
X
X
X
XX
XX
Secondary zinc
refining
Sol 1 amendment
X
Flocculation
(continued)
-------
Waste Type Est. Generation
1985, Tons
Sludge from 300
Mercury cell
Cl production
Other toxic 900
metal wastes
CHELATED
TOXIC METALS
Solutions 9000
Sludges, 4000
solids
CORROSIVES WITHOUT
TOXIC METALS
Liquids and solids 75,000
TOXIC ANIONS
Potliner
(Alum. Prod.) 10,000
Current
Methods
Landfill
Landfill
Precipitation
and landfill
Landfill
Neutralization
Landfill
residues
Landfill
Storage
Available
Methods
Hypochlorlte
dissolution
Cement
Cement
Pozzolanic
Improved
precipitation
methods
Pozzolanic
Pozzolanic
Cement kiln
Incineration
Rotary K11n
Incineration
Reduction
Potential
XX
Membrane cell
process
Prepurified salt
X
XX
Process
modification
Evaporation
Reverse Osmosis
Ion transfer
Ion exchange
X
X
Redesign
Recycling
Potential
X
X
XXX
Electrolytic
metal
recovery
X
XX
(continued)
-------
Waste Type
Est. Generation
1985. Tons
Current
Methods
Available
Methods
Reduction
Potential
Recycling
Potential
vo
PO
Power boiler
Incineration
Fluldlzed bed
Incineration (?)
Many experimental
processes
Residue from
cryolite recovery
Cyanide solutions
3800
4000
Impoundment
Chemical
oxidation
Activated sludge
Electrolytic
oxidation
XXX
Substitution
Good housekeeping
practices
Process modification
Evaporation
Reverse osmosis
Ion exchange
Ion transfer
Other Toxics
200
REACTIVE
WASTES
Torpedo
propellent
residue,
obsolete
ammunition,
laboratory
chemicals
430
Landfill
Detonation
(continued)
-------
Waste Type
Est. Generation
1985. Tons
Current
Methods
Available
Methods
Reduction
Potential
Recycling
Potential
Phenyl
Isocyanate,
Other reactives
PAINT
RESIDUALS
Waterfall paint
booth sludge
4000
Landfill
Chemical
treatment
Rotary Kiln
Incineration
XX >
Substitution
Process modification
Sludge, residues
and still bottoms
1000
Landfill
Rotory Kiln
Incineration
XX
Substitution
10
10
Aged, leftover
paints; solvents;
containers
2000
Landfill
Chemical
treatment
Neutralization
Rotary Kiln
Incineration
XX
Substitution
Distillation
Sell to sec.
user
DISCARDED
CHEMICAL
PRODUCTS
Black liquor
vanillin manuf.
5000
Landfill
Land treatment
Cement Kiln
Incineration
XXX
Laboratory
wastes
Landfill
Rotary Kiln
Incineration
(continued)
-------
Waste Type
PESTICIDES
Pentachlorophenol
and Creosote
sludges
Unused Penta
Tank rinsate
(applicators)
Other listed
wastes
Liquids
(includes
capacitor oil )
Equipment
Soils^ etc.
Est. Generation Current
1985, Tons Methods
3990 Landfill
7 Unknown
50 Solar evaporation
and landfill
*
575 Landfill
2400
Incineration
3500 Rinse, landfill
Incineration
2000 Landfill
Available Reduction
Methods Potential
Incineration XX
Substitute
Itineration XX
Sell for use
Activated X
Recycling
Potential
X
XXX
X
carbon Apply rinsate use as
Incineration XX
Substitution
Chemical XXX
dechlorinatlon Manufacture
banned
XX
Incineration XXX
makeup
water
N.A.
N.A.
N.A.
(continued)
-------
Waste Type
Est. Generation
1985. Tons
Current
Methods
Available
Methods
Reduction
Potential
Recycling
Potential
CLEANUP
WASTES
(NON-PCB)
Soils, etc.
3000
Landfill
Land treatment
(Some organlcs)
Groundwater:
Aeration, stripping
Evaporation
Carbon adsorptoln
Ion exchange
XX
Encapsulate
In place
In-sltu
treatment
UD
cn
Demolition
debris
3000
Landfill
Decontamination
X
Reuse
MISCELLANEOUS
WASTES
10.000
-------
From the standpoint of technological application alone, an apparent
potential exists for Incineration of up to 40,000 tons of regulated hazardous
waste per year, based on 1985 data. Including a fraction of the future waste
soils which may have significant organic materials, the total incinerable
waste could reach 60,000 tons per year; however, two-thirds of that total
would probably require fuel-assisted burning, due to low potential heat
content. Further, at least 5000 tons of waste are amenable to recycling, and
that practice will accelerate. Up to 15,000 tons of liquids (including PCB
oils) may be sufficiently pure to allow injection incineration, but, as noted,
one-half of that amount can be recycled and much of the remainder is dilute
aqueous solution which might be more effectively treated in some other way.
Perhaps 25,000 tons of waste now destined for landfill or impoundment
could be handled by other means, particularly incineration. Even if that
shift were accomplished, a residual averaging at least ten percent of the
original weight would still require landfill or further treatment. In the
case of soil and certain equipment and debris, the volume of the residual can
be nearly 100% of the initial amount.
Many variations of incineration techonology exist, but some are not
commercially available. Cement kiln incineration is a process which will work
well for certain wastes in the northwest, including potliner. Although the
fluidized bed, multiple hearth and infrared incinerators and the plasma arc
pyrolysis process could conceivably be useful in Region 10, the rotary kiln
incinerator appears to present the most likely application. That type of
burner has the flexibility to handle liquids, sludges and solids while
providing the necessary efficiency to comply with RCRA and TSCA standards
under most circumstances.
-------
Mobile units might find application 1n all of the Region 10 states,
especially Alaska, for destruction of organic contaminants In soil as well as
other wastes. Any estimate of waste from remedial action sites to be actually
available for Incineration 1n future years would be highly speculative. One
landowner has already contracted to use a process which thermally removes and
captures organlcs (Including PCB's) from soil at a major site 1n Alaska; final
disposal must then be applied to a much less voluminous waste. The results of
the RCRA permitting process pertaining to other technology, such as Injection
wells In Alaska, will affect the amount of material which might be available
for Incineration 1n the region.
Chemical detoxification might be employed for certain wastes In the
northwest. Various reagents are being developed for dehalogenatlng organic
wastes such as PCBs. Some Washington wastes are being treated In that fashion
at facilities outside Region 10. Other specialized technology might be
applicable 1n future years for routinely generated wastes or for remedial
action projects. Experimental methods Include treatment of organlcs by such
organisms as white rot fungi and highly specific bacteria and yeasts.
Available in-situ procedures and other on-site methods of treating
contaminated soil and groundwater are too numerous to detail here.
One of the primary purposes of this survey is to contemplate the future
of hazardous waste landfill ing in the region. Hypothetically, as much as
180,000 tons of waste could be landfilled annually if solidified, stabilized
or encapsulated. Numerous methods and materials are available to accomplish
such containment, Including cement, lime and pozzolanic solidification;
glassification; polymerization; thermoplastic solidification; sorption; and
various means of macroencapsulation. However, many factors dictate that a
97.
-------
large Increase In the landfill ing of wastes generated in Region 10 will never
occur.
One specific overriding factor must be considered when projecting
available waste for landfill ing. The 1984 RCRA amendments established a
comprehensive program of evaluation of all hazardous wastes for the purpose of
banning the landfilling of any waste for which alternative technology exists
and those wastes which cannot be permanently Immobilized. A complex sequence
of study and regulation began.
Certain solvent wastes and dioxin-containing wastes were to be banned in
November, 1986. Wastes with greater than one percent of the listed solvents
were held to the 1986 deadline, but solvent^water mixtures of lesser
concentration, solvent-inorganic sludge mixes, solvent-contaminated soils and
small quantity generator wastes were Issued a two-year variance (November 8,
1988). Due to a lack of national waste disposal capacity, dioxin-containing
wastes received the same time extension.
The so-called "California list" of wastes is banned from landfill as of
July, 1987 (the California list wastes were banned from landfill in Idaho by
state law on July 1, 1986). The list includes liquid wastes containing free
cyanides in concentrations equal to or greater than 1000 milligrams per liter;
liquid wastes containing certain metals (or elements) or compounds of same
above specific concentrations; liquid wastes with a pH equal to or less than
2.0; liquid PCBs at a concentration equal to or greater than 50 ppm; and
wastes containing halogenated organic compounds in total concentration equal
to or greater than 1000 mg/kg.
98.
-------
CERCLA wastes are exempt from the landfill ban until November, 1988. By
August, 1988, EPA must study the first one-third of the RCRA-llsted wastes and
adopt regulations establishing treatment standards for each waste. After that
date, no such waste may be landfilled unless the contaminants are reduced to
the standard concentration. If the agency falls to adopt regulations, all of
the listed wastes will be banned. Regulations pertaining to the second
one-third of the listed wastes must be adopted by June, 1989, and for the
final one-third by May, 1990. "Characteristic" wastes are to receive the same
consideration by 1990.
For this report, the Region 10 wastes were evaluated In terms of their
potential coverage by each phase of the landfill ban regulations. Table 17
presents an array of estimated maximum tonnages which could be banned from
landfill at each step of the regulatory process. Note that these estimates
are crude and probably overstate the true potential for landfill ban because
the concentrations of pollutants in the various Region 10 wastes are unknown.
Those determinations will be made on a case-by-case basis by the generators
and waste management firms. Moreover, not all of the wastes will actually be
banned, since no alternative disposal method will be found for some, and some
wastes will be landfilled after treatment.
Available data do not clearly establish the physical form of reported
metals-containing wastes. Most sludges will be considered to be liquids for
the purposes of the California list rule. The figures shown in Table 17 are
high to some degree because a fraction of the metals waste is dry solids.
However, if not subject to the California list rules in 1987, they will be
covered by the "characteristic" rule in 1990.
99-
-------
TABLE 17
1
ESTIMATED MAXIMUM POTENTIAL LANDFILL BAN, REGION 10
BASED ON 1985 GENERATION DATA (TONS)
o
CD
Category
Solvents
Dioxin
California List
Cyanide
Metals
Acids
PCB
Hal . Organlcs
CERCLA Wastes
RCRA-Listed
First one-third
Second one-third
Third one-third
Characteristic
Total
DATE
1986-88
Nov., 1988
July, 1987
Nov . , 1 988
Aug., 1988
June, 1989
May, 1990
May, 1990
AK
70
0
50
600
10
180
50
0
20
2
2
675
1659
ID
140
0
340
620
90
260
400
0
40
2
0
375
2267
OR
2700
260
3300
4300
2900
700
1950
0
3500
25
0
7500
27,135
WA
11,500
7
19,000
28,000
7000
1230
3230
1000
15,500
5
0
8,800
95,272
REGION 10
14,410
267
22,690
33,520
10,000
2370
5630
1000
19,060
34
2
17,350
126,333
1985
91
0
1227
6570
400
7
1530
7
4150
11
1
447
14,427
1. Washington-regulated wastes not considered
2. Region 10-generated waste landfilled in 1985
-------
If all of the waste categories under study (other than characteristic
wastes) were to be actually banned, and 1f none of the Region 10 waste meets
the disposal standards prior to treatment, about 109,000 tons of waste would
be banned from landfill by 1990 unless properly pretreated. That conclusion
1s based partially In the assumption that the Washington-regulated wastes will
not be banned (a weak assumption). About 17,000 tons of waste would
theoretically be amenable to landfill without treatment unless banned by
"characteristic waste" regulations.
Over 14,000 tons of solvent wastes would be banned by 1988 (some were
banned In 1986). Far less than that amount is being landfllled now. The 1985
data show 265 tons of banned dioxin-contalning waste In the region. None is
reported from Alaska or Idaho, but small amounts are known to be In storage in
those states, awaiting disposal.
Nearly 75,000 tons of reported waste could be subject to the "California
list" ban, if none of that waste currently complies with the maximum
concentration limit. Obviously, no such amount of those wastes is being
landfilled now. By mid-1985, Section 3004 (c) of the RCRA regulations had
already banned the landfill of bulk or non-containerized liquid hazardous
wastes and free liquids contained in hazardous wastes (even with absorbents).
That regulation, of course, extends to California list wastes, and probably
had a substantial effect on the 1985 data. As liquid wastes are the main
focus of the California list regulation, that regulation is more likely to
affect the wastes being placed in surface impoundments than those being
land-disposed. The obvious exception is non-liquid wastes containing greater
than 1000 mg/kg halogenated organic compounds (Region 10 = up to 5600 tons).
-------
The apparent maximum effect of the regulation of the first one-third of
the RCRA-Hsted wastes will be a ban on landfllllng of approximately 19,000
tons of waste from Region 10. As Indicated by Table 17, virtually no Region
10 waste will be Impacted directly by the regulations pertaining to the
remaining two-thirds of the RCRA list, because most of that waste will already
be covered by the California list rules.
Of the nearly 127,000 tons of RCRA-regulated wastes and PCS oil generated
in 1985, only 14,427 tons were landfilled within the region, all at commercial
facilities in Oregon and Idaho. Therefore, almost 112,000 tons of the waste
which will be subject to potential landfill ban were already being handled in
some other fashion. Since only 13% of the wastes were being landfilled, and
the physical state of those wastes is unknown, the specific effects and timing
of the ban cannot be determined. However, it is apparent that the ban will
have virtually no effect on the landfilling of solvents and
currently-regulated dioxin-containing wastes, since very little has been
managed in that way in the past.
Without question, shifts in the use of hazardous waste management methods
will occur in Region 10 in response to economic incentives, technological
advances and governmental requirements. Equally apparent is the need for a
coordinated approach to waste management in the region by all parties if
compliance with regulations is to be achieved at reasonable cost. The unique
logistical features of Region 10 dictate that no single facility, process or
system will solve the diverse problems facing the waste generators. The
ultimate disposition of each lot of hazardous waste will depend on the results
of chemical analysis performed pursuant to the new waste disposal
regulations. In fact, assurance of the availability of a sufficient supply of
high quality laboratory facilities (and monitoring those facilities) may prove
to be the most imposing challenge facing waste managers in Region 10.
102.
-------
WASTE MANAGEMENT CAPACITY
The combination of technical, economic and regulatory factors which will
determine the actual application of waste management technology to particular
waste streams is so complex as to discourage analysis. Nevertheless, the
general information compiled in this report provides a basis for a rational
estimation of the current and future need for basic waste management
facilities in Region 10. Some data are available regarding the capacity of
existing and proposed facilities as well.
Waste management capacity cannot be simply defined. Storage capacity is
nothing more than the space available for waste piles and drums and the volume
of tanks and impoundments. Treatment capacity is limited by various
throughput limitations of the facilities. In the case of batch-process tanks,
capacity might be limited by tank size, chemical reaction rate, available
manpower or some other factor. Flowthrough liquid treatment facilities are
limited by hydraulic design and Incinerators by combustion chamber design.
Impoundment capacity is initially determined by pond size and the availability
of additives (such as waste acids and bases for neutralization) and ultimately
by evaporation rate, once the pond is full. Landfill capacity is normally
expressed in terms of total life of the facility (years, volume, weight),
although logistics and personnel limitations will establish a practical daily
capacity as well.
The foregoing sections of this report have outlined the volume and
character of the Region 10 wastes, the current handling methods and potential
technological application. The availability of facilities for handling those
wastes during the next ten years can be estimated on!y through compilation of
data from RCRA and TSCA facility permit files and by securing business plans
directly from waste management companies. Both methods were attempted during
this assessment.
'03.
-------
On-slte facility capacities for the standard EPA waste management
categories were totaled from the permit data files. Off-site storage capacity
was determined 1n the same way. These figures must be viewed with some
suspicion, however, because much of the data came from "Part A" applications
and are neither recently submitted nor verified. Moreover, while most of the
facilities decribed by the permit applications currently exist, some are only
proposed for construction. Data verification and permit Issuance to current
applicants will not necessarily be complete for five years. RCRA deadlines
require permit issuance for landfills by 1988, incinerators by 1989, treatment
by 1990 and storage by 1992.
Off-site treatment and disposal capacities were estimated by reviewing
operating permit ("Part B") application data and closure plans and through
discussions with managers of the major waste management companies in the
region. That Information allowed the production of a summary of treatment
capacities according to general waste types rather *han the less meaningful
treatment method categories. The projections made in this fashion, while not
fully verified, are at least based on recent data. The on-site facility
capacities are presented in Table 18. For comparison, the 1985 actual on-site
storage, treatment and disposal tonnages are reiterated in the Table.
Proposed storage facilities would accomodate nearly 300,000 tons of waste,
mostly in waste piles. Actual 1985 storage totaled just over 100,000 tons.
Treatment facilities proposed for permit would likewise handle much more waste
than that treated on-site in 1985. Similarly, proposed disposal facilities
would be capable of dealing with more waste than the amount disposed of by
each method in 1985.
104.
-------
TABLE 18
ON-SITE HAZARDOUS WASTE MANAGEMENT FACILITIES
1
APPROXIMATE PROPOSED PERMIT CAPACITY, REGION 10
AK ID OR WA REG. 10 1985
STORAGE (Tons)
Container 1600 250 10,000 3100 14,950 4365
Tank. 12 1150 1290 22,000 24,452 4213
Pile 00 6200 225,000 231,200 91,720
Impoundment 0 250 9000 200 9450 6997
TREATMENT
3
Tank (Tons) 17 0 7200 1800 9017 4919
3
Impoundment (Tons) 000 18,000 18,000 0
Incincerator (Tons/Yr.) 0 2100 1000 1600 4700 2437
4 4
Other (Tons/Yr.) 0 10,000 3300 1.1 1.1 1938
DISPOSAL
4
Injection Well (Tons/Yr.) 3000 0 0 0 3000 496
Landfill (Tons/Yr.) 000 40,000 40,000 32,037
LandAppl. (Tons/Yr.) 000 17,000 17,000 1445
3
Impoundment (Tons) 0 0 340 34.000 34.340 28.982
1. Some facilities existing, some not
2. Amount actually handled in Region 10 in 1985
3. Total containment capacity; potential throughput unknown
4. Millions of tons; includes wastewater treatment and disposal facilities
105.
-------
Permits for three to five injection wells have been requested by the
petroleum extraction industry on the Alaska North Slope. The Arco Prudhoe Bay
wells would accomodate 470 tons of waste per day, while the Standard Oil
Injection well would handle as much as 10 million tons per day. In neither
case would regulated hazardous waste be disposed of in quantities even close
to those totals (prior to mixing). Rather, the wells will be used primarily
for disposal of unregulated wastewaters.
EPA's proposed underground injection control regulations require that the
waste stay within the injection zone for a certain period of time. This
factor and many other technical and policy matters will determine whether or
not the permits will be issued. The outcome of the permitting decision will,
of course, bear greatly on the need for implementation of other waste disposal
options (such as incineration) in Alaska, as will the decision of the well
owners regarding acceptance of off-site wastes for injection if the wells are
permitted.
Most of the permit applications for on-site waste management reflect the
pattern of existing facilities in the region. The most notable exceptions are
the proposed small incinerators. If approved, those burners would be built at
federal facilities in Idaho and Oregon, and at a wood products plant in
Washington.
Table 19 presents estimates of off-site waste management facilities
proposed for permit in Region 10. Storage, treatment and disposal permit
applications again relate primarily to existing facilities, but some new
projects have been proposed. Off-site storage capacity easily exceeds the
106.
-------
TABLE 19
OFF-SITE HAZARDOUS WASTE MANAGEMENT FACILITIES
1
APPROXIMATE PROPOSED PERMIT CAPACITY REGION 10
2
STORAGE (Tons)
Container
Tank
Pile
Impoundment
TREATMENT (Tons/Yr.)
Physical /Chemical
Oil Recovery
Solvents recovery
Anlons
Organlcs
Corrosives/Metals
Incineration
DISPOSAL
Injection Well (T/Yr.)
Landfill (T/lifetime)
AK,
0
0
0
0
?
0
0
0
0
0
7
0
ID
870
705
4700
4
75,000
0
7
0
0
20,000
0
0
3
1.57
OR
.600
420
0
4
83,000
7
7
0
0
25,000
0
0
8
2.07
WA
7000
1 1 ,000
3
60,000
5000
,
35,000
6
200,000
10,000
15,000
5
100,000
7
50,000
0
7,
1.4
REG. 10
8470
12,125
64,700
4
163,000
35,000
200,000
10,000
15,000
5
145,000
7
50,000
7
8 8
5
1985
7012
9940
57,000
4
18,000
12,000
7
3000
12,000
23,500
0
615
76,695
1. Some facilities existing, some not
2. Amount actually handled in Region 10 in 1985, including state-regulated
3. Not RCRA
4. Also treatment
5. Other than NPDES wastewaters
6. Includes capacity for exempt wastes
7. Proposed only
8. Mill ions of tons
107.
-------
space actually used in 1985. Information on treatment is sketchy, but as
stated earlier, the permit file data were augmented by new estimations secured
from facility managers regarding the waste treatment throughput potential of
their facilities. That information allowed a rough separation of
physical/chemical treatment processes into groups labeled in Table 19 as oil
recovery, corrosives/metals, solvent recovery (other than alternative fuel
blending), anion destruction and treatment of organic materials.
Excess capacity (relative to projected waste generation) for
neutralization of liquid corrosives with or without metals will be available
if permits are issued for facilities existing or proposed in Idaho, Oregon and
Washington. No deficiencies are apparent in the systems available to handle
oils, solvents and cyanide (facilities mostly in Washington). While some
capacity to chemically treat organics exists, little was learned about the
scope of those capabilities during this assessment.
No off-site incinerators have been yet approved or constructed within
Region 10. One major facility with the capacity to burn up to 50,000 tons of
waste per year has been formally proposed for construction in central
Washington. Plans for another (competing ?) project have been revealed by a
consortium of waste management firms, but no permit application has yet been
filed. Obviously, the actual construction of such a facility would have a
profound effect on future waste management practices in the region.
The capacity of existing landfills for disposal of hazardous waste within
the region is large and would be augmented substantially by the construction
of a facility associated with the proposed incinerator in central Washington.
103.
-------
Oregon's landfill capacity as outlined by the current permit application 1s
slightly more than two million tons of waste. That figure represents the
amount of land dedicated to landfill for the term of the proposed permit (10
years). Note, however, that the major facility operator owns enough land to
easily triple that capacity in the vicinity of the existing landfill, but no
assumption can be made regarding that possibility.
In Idaho, the commercial landfill space proposed for permit would
accomodate 1.5 million tons of waste. However, the actual remaining capacity
of the land planned for waste disposal at the site is about two million tons.
The proposed Washington facility would add 1.4 million tons of capacity, for a
regional total of approximately five million tons of waste.
Idaho and Oregon landfill lifetimes were calculated on the basis of
several possible waste disposal rates and reported in Figures 15 and 16. If
the Oregon facility were to continue to receive waste at the same rate as in
1985 (82,000 cubic yards/year), the life of the landfill as proposed for
permit would be 18 years (2005); at the higher 1986 rate of fill (102,000
cubic yards/year), the life of the facility would be 12 years (1999).
However, the closure date of the land disposal cells proposed for permit is
estimated by the company to fall in 1996; receipt of over 164,000 cubic yards
of waste per year would be required to fill the site by that time. Such a
rate of fill is possible, but would require a broader market or volume
increase due to waste stabilization and expanded CERCLA waste business. None
of the scenarios depicted by Figure 15 would alone provide 20 years of
disposal capacity in Oregon, but as permits are limited to a 10 year duration,
facility proposals for the second decade are unknown.
:C9.
-------
Figure 15
Commercial Hazardous Waste Landfill Capacity, Oregon
1543
a
9-0
U. o
Base
Site Capacity
(Current Permit Application)
1996
1999
2005
1985
1990
1995
At Rate of Fill Projected by CSSI
(164,000 Cu. Yd./Yr.r
At 1986 sate of Fill
(102,658 Cu. Yd./Yr.r
At 1985 Rate of Fill
(82.000Cu. Yd./Yr.r
• Assumes 40% Capacity Loss Due to Cover.
2000
2005
Figure 16
Commercial Hazardous Waste Landfill Capacity, Idaho
1524
-------
Since the Idaho facility is rebuilding Its RCRA waste disposal business
following several years of self-imposed restricted activity, projection of
facility life can be based only on company plans as discovered during this
assessment. Apparently, wastes averaging 117,000 cubic yards per year are
expected to be received at the existing site (if permitted); that rate of fill
would result in closure of the facility exactly 20 years from now (2007). For
comparison, the 1985 and 1986 rates of fill were approximately 25,000 and
35,000 cubic yards, respectively. Therefore the landfill activity at the site
would have to be quadrupled to utilize available capacity within 20 years.
Further, the character of the waste stream will change dramatically, because
soon the Idaho site will no longer receive the PCB wastes which have dominated
its business in recent years.
Potential Capacity in the Nest
As previously discussed, Region 10 waste generators currently ship a
significant portion of their hazardous wastes and PCB wastes to facilities in
nearly two dozen states for treatment and disposal, and might have to ship
even more as new regulations reduce the local options. Much of the exported
waste is treated or landfilled in California and Nevada or sent to the Midwest
for incineration. National data suggest that a waste disposal capacity
shortfall of some proportion will occur within the next five years unless
proposed facilites are permitted and built faster than expected.
»
Region 10 clearly has sufficient landfill capacity for the next decade if
existing facilities are issued permits. Obviously, approved commercial
incineration capacity in the region is zero unless TSCA-permitted mobile units
11.
-------
are brought 1n. Much of the permit review process still lies ahead for the
only formally proposed major incinerator project in the region, and no
application has yet been developed for the informally proposed facility.
Therefore, those projects could well be in competition with similar ventures
in adjacent regions.
Permit applications for at least four new major commercial incinerators
have been submitted in EPA Region 9. Proposed facilities for southern
California would handle about 60,000 tons of waste and those planned for"
northern California could burn nearly 300,000 tons of waste per year. The
largest of those is an existing sulfuric acid regeneration furnace which would
be modified to accept hazardous waste as a heat source. A permit decision on
that facility could occur as early as March, 1988. Two other incinerators
might be built in Region 9, one on the site of an existing major landfill in
California; the other is the well publicized ENSCO project in Arizona. No
permit application has been submitted for either of them.
In Region 8, eight separate commercial incineration facilities are being
planned by different entities (total capacity over 100,000 tons per year).
The proposed sites which are closest to the Region 10 states are in northern
Utah. The permit application for one of those sites is being actively
considered at this time. In both of the regions adjacent to Region 10, permit
decisions could be made on more than one incinerator within the next 18 months.
The foregoing information is provided for consideration by Region 10
waste management planners because the incineration market, while clearly
12.
-------
expanding 1n the West now, Is nonetheless limited, and the few projects
permitted first may be the only ones built- That eventuality underscores the
need for quickly augmenting all aspects of the hazardous waste management
planning process 1n the region 1f the full range of options Is to be
considered.
-------
PROBLEMS/RECOMMENDATIONS
The hazardous waste reporting sytems employed by EPA and the Region 10
states collectively embody a powerful program planning tool, but certain
shortcomings of those systems became evident during this assessment. Problems
were encountered regarding the timeliness of generator and facility surveys,
the accuracy of data, and the scope and comparability of summary reports.
Those problems are generally reflective of the list of system deficiencies
noted recently by the National Governors' Association in its report to the EPA
Office of Solid Waste on hazardous waste reporting system design.
Comprehensive waste generation and waste handling data bases are
necessary for various program purposes, Including compliance evaluation,
determination of waste management facility needs, estimation of potential for
waste reduction, development of national, regional and state waste management
strategies, and efficient assignment of program resources. Such diverse
missions cannot be served without a data system which accounts for hazardous
wastes on a mass balance basis. The Region 10 systems fall short of that
capability for the following reasons:
1. Data are not entered into a common electronic system; computer-aided
regional analysis is not possible.
2. States and EPA regulate different waste materials and different
volumes or concentrations of the same materials.
3. State and EPA data verification (quality control) procedures and
level of effort are significantly different. The Washington DOE is
the only Region 10 agency routinely conducting a substantial data
14.
-------
verification program. In spite of the Impressive effort made by the
HasMngton agency, a waste management facility reporting error
amounting to ten percent of the waste generated In the state In 1985
was not discovered by DOE but was noted during the current
assessment. Generator and facility reporting discrepancies 1n
Alaska were as high as a factor of two or three. Waste
characterization as outlined by the Idaho annual report differed
greatly from that shown by the EPA biennial report for nearly the
same period of time. The Oregon biennial report did not account for
the importation of Washington-regulated wastes.
4. Sequential waste management steps are not adequately reported,
resulting 1n a variety of problems, such as the double or
triple-counting of wastes, insufficient identification of treatment
processes employed, and Inconsistent reporting of
wastewater/residual volumes.
5. Biennial reporting frequency is inadequate and reports are generally
produced too late for good program planning and evaluation (up to 15
months after end of year).
6. Waste characterization data are not sufficiently comprehensive.
Each waste lot is identified by one or more three digit
characterization codes; only one such code number can be entered
into the EPA data management system (even for mixtures) although it
cannot fully describe the waste.
15.
-------
7. The 11st of notlfiers (registrants) may not reflect the actual
universe of potentially regulated entitles.
8. State and EPA survey instruments differ substantially
-------
within a state; thus, a mass balance determination of In-state
generated wastes Is Impossible through the use of biennial report
printouts alone.
None of these frailties invalidates the Information contained in this
report and the documents on which it is based, because the particular
conclusions reached as a result of this assessment required only
order-of-magnitude level data; the biennial reports are much more precise than
that. Nevertheless, if the Region 10 states are to evaluate the hazardous
waste handling problem to an extent sufficient to ensure the application of
the most cost-effective and health-protective management methods, a more
comprehensive reporting and analysis process must be developed.
Such a process should include at least the following features:
1. A single report form to be used by all states (or as the core of any
state-developed form) to collect data both from hazardous waste
generators and waste management facilities.
2. Surveys conducted at least annually and summary reports issued
without great lag time.
3. Clearly-stated reporting requirements, particularly with regard to
definitions of reportable wastes (for example, under what
circumstances are volumes of wastewaters reportable prior to
treatment? Conversely, when are treatment residuals reportable as
newly generated wastes?)
4. An annual determination of the regulatory status of al1 potential
generators.
117.
-------
5. Verification of all generator and facility-reported data by state
agencies and EPA (staff augmentation required).
6. Characterization of wastes in terms of physical form and all
relevant chemical components (within the limits of practical
analysis) through use of a more complex coding system.
7. Tracking of wastes throughout the country and reporting of treatment
and ultimate disposal of those wastes to the regulatory agency in
the state of origin.
8. The capability to account for stored wastes at the beginning as well
as at the end of a reporting period.
9. More detailed description of waste treatment processes through a
more complex coding system.
10. The capability to compare the volumes of various wastes on an annual
basis and to determine the degree to which each generic means of
waste reduction is employed by each category of industry.
11. The capability to determine the remaining permitted capacity of
landfills on an annual basis and the practical throughput capacity of
treatment faci1ities.
12. The entry of all core data into a commonly accessible automated
system.
13.
-------
At the national level, EPA and the states are addressing the problems of
the biennial reporting system under the auspices of an advisory council formed
by the National Governors' Association at the request of EPA. The council Is
composed of representatives of the RCRA-regulated community and environmental
Interest groups as well as EPA and state agencies. Alternatives are being
considered for upgrading and coordinating the data collection process. The
council has Identified five major objectives to be pursued through a new
reporting system: determination of regulatory status of waste handlers;
Improved waste characterization; more complete waste tracking; better
documentation of waste minimization programs; and development of Information
regarding TSDF capacity.
C"
Plans are also being formulated to develop new software for the handling
of hazardous waste management data. Such a system could be operational by
mid-1988. The package would facilitate data entry to a redesigned central
data processing system by all states from newly designed survey forms, allow
validation of data entry, produce summary reports and provide protocols for
processing of data. It is recommended that Region 10 state agencies actively
participate 1n the development of the program, contribute in timely fashion to
the national data base, and ultimately use the analytical capability of the
system to the degree that it meets the requirements of the agencies.
Further, it is recommended that the Region 10 states, individually or
collectively, conduct intensive studies of waste management capacity and waste
reduction potential as soon as practicable. Waste reduction studies should
include the determination of industry unit productivity so that a true
calculation of the effects of future reduction schemes can be made.
19.
-------
Arrangements for holding confidential any such Information pertaining to
individual companies will likely be necessary. The capacity surveys will
require considerable direct contact and discussion with waste management
industries as well as detailed review of permit applications to secure
information on the true capabilities of waste management facilities and likely
waste sources to be served by those facilities; the EPA RCRA facility permit
data summary reports are neither sufficiently detailed nor up-to-date for that
purpose, because only a relatively few permit applications are being
intensively processed at this time.
Agencies should solicit the assistance of industry representatives and
other interested parties through the formation of investigation steering
committees or other suitable means. Once the baseline data are in place from
these one-time studies, the ongoing reporting processes previously discussed
will provide updated information which can be augmented with infrequent
independent followup surveys. EPA and the Region 10 states have an
opportunity to develop planning mechanisms which will ensure appropriate
handling of hazardous waste in the future, but to do so, the management
officials must have access to an improved data collection system very soon.
Critical hazardous waste management policy will be established in the
northwest states during the next two years, whether by active design or
passive acceptance of the initiatives of the national marketplace and
regulatory programs. The people of the Region 10 states will be best served
by the creation of clear processes for reaching joint conclusions regarding
data systems, facilities development, technology transfer and public health
objectives. True public participation should be the hallmark of those
processes, from basic policy formulation to ongoing program management.
20..
-------
REFERENCES
(Selected List)
Abt. Associates, Inc., National Small Quantity Hazardous Haste Generator
Survey. EPA-OSW, February, 1985.
Ad Hoc Task Group, Liquid Haste Disposal Options for the North Slope of
Alaska. December, 1986.
Apogee Research, Inc., U.S. Hazardous Haste Management Control Programs:
Current Policies and Options for Improvement. The National Council on
Public Works Improvement, Washington, D.C., March 31, 1987.
Connecticut Hazardous Waste Management Service, Connecticut Hazardous Waste
Management Plan : 1985-2005. January 1, 1986.
Coughlln, Robert, Hazardous Waste. USEPA - Region 10 (Unpublished), February,
1987.
Environmental Resources Management, Inc., Alaska Hazardous Waste Generation
Study (for Alaska D.E.C.), October, 1986.
Idaho Department of Health and Welfare, Idaho Hazardous Waste Generation and
Disposal Report. December 31, 1985.
Industrial Economics, Inc., Regulatory Analysis of Restrictions on Land
Disposal of Certain Dioxin - Containing Wastes. USEPA - OSW, Washington, .
D.C., November, 1986.
Industrial Economics, Inc., Regulatory Analysis of Restrictions on Land
Disposal of Certain Solvent Wastes. USEPA-OSW, Washington, D.C., November,
1986.
Municipality of Metropolitan Seattle, Toxicant Pretreatment Planning Study
Summary Report. Metro Toxicant Program Report No. 3, May, 1984.
National Governors' Association, Designing a More Effective Hazardous Waste
Reporting System: A Background Paper (Draft), for EPA-OSW, January, 30 1987.
New Jersey Hazardous Waste Facilities Siting Commission, New Jersey Hazardous
Waste Facilities Plan. March, 1985.
Northwest Power Planning Council, Northwest Conservation and Electric Power
Plan. 1986.
Oregon Department of Environmental Quality, 1985 State Biennial Program Report.
Hazardous Waste Generation and Treatment. Storage and Disposal. March 27,
1987.
Pope-Reid Associates, Inc., Background Document for Solvents to Support
40CFR268. Land Disposal Restrictions. Vol.1. USEPA, Washington, D.C.,
August, 1986.
Puget Sound Council of Governments, Characterization and Impacts of
Nonregulated Hazardous Wastes J_n Municipal Sol id Waste of King County (by
Cal Recovery Systems, Inc.), December, 1985.
121 .
-------
Rozell, David, Hazardous Waste Reduction: Issues Related to Program Planning.
Oregon Department of Environmental Quality, February, 1987.
The Environmental Defense Fund, Inc., Approaches to Source Reduction.
Practical Guidance from Existing Policies and Programs. June, 1986.
Toxic Waste Assessment Group, Alternatives to the Land Disposal of Hazardous
Hastes. An Assessment for California. Governor's Office of Appropriate
Technology, State of California, 1981.
U.S. Congress, Office of Technology Assessment, Serious Reduction of Hazardous
Haste: For Pollution Prevention and Industrial Efficiency. OTA-ITE-317,
September, 1986.
USEPA, 1985 Biennial Program Report. Hazardous Waste Generation and Treatment,
Storage and Disposal (Alaska and Idaho) January 12, 1987.
USEPA, Development of Predictions of Future Pollution Problems.
EPA-600/5-74-005, March 1974.
USEPA, Forecasts of the Quantity and Composition of Solid Waste.
EPA-600/5-80-001, May 1980.
USEPA, Handbook for Stabilization/Solidification of Hazardous Hastes.
EPA-540/2-86-001, June 1986.
USEPA, Minimization of Hazardous Waste. Report to Congress. EPA-530/SW-86-003,
October, 1986.
USEPA, Mission Elements Needs Statement, Biennial Report Information System.
OSW/OPPI, June 15, 1987.
USEPA, Mobile Treatment Technologies for Superfund Wastes. EPA
540/2-86-003(f). September, 1986.
USEPA, Sol Id Waste 2D. Federal Lands jjn Alaska, Second Report to Congress, 1978.
USEPA, Systems to Accelerate In. Situ Stabilization of Waste Deposits.
EPA-540/2-86-002, September, 1986.
USEPA, Treatment Technology Briefs. Alternatives to Hazardous Waste LandfilIs.
EPA-600/8-86-017, July. 1986.
Washington Department of Ecology, 1985 Hazardous Waste Annual Report Summary
(Draft). #87-14.
Washington Department of Ecology, 198j State Biennial Program Report,
Hazardous Waste Generation and Treatment, Storage and Disposal, January 7,
1987.
Washington State Department of Ecology, A Study of Hazardous Waste Management
Priori ties for Cateqori es of Was_te j_n Was hi ngton State, Document Number
86-7. July, 1986.
122.
------- |