qJJ jj\U d") associates
A COMPANY OF SCIENCE AFP1 i.~»"ONS. INC.
EVALUATION OF COLLECTION, TREATMENT,
AlO DISPOSAL ALTERNATIVES FOR HAZARDOUS
WASTES FOR TEE STATE OF ALASKA
13400-8 Northup Way, Suite 38, Ballevue, Washington SS005

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EPA #68-01-6463
EVALUATION OF COLLECTION, TREATMENT,
AND DISPOSAL ALTERNATIVES FOR HAZARDOUS
WASTES FOR THE STATE OF ALASKA
Prepared by:
Resource Technology Corporation
20480 Pacifica Drive, Suite G
Cupertino, California 95014
and
JRB Associates
13400-B Northup Way, Suite 38
Bellevue, Washington 98005
September, 1982

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Although the research described herein has been funded
wholly or in part by the U.S. Environmental Protection
Agency through contract EPA 68-01-6463 to Resource Tech-
nology Corporation, it has not been subjected to the
Agency's peer and administrative review and therefore does
not necessarily reflect the views of the Agency, and no
official endorsement should be inferred.
¦111111111111
Rxaooaonbs

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TABLE OF CONTENTS
Page
Authorization	-	i
1.0 INTRODUCTION	1
1.1	Historical Overview	1
1.2	Waste Collection Categories	3
1.3	Program Objectives .... 	 5
2.0 HAZARDOUS WASTE INVENTORY 	 7
2.1	Field Inspections of RCRA Permit Applicants	7
2.2	Small Generator Waste Inventory	7
2.3	Hazardous Wastes Data Base Generation	10
2.4	Waste Types, Quantities, and Distribution	12
3.0 HAZARDOUS WASTE COLLECTION, STORAGE, AND IN-STATE TRANSPORT . . .17
3.1	Current Waste Disposal Practices 	17
3.2	Collection Facilities for Small Quantity Generators	18
3.2.1	Waste Collection, Packaging, and Handling	20
3.2.2	Small Quantity Collection Facility Design
Considerations	.			.21
3.3	Intrastate Transport of Alaskan Hazardous Wastes 	29
3.3.1	Railbelt Transport of Wastes		 .29
3.3.2	Alcan Highway Transport of Wastes	30
3.3.3	Hydro-Train Transport of Wastes	30
3.4	Uniform Manifest for Transporting Hazardous Wastes 	31
4.0 HAZARDOUS WASTES TSD ALTERNATIVES EVALUATION	32
4.1	Waste Solvent Recovery and Recycle 	33
4.2	Waste Solvent Incineration			*.37
4.3	Hazardous Waste Disposal in a Secure Landfill. ...... .37
4.3.1	Secure Landfill Disposal in Oregon.'. . . . 	37
4.3.2	Secure Landfill Disposal in Alaska	39
4.4	Hydro-Train Transport of Hazardous Wastes	41
4.5	Summary of Costs of TSD Alternatives	43
5.0 CONCLUSIONS AND RECOMMENDATIONS	48
REFERENCES	53
APPENDIX A - Alaska Hazardous Waste Generator Inventory,
Partial Listing, March 1982 	54
APPENDIX B - Conceptual Structural Design and Equipment for a
Transfer Station Storage of Hazardous Wastes. ..... .57
APPENDIX C - Assumptions and Economic Analyses Associated with
Collection, Storage, Treatment, and Disposal of
Alaskan Hazardous Wastes	69
APPENDIX D - EPA, DOT Joint Proposal. on Uniform Manifest Form
for Transporting Hazardous Wastes 	 ... .72

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AUTHORIZATION
This report was prepared for the State of Alaska under the auspices of the
U.S. Environmental Protection Agency's Technical Assistance Panels Program.
The Technical Assistance Panels Program is authorized by Section 2003 of the
Resource Conservation and Recovery Act of 1976 (RCRA), Public Law 94-580, to
"provide teams of personnel, including Federal, state, and local employees or
contractors	to provide states and local governments upon request with
technical assistance on solid waste management, resource recovery, and
resource conservation." This report was prepared by Resource Technology
Corporation, and JRB Associates, which are the Technical Assistance Panels
contractors for USEPA Region X.
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1.0 INTRODUCTION
Previous hazardous waste studies conducted in Alaska by the Alaska Department
of Environmental Conservation (ADEC) and the US Environmental Protection
Agency Region X (EPA-X) focused on the identification of hazardous wastes
generators, and types and quantities of hazardous wastes generated. All
studies concluded that hazardous waste quantities tend to be small, generally
of a solvent and petroleum sludge type, and are dispersed throughout the broad
expanse of the State of Alaska. Little direction has been given to the logis-
rirji rnnrcrn-i; of how to centralize the collection of these wastes, what trans-
port mechanisms are available, what wastes can be segregated and treated, or
whether %»astes should be disposed of within the state or exported to the con-
tinental United States. The only current method for hazardous waste disposal
is for a generator to contract with a private carrier to transport the wastes
to the secure land disposal facility at Arlington, Oregon.
The Alaska Department of Environmental Conservation is concerned that private
citizens, commercial and industrial businesses, and even large military bases
in the state do not have a system available to conveniently collect and dis-
pose of hazardous wastes in an environmentally sound manner. To rectify this
program deficiency, ADEC has requested technical assistance from EPA to con-
duct a feasibility analysis of storage, treatment, and disposal alternatives
to accomodate this need. ADEC's goal is to encourage all generators of
hazardous wastes, and at a minimum those which generate 100 kilograms or more
per month, to collect, store, and dispose of hazardous wastes in an approved
manner.
1.1 Historical Overview
Since its organizational formation, ADEC has had a responsibility for the
management of solid waste disposal practices in the State of Alaska. With the
commercialization and industrialization of the state, particularly in relation
to energy exploration and development, the quantities and types of taste
materials have increased many fold from the historical wastes. ADEC staff in
Juneau, Anchorage and Fairbanks worked with municipal and borough governments
and many private and institutional entities to identify and develop waste
management programs, and secure and implement environmentally acceptable
disposal practices.
With continued development of the state's industrial base, ADEC and EPA began
to express concern with regard to the management of hazardous wastes in
Alaska. Several old disposal sites suspected of containing hazardous wastes
had been discovered while improving statewide solid waste disposal practices.
With the passage of the Resource Conservation and Recovery Act (RCRA), ADEC
soon expanded its solid waste management program activities. Together with
the EPA, ADEC hazardous waste materials coordinator, and state regional field
investigators began the effort to identify generators of hazardous wastes and
to try and document where possible the fate of those generated wastes. Some
of the material was known to be in old or abandoned disposal sites, and some
was found to be transported out of the state for treatment and/or disposal.
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Other wastes were accumulating at the site of generation, while others were"
being improperly disposed of by surface application or shallow burial pits.
In 1980, EPA contacted 322 industrial, commercial, and institutional facili-
ties in Alaska which could be producers of hazardous wastes. The response to
this RCRA notification program involved 127 industries, all of which combined
reported 75 different waste types. However, waste quantities did not need to
be reported during this activity.
During the summer of 1980 a field investigation team surveyed 97 businesses
from 35 industrial categories suspected of producing hazardous wastes. (D la
addition, the team investigated disposal practices at seven landfills. The
study classified each business and waste-disposal site according to the prob-
able level of risk to the environment and to public health. Field studies
were conducted at those sites classified with a potential hazard or high
hazard. The study did not find any waste generation, storage, or disposal
sites of cause for significant concern. It did note the logistical diffi-
culties of hazardous waste disposal due to the absence of adequate disposal
facilities in the state* and high transportation costs associated with hauling
of hazardous waste6 in Alaska.
In January 1981, a sunnary report of historical and current state agency
activities in hazardous waste management was prepared by the Alaska Department
of Environmental Conservation.^) Using the conclusions of the above reports,
supplemented by file records and an industrial inventory prepared by its
staff, ADEC prepared a summary of hazardous waste management problems in the
state, including the lack of statewide legislative authority to regulate those
wastes, and proposed numerous options to rectify these shortcomings. This
report clearly marks the beginning of the ADEC hazardous waste management
program. The report identifies disposal and control options; targets the
types and quantities of wastes to be regulated; realizes the current short-
comings in storage and transportation of wastes due In part tc the absence of
state regulations; and outlines program objectives to encourage resource
recovery, coordinate emergency response and safety, and educate the public and
industrial sector to more effectively manage their hazardous wastes.
The 1981 ADEC report concludes with an outline and program structure contain-
ing 18 elements. It Is noted that the envisioned program would rely on
out-of-state facilities for final disposition of Alaska's hazardous wastes.
ADEC would implement a state manifest program for the control of hazardous
wastes transported throughout the state, and would control the disposal of
even small quantities of hazardous wastes into unsecured landfills. Major
emphasis was to be placed on the development of transfer stations* across the
state, and to encourage total awareness and participation in the disposal of
hazardous wastes at these transfer stations.
Concurrent with the above activities, ADEC and the legislature began to draft
laws governing in-state hazardous waste practices. The resulting legislation
for statewide management of hazardous wastes is Alaska State Senate Bill
No. 29, which became effective January 1, 1982. That legislation now enables
ADEC to develop regulations for the storage, transportation, treatment, and
disposal of hazardous wastes. Sehate Bill 29, and the hazardous waste program
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now being prepared by the state, will enable ADEC to fully implement the hazar-
dous waste rules and regulations as mandated by EPA.
In summary, while the concern for hazardous waste disposal is not new, only in
the last three years have ADEC and EPA begun an intense effort to assess the
magnitude of the problem in Alaska. Based on the conclusions of this report
and in conjunction with the developing state program, ADEC will initiate a
remedial program to collect the hazardous wastes generated and currently
stored across the state.
1.2 Waste Collection Categories
The hazardous waste categories subject to regulation in Alaska under the state
program have not yet been promulgated. The management of hazardous wastes
generally consider four categories of materials. These include ignitables,
corrosives, reactive wastes, and acutely hazardous wastes. The current
federal controlling regulations defining these wastes can be found in 40 CFR
261 (EPA regulations) , 49 CFR 173 (DOT requirements) and 29 CFR 1910 (OSHA
regulations). In that ADEC has yet to define the waste types to be regulated
under its program (if different than Federal regulations) , presented below are
definitions of wastes regulated by the Oregon Department of Environmental
Quality.(3) They are of interest to this report for many wastes are currently
shipped from Alaska to secure landfill facilities in the State of Oregon. A
summary of the four waste types considered in this study are:
•	Ignitable Wastes are those that pose a fire hazard during
routine management. These wastes may cause damage directly from
heat and smoke production, or indirectly by dispersing the hazar-
dous wastes into the air or by causing non-hazardous wastes to
ignite or emit toxic fumes. A waste is ignitable if it has any
of the following properties:
•
(1)	Liquid that has a flash point less than 60#C (14( °F) as
determined by the Pensky-Martens Closed Tester (ASTM
D93-73) or an equivalent method.
(2)	Flammable compressed gas as defined by 49 CFR 173.300(b).
(3)	Any Class C explosive as defined by 49 CFR 173.100.
(4)	Any other waste, that under conditions incident to its
management, is liable to cause fires through friction,
absorption of moisture, spontaneous chemical change, or
retained heat from manufacturing or processing; and when
ignited burns so vigorously and persistently as to create a
hazard during its management.
•	Corrosive Wastes require special containers because of their
ability to corrode standard containers or materials. Corrosives
will burn the skin if a person comes in contact with it. A
waste is corrosive if as a liquid or sludge, or as a solid mixed
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with an equal volume of water, it has either of the following
properties:
(1)	A pH of 2 or less, or of 12 or greater.
(2)	Any corrosive as defined by 49 CFR 173.240.
•	Reactive Wastes are those that during routine management tend to
react spontaneously, react vigorously with air or water, are
unstable to shock, or heat, generate acutely hazardous gases, or
explode. A waste is reactive if it has any of the following
properties:
(1)	Chemical instability which may readily undergo violent
chemical change such as reacting violently or forming poten-
tially explosive mixtures with water; or generating toxic
fumes when mixed with water under mildly acidic or basic
conditions.
(2)	Any waste that is capable of detonation or pyyjosive reac-
tion with or without a strong initiating source or heat
before initiation. This includes explosives as defined by
49 CFR 173.51 (Forbidden), 173.53 (Class A), or 173.88
(Class B).
(3)	Any oxidizer or other reactive waste as defined by 49 CFR
173.151 or 173.151a. (Note: Unless determined otherwise,
oxidizers shall be assumed to be incompatible with all
other materials.)
•	Acutely Hazardous Wastes are those which when improperly managed
can release toxins in sufficient quantity to pose a substantial
hazard to human health or the environment. They include the
following waste categories:
(1) Pesticides and Pesticide Manufacturing Residues
(a)	Oral Toxicity: Material with a 14-day oral LD50 equal
to or less than 500 mg/k.g. (Note: Oral LD50 is the
median oral lethal dose.)
(b)	Inhalation toxicity: Material with a one-hour inhala-
tion LC50 equal to or less than 2 mg/1 as a gas or
vapor or a one-hour inhalation LC50 equal to or less
than 200 mg/m^ as a dust or mist. (Note: Inhalation
LC50 is the median inhalation lethal concentration.)
(c)	Dermal penetration toxicity: Material with a 14-day
dermal LD50 equal to or less than 200 mg/kg. (Note:
Dermal LD50 is the median dermal lethal dose.)
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(d) Aquatic toxicity: Material with 96-hour aquatic TLm or
96-hour aquatic LC50 equal to or less than 250 rag/1.
(Note: TLm and LC50 are the aquatic median tolerance
limit.)
(2)	Halogenated Hydrocarbons and Phenols (excluding polymeric
solids)
(a)	Waste containing halogenated hydrocarbons (excluding
polychlorinated biphenyls) or halogenated phenols is
toxic if it contains 1% or greater of such substances.
(b)	Any waste containing polychlorinated biphenyl (PCB) is
considered toxic and shall be managed in accordance
with 40 CFR 761.
(3)	Inorganics
(a)	Waste containing cyanide, arsenic, cadmium or mercury
is toxic if it contains 100 ppm or greater of such sub-
stance or 200 ppm or greater of the sum of such sub-
stances .
(b)	Waste containing hexavalent chromium or lead is toxic
if it contains 500 ppm or greater of such substance or
1000 ppm or greater of the sum of such substances.
(4)	Carcinogens
(a) Waste containing carcinogens as identified by OSHA in
29 CFR 1910 is toxic.
L.3 Program Objectives
rhe purpose of the technical assistance work order was threefold:
1.	Hazardous Wastes Inventory
Using historical Information on generator location, waste
types, and quantities, supplemented by data gathered by EPA-X
through field investigations of facilities applying for RCRA
Part-A treatment, storage, or disposal (TSD) permits, and by
small generator inventory data gathered by ADEC staff, deter-
mine annual hazardous wastes generation rates, types of
wastes, and their geographic distribution.
2.	Evaluation of TSD Alternatives
Once the above activity is complete, identify and evaluate
strategies available to ADEC to collect and transport, store,
treat, or dispose of those wastes in an environmentally
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acceptable manner. The evaluation shall consider logistical
considerations unique to Alaska, capital and long-term opera-
tions and maintenance costs, legal and administrative programs
and their impacts on both the regulated community and state
agencies, and environmental issues.
Summarize Conclusions and Develop an RFP Document
Prepare a summary of conclusions and a recommended direction
for the TSD of Alaskan hazardous wastes. Should the preferred
program be such that a long term treatment or disposal site,
or other complex facilities, be located and constructed in
state, the study would conclude with RXC/JRB preparing a
Request for Proposal (RFP) document and technical scope of
services. This RFP will enable ADEC to solicit consultant
services to initiate site location and design development of
the above preferred TSD alternative.

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2.0 HAZARDOUS WASTE INVENTORY
The successful completion of the hazardous waste TSD alternatives analysis
hinges on the ability to identify the types and quantities of hazardous wastes
generated and/or stored in the State of Alaska. Given the short time frame to
conduct the study, the inve-ntory effort was concentrated in the areas of
minimizing uncertainty in the available data base gathered from previous
inventory efforts, and in trying to ascertain the types and quantities known
to occur throughout the state but not part of the existing hazardous waste
inventory. Once the inventory information is confirmed, it can then be com-
piled in a central data base from which summary analyses can be performed.
Figure 1 represents an information flow schematic representing the development
of this data base.
2.1	Field Inspections of RCRA Permit Applicants
Nineteen commercial, industrial, and military facilities in Alaska have
applied to EPA-X for permit to own or operate hazardous waste TSD facilities.
All of these permits were filed prior to the November 19, 1980 deadline man-
dated by passage of the Resource Conservation and Recovery Act of May 19,
1980. Concurrent with these filings, EPA-X and ADEC staff performed site
investigations on most of the non-military facilities during the summer of
1980. These investigation reports provided insight and perspective to the
-ype, character, and quantities of wastes as reported in the permit applica-
tions, and provide some knowledge as to current storage, treatment, and dispo-
sal practices employed by the permit applicants. These field investigation
reports, together with the permit applications, provided some of the informa-
tion used in this report. No additional efforts were made to contact these
facilities.
In an effort to assist in quantifying waste types known to exist in the state,
EPA-X performed field investigations of the larger military facilities in the
Fairbanks and Anchorage metropolitan areas. These field studies were done
concurrently with this report, and though the investigation reports have yet
to be finalized, the field data was communicated directly to the RTC/JRB team
for insertion into the data base.(^) As with the reports described above,
these field investigations have modified the interpretation of raw data that
is reported on the Part A permit applications. The 1982 field studies suggest
the Alaskan military reservations are actively pursuing a program to export
from Alaska all hazardous wastes that have been in a long-term storage mode,
especially PCB contaminated transformer coolants.
2.2	Small Generator Waste Inventory
To assist the contractor in trying to characterize and quantify hazardous
waste generated and stored in industrial, commercial, and institutional facili-
ties, ADEC conducted a telephone inquiry of businesses across the state which
possibly generate wastes subject to the state hazardous waste management
strategy. To accomodate ADEC, the RTC/JRB team compiled a computer register
°f approximately 150 industries known to or suspected of generating hazardous
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Review/Interpret
Industrial Wastes from
Available "Records
•	Part A Applications
•	FIT Rpt; ADEC Records
•	Indus. Pretreatment
•	State Reg,Tax Records
•	PCB Wastes Inventory
Locate Industries
Waste Types and
Quantities on
Indicator Maps
Develop Small Quantity
Industrial Inventory
and Waste Types
Assemble All Data
and Prepare Central
Data Base
Verify Part A Permit
Applications via
Facility Inspections;
Confirm PCB Information
Figure 1 - INFORMATION FLOW SCHEMATIC FOR
DEVELOPMENT OF ALASKAN HAZARDOUS WASTES INVENTORY
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wastes. This computer listing (see Appendix A) included all 77 facilities
which submitted notifications to EPA-X in accordance with requirements set
forth in Section 3010 of RCRA. In addition, the Alaska Department of Commerce
and Economic Development provided RTC/JRB a 1981 listing of all entities
licensed to conduct business in the State of Alaska. This 768 page register
vas reviewed and from it was extracted a listing containing 67 small
industries which by standard industrial classification (SIC) code were
probable generators of hazardous wastes. These industries were subsequently
added to the EPA notifiers list.
central staff participated in rcrtidiicTi'ng telephone interviews with
approximately half of these small generators. An effort was made to contact
it least one company within every identified SIC code. In the Fairbanks and
Anchorage ADEC offices, regional support staff contributed to the development
if a comprehensive waste inventory. In both offices, field staff were able to
provide additional information regarding industrial hazardous waste generators
and their waste types.
During its telephone interviews with the small generators, ADEC attempted to
ietermine the following information:
•	Business name, telephone number, and confirm SIC code
•	Identify major business activity
•	Determine if any production wastes are generated, and if so,
what disposal practices are currently employed
•	Identify chemicals, and estimate quantities, used for parts
degreasing, process cleanup, or generated production wastes.
•	General awareness of RCRA regulations
Results of the small generator telephone survey reveal that of those indus-
tries which generate small quantities of wastes, they tend to generate spent
lubricants; small containers of pesticides, thinners and degreasers; and small
volumes of contaminated dry sorbents, rags, and paper products used to recover
spilled materials. Generally, all wastes are disposed of In the locally
available solid waste system. One exception may be that vaste oils are often
either burned for their heat value, or are used for dust control by road
oiling.
ADEC's telephone survey did not identify any industry which either generates
or stores hazardous wastes in excess of 100 kilograms per month. They will
continue their telephone survey for those remaining industries on the
industrial register not yet contacted. Though the waste types as reported are
real, quantities are small and as a rule would tend to be exempt from
regulation by either RCRA or the pending state program. In an effort to
collect and properly dispose of as many of these wastes as possible, a central
receiving station can be made available to the public in all communities where
wastes are known to be generated. As the receiving drums become full, or
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on a predetermined schedule, these central storage drums of wastes would b ^
collected and transported for controlled treatment and disposal.
2.3 Hazardous Wastes Data Base Generation
Concurrent with EPA field activities and the ADEC telephone survey, th	the
RTC/JRB team reviewed historical records to assemble the appropriate data bas	base
for the alternatives evaluation. All Pa-rt A permits were reviewed and dat	data
types and quantities summarized. Once this summary was prepared, it wa	was
continuously amended as additional references were reviewed, new data wa	was
forthcoming, or interpretations of composite data were made. Additions.	-onal
sources of information included the 1981 Industrial Pretreatmenc Program fo	: ^or
the Municipality of Anchorage, the 1980 FII Report prepared for EPA-X, th	clie
developing pretreatment program in the City of Fairbanks, and numerous record	:orc^s
available at both EPA-X and ADEC.
A summary of hazardous waste chemical types is presented in TaJale 1. Man
industries, and the military, report small quantity generations of spen	3Pent
solvent and degreasers (F. Series). The majority of the organic chemicals	:a^-s»
pesticides, and herbicides are reported by the military facilities (P and	nd u
Series). The largest quantity of wastes are those generated from the ot	oi*
production and bulk oil storage industries (D and K Series). In all but a fe'	' ^ew
instances, these wastes are either reinjected into the producing oil fields	:^s»
or are incinerated for heat recovery. Permits may be issued for reinjectio:	-c*on
and incineration purposes, although exemptions from regulations exist f0:	^or
subsurface injection of petroleum development wastes and incineration o	:
wastes for heat recovery purposes. Because of the possible exemption froi	i'rom
regulation, wastes disposed of by reinjection or incineration were droppei	'PPed
from further consideration in this study.
The quantities of wastes reported in the Part A application and in previou;	*ous
studies was found to be quite suspect, and required care in interpretation	ion*
Many industties, and it is believed the military too, errored on the side o:	s
caution when reporting the quantities of hazardous wastes. A fe» examples cat	can
best demonstrate this problem in data interpretation:
• A manufacturer of anhydrous ammonia and urea products has
reported generation of 83,000 tons per year of non—listed
corrosive wastes. Upon Investigation, these wastes are spent
catalysts used in the production process. The ceramic catalytic
materials are contained in thirteen production vessels, with
vessel catalytic loadings of 20 to 230 tons. Due to position in
the process stream, and catalytic material properties, the
vessels are batch dumped anywhere from every one (1) to six (6)
years. The ceramic materials are dumped onsite in large holding
ponds where they spontaneously oxidize with air. Though Che
ceramic matrix contains heavy metals, or have heavy metal con-
taminants adhering to the granule surface, the spent catalysts
have been tested using the Federal EPA Hazardous Waste Extrac-
tion Procedure, and they all were shown to be non-hazardcms in
terms of leaching metals. Holding basin rainfall water is
collected and treated with other plant wastewaters prior to
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Table 1 - HAZARDOUS WASTE CHEMICAL TYPES
REPORTED BY ALASKAN INDUSTRIES
Code
Substance
Code
Substance
DOOO
Non-listed toxic wastes
D004
Arsenic
D001
Non-listed ignitable wastes
D008
Lead
D002
Non-listed corrosive wastes
D009
Mercury
D003
Non-listed reactive wastes
D011
Silver
F001
Spent halogenated degreasing
solvents
and sludges
F002	Spent halogenated solvents and still bottoms
F003	Spent non-halogenated solvents and still bottoms
F005	Spent non-halogenated solvents and still bottoms
F017	Paint residues generated from industrial painting
F018	Wastewater treatment sludge from industrial painting
K049	Slop oil emulsion solids from petroleum refining industry
K050	Petroleum refinery cleaning sludges
K051	API separator sludge from petroleum refining industry
P035	2,4-Dichlorophenoxyacetic (also listed U240)
P049	2,4-Dithiobiuret
PI02	Propargyl alcohol
P105	Sodium azide
P106	Sodium cyanide
U002
Acetone
U161
Methyl isobutyl ketone
U013
Asbestos
D169
Nitrobenzene
U031
N-Butyl Alcohol
U170
p-Nitrophenol
U044
Chloroform (I,T)
U188
Phenol
U059
5,12-Naphthacenedione
U201
Resorcinol
U069
Dibutyl phthalate
U210
Te t rac hloroe thylene
U072
p-Dichlorobenzene
U211
Carbon tetrachloride
U080
Methylene chloride
U218
Thioacetamide
U102
Dimethyl phthalate
U220
Toluene
0117
Ethyl ether
U223
Toluene diisocyanate
U122
Formaldehyde
U226
1,1,1-Trichloroethane
U134
Hydrofluoric acid
U227
1,1,2-Trichloroethane
U144
Lead Acetate
U228
Trichloroethene
0151
Mercury
U233
2,4,5-T (Silvex)
U154
Methanol
U239
Xylene
U159
Methyl ethyl ketone


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regulated discharge to Cook Inlet. The company also reports: tthe
generation of 36 tons per year of arsenic wastes. These arsfflnic
compounds are a contaminant (at 20 ppm) of an oxazolidine waffi.te
byproduct. Oxazolidine is used in cleanup and stripping of
gaseous carbon oxides in the natural gas stream before chennical
reactions lead to product formation. Produced at a rate oaf
about 50 gallons per day, the oxazolidine is containerized: "in
drums, stored on site, and transported to Seattle for recycle
and/or destruction.^) Annual shipment rates are approximately
400 drums.
•	A petroleum producer on the North Slope reports the annual gen-
eration of 30,000 pounds of lead wastes. Inquiry conducted ffiar
this study identified these wastes as leaded tank bottoms and
leaded waste lubricants, all of which are reinjected in vasrte
disposal wells located on the slope.
•	Many of the military facilities reported as wastes what ap^satar
by their description to be useable products in Inventory. iFot
example, Fort Greeley (US Army) reports eleven different pesati-
cide products in storage, including 230 nine—ounce aerosol cans
of Pyrethrin. It is difficult to determine if these cans are
indeed waste, are off-spec or excess supplies, or are useable
products in storage.
2.4 Waste Types, Quantities, and Distribution
Hazardous wastes are ubiquitous to our society when one considers small
volumes of wastes generated by the home owner, and those wastes generated by
the commercial and Industrial sector. In the analysis of small and large
generators of hazardous wastes, the distribution of generator sources runs
from Adak to Ketchikan, and from Kodiak to Prudhoe Bay. Figure 2 shows that
the majority of generators are located in the urbanized and industrialized
Matanuska and Tanana Valleys. Further analysis of the available data also
suggests that the known significant generators of hazardous wastes, those
which generate more than 100 kilograms per month, are all in the vicinity of
Anchorage, Kenai, Fairbanks, or Prudhoe Bay.
A compilation of available data suggests that hazardous wastes are generated
in Alaska at an annual rate of 350 to 400 tons per year. This range is
approximately half that projected by ADEC staff in early 1981, and can be
explained primarily by exclusion of waste petroleum fractions presently incin-
erated or disposed of on-site, and by identification of data entry errors as
indicated in Section 2.3 above. Of this total annual generation rate, approxi-
mately 65 percent of the wastes are generated among the numerous military
bases throughout the state. Elmendorf and Eielson Air Force Bases, and army
installations at Forts Richardson and Wainwright, together generate 60 percent
of the statewide total.
Statewide wastes were separated into four classes to facilitate quantitation
and identification of alternatives for treatment and disposal. These four
classes included:
12

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Prudhoe
Fairbanks #•
<0
Anchorage
iJuneau
rJ &

..
o».

• m. Adak Island	* _
• %
»*%
Figure 2 - FACILITY LOCATION OF KNOWN GENERATORS OF HAZARDOUS WASTES IN ALASKA

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•	Solvents - chemicals or petroleum distillates used for metal
parts degreasing, cutting and finishing; varnish, lacquer and
paint thinners; and paint stripping solutions. The wastes are
generally ignitable substances. If kept free of cross-
contamination, and at least 80 percent of the waste solvent is
of a single chemical type, they lend themselves readily to
recovery and reuse.
•	Petroleum Sludges - contaminated petroleum wastes that are
either a byproduct of a recovery or distillation process, or are
sludges which have accumulated in bulk ^storage ranks a ad have
been withdrawn during tank maintenance procedures. The wastes
have limited combustibility, often can contain sediments and
heavy metal contaminants, and are generally not suitable for
product recovery. They may be suitable for roadway stabili-
zation or incorporation into road surface mixes.
•	Acids and Corrosives - liquid wastes from pickling liquors,
electroplating baths, battery manufacturing, and boiler tube
descaling processes. Acid wastes may often contain high dis-
solved heavy metal concentrations, whereas caustics often
contain colloidal suspensions and high alkalinity. These wastes
streams are rarely suitable for product salvage or recovery.
However, they can be neutralized and then possibly disposed of
in local landfills.
•	Other Sludges and Solids - hazardous waste solids which may be
elctroplating sludges from industrial pretreatment systems,
spent containers and waste pesticides and herbicides, and out-
dated or waste chemical reagents and materials from laboratories
and other testing services. These wastes streams are generally
in small batches, may be mixed, and generally are not suitable
for reclamation or recovery.
Solvent wastes account for approximately 60 percent of the known hazardous
wastes generated in the state. Together with the acid/caustic wastes, liquid
wastes approximate 75 percent of the total generated waste streaa. Table 2
presents a detailed summary of the waste type, quantities, and generator
location for those facilities found to generate one drum equivalent or more of
wastes per month. To accomodate uncertainties in the data base, roundoff
error in monthly generation rates has been to the high side.
Two proposed regional storage facilities have been included in the total
monthly waste projections. One is located in both Fairbanks and Anchorage to
serve the residential and small commercial hazardous waste generator. Thes<
users are those which generate small quantities of wastes on an infrequent
basis. For example, a small plater who neutralizes and dumps his plating batt
once in six months and generates a five-gallon pail of heavy metal hydroxid*
sludges. Likewise, the home owner will have available a local facility at
which to dispose of old solvents, thinners, and pesticides.
14

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Table 2 - HAZARDOUS WASTE GENERATOR WASTE TYPES,
MONTHLY QUANTITIES, AND ALASKAN LOCATIONS
(55 gallon drums/month)
Facility
Adak Naval Station
Alaska Husky Battery
Alaska Plating
Alaska Railroad
Anchorage Regional TSD
Clear AFB
Eielson AFB
Ilmendorf AFB
"airbanks Regional TSD
?ort Greely
?ort Richardson
Tort Wainwright
Frontier Tanning
General Electric Co.
North Pole Refinery
Phillips Petroleum
Statewide Subtotal (with Military)
Commercial/Industrial Total
(without Military)


Petro
Acids/
Other
Citv
Solvents
Sludges
Caustics
Solids
Adak
—
1
—
—
Anchorage
—
—
—
1
Anchorage
—
—
—
1
Anchorage
4
—
—
—
Anchorage
2
2
1
1
Clear
3
—
—
—
Salcha
20*
—
—
—
Anchorage
12
—
13
2
Fairbanks
1
1
1
1
Ft. Greely
1
1
—
—
Anchorage
8
—
3
—
Fairbanks
9
—
—
1
Anchorage
—
—
—
1
Kenai
2
—
—
—
North Pole
2
4
1
—
Kenai
2
11
1
—
66
13
20
18
20
4
8
5
Monthly Statewide Waste Rate ¦ 114 drums
Monthly Commercial/Industrial Waste Rate - 40 drums
*Includes 10 bbls/month of methanol
15

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Similar small scale storage facilities could be made available at the more
remote communities across the state. Wastes generated in the west and south-
west part of the state could be collected on a continuous basis, and when
drums are full flown to Anchorage for shipment to the final TSD facility.
Although hazardous wastes generated in cities in the southeast would be
collected and stored in similar local receiving stations, it is probable that
transport and final disposition of the wastes could -more readily be accom-
plished via transport to Seattle.
16

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3.0 HAZARDOUS WASTE COLLECTION, STORAGE, AND IN-STATE TRANSPORT
3.1 Current Waste Disposal Practices
Section 2.0 concludes that approximately 350 to 400 tori6 per year of hazardous
wastes are generated in the proximity of Fairbanks, Anchorage, and Kenai.
Current disposal practices include long term on-site accumulation, land
disposal both on-site and in local landfills, selected incineration with other
combustible wastes, and to a limited extent transport and disposal at the
secure landfill in Arlington, Oregon. Information made available to ADEC by
che operator of the Arlington disposal site reveals the following waste types
and quantities being received from military and industrial facilities in
Alaska for the 27-month period eoding in March, 1982:
ALASKAN HAZARDOUS WASTES RECEIVED AT
ARLINGTON, OREGON SECURE LAND DISPOSAL SITE
(January 1980 - March 1982)
PCBs
Acids/Bases
Sludges
Pesticides
Other
Comparison of the above information, with the net difference between the
November, 1980 Part A applications filed by Alaskan military and industrial
facilities and the 1981-1982 field inspection reports, suggests that many of
the PCB contaminated oils, and pesticide and herbicide wastes, have been
removed from on-site storage and exported for secure disposal. Assuming that
the waste acid/caustics, sludges, and other wastes have a specific weight of
65 pounds per cubic foot, It can be estimated that approximately 36 tons per
year of acids, caustics, sludges, and other hazardous wastes are being sent to
Arlington, Oregon for treatment and disposal. This represents approximately
20 percent of the annually generated 178 tons of non-solvent hazardous wastes
identified in Section 2.0. The disposition of the remaining solids is not
known. On-site storage, and disposal in local landfills, are the two most
probable disposal routes.
The disposition of the 200 tons of solvent wastes annually generated in Alaska
is not as clearly understood. Discussion with a large solvent reclamation
facility in Seattle (and only known recycler of such wastes in EPA Region X)
reports that he has received no solvents from Alaska for treatment or
quantity (eu ft)		percent
of Total
27-Month
Annual Average
5,455
2,424
1,491
663
539
240
381
169
63
28
7,929
3,524
68.8
18.8
6.8
A.8
0.8
17

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disposal. It is probable that many of the waste solvents are discharged t( t0
local sewer systems, disposed of in local landfills, or are incinerated witl
waste oils and other combustibles for their heat value.	(
Knowing the hazardous wastes composition and quantities, one is now prepare! rec*
to begin the development of alternatives to collect, transport, and treat ot or
dispose of those wastes. Figure 3 presents an information schematic repre* ~c~
seating the development of these alternatives. Collection and in-state trans- 1S"~
port will be discussed below. Ultimate treatment and disposal alternatives "es
will be discussed in Section 4.0.
3*2 Collection Facilities for Small Quantity Generators
The proposed state regulations for Alaskan hazardous wastes management intends 1C'S
to identify all facilities which generate more than 100 kg/month of wastes, as'
and encourage resource recovery, or the transport and proper treatment and
disposal of these wastes. In addition, ADEC seeks to prevent wherever prac-ac
tical the placement of any hazardous wastes in unsecured land disposal areas,TS*
To achieve this end, it is recommended that small generator waste repositories~es
be constructed in both Fairbanks and Anchorage, at a minimum, and elsewhere as aS
necessary when the present demand or future growth justify their presence.
The hazardous waste collection station will act much like a transfer station ~on
o S
in a conventional solid waste management program. Small quantities of wastes," '
generally of the solvent, sludge, or pesticide components, will be brought to^
the storage facility on a random basis during scheduled open hours. Thc^*
operator of the facility will log in on manifests the waste types and quanti-"1
ties, and repack the small containers in one of several large storage ^ru®*:)e{j
for that type of compatible waste until they become full. On a prescribed^^
schedule, these wastes would be collected by a contract transporter who would
ship the wastes to a predetermined TSD facility.
Minimum criteria for the location of the collection station include:
•	Ready access by road from the surrounding service area
•	Proximity to long distance highway or railroad transportation
corridors
•	Compatibility with local land use plan
•	Adequate distance and physical separation from any surface water
course, ground water table or recharge zone
•	Adequate distance from human habitation
•	Availability of on-site or neighboring 24-hour security or
surveillance
•	Availability of skilled operating labor and local fire fighting
staff trained in hazardous waste management, chemical handling
and safety, and emergency spill response.
18

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Identify Uistc
Storage Treatment
and Disposal
Alternative* Bated
on Known laforat.ition

Identify Geographic
Target Areaa for
Disposal facllttUa





Meat Iff fiantfQeudaal
Storage t Transfer
Support Servlcei to
(¦plcacnt Ujistt
Katiigenent Presraa
OtCeralM Oetlgn
Criteria far Disposal
A) tarnati vri
Identify Fnvironaental
Conslulntt, Socio-
Economic Considerations,
long-Tera Indu»tr1al
Growth fotentlal I
Identify frogr
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Given chat Anchorage and Fairbanks have the largest municipal frire fightii =
units, both have a large military presence for emergency responise purpose '
and both have ADEC regional offices staffed with professionals trained in p: A
and hazardous materials emergency response, these cities cart provide t! 2
initial logistical support necessary to augment a local hazardous waste shoi :
term storage site. Candidate sites for locating the facilities include*
Anchorage	Fairbanks
Sewage Treatment Plant	Sewage Treatment Plant
Merrill Airfield Area	Fairbanks Landfill
Anchorage Internat'l Airport Area	Fairbanks Internat'l Airport Area
Anchorage Landfill	Peger Road Industrial Area
Ship Creek Industrial Area	Phillips Field Industrial Area
Campbell Airfield Area
3.2.1 Waste Collection, Packaging, and Handling - Since collected -wastes wiJ~
be transported by truck and/or rail to a treatment and disposal facility!
procedures must be followed to comply with waste acceptance criteria require3
by both the Department of Transportation (DOT) and the secure landfill dispos"
al operator. The listed DOT items not acceptable for transport as hazardou^
waste, or not acceptable for disposal will be continuously updated by Apt"
management and facility owners to reflect current technology. Extreme!'
dangerous or reactive chemicals may be refused if the hazards to collectijf1
site, transporter, or disposal site personnel and facilities are considered t°
be unacceptable.
By collecting the hazardous wastes generated by others, the central receiviip
site becomes a hazardous waste storage facility as defined by RERA regula~
tions. If more than 1000 kilograms of wastes accumulate and are stored f
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waste. It should be noted that original containers for many hazardous
~aterials (such as pesticides, herbicides and acids) are probably suitable for
those items as hazardous wastes. Should a container be leaking, it may be
able to be placed into another container or its contents mixed with or poured
onto an absorbent material.
:he facility will normally have three DOT-approved open-head metal drums with
;he lids removed available for the collection of the three accepted hazardous
;aste classes, namely: ignitable wastes, corrosive wastes, and toxic wastes.
¦DOT prohibits the shipment of corrosive liquids in metal outside drums or
-.arrels unless an exemption is obtained, but EPA requires the outside
containers be metal). Standard drums are 55 gallons, but drums up to 110
allons capacity may be acceptable. Containers of compatible wastes of the
ame waste class would be placed into each outside container. Those inside
containers would be overpacked and surrounded, at a minimum, by a sufficient
luantity of absorbent material to completely absorb all liquid contents of the
inner containers. Suitable absorbent materials include vermiculite, compres-
sed peat, and fuller's earth. Other materials, such as dirt and flyash, may
be able to be used for some classes of hazardous wastes. However, these
denser materials will add considerably to the cost of transport as compared
against the highly absorbant and light vermiculite and peat. There is no
maximum inside container size constraint or liquid quantity constraint for
items placed into the outside container, provided the absorbent packing
aaterial will completely absorb the total amount of liquid. Typical liquid
loads might be 20 gallons in a 55-gallon drum; solids and sludge loads might
be equivalent to 40 gallons per drum.
When full, each outside container would be sealed and placed into storage.
Storage areas shall be secure, protected from the elements, and able to con-
tain any hazardous waste spill. Only compatible wastes should be stored in
close proximity to each other. While separate storage facilities are not
required for each class of hazardous waste, sufficient clearance should be
allowed in the event of a spill, leak, fire, or other emergency condition.
Clearance requirements shall depend upon the quantity and types of hazardous
materials in storage, and local building and fire codes.
3.2.2 Small Quantity Collection Facility Design Considerations - Small
quantity collection and storage facility size may vary due to storage
requirements. Regardless of the facility size, however, there are at least
ten steps taken at the facility prior to shipment by rail or truck which
affect design. These are:
•	Receive and identify wastes
•	Determine compatibility with other wastes in proposed collec-
tion/storage container
•	Initiate and/or annotate a listing of contents for drum
•	Load wastes into drum and pack with absorbent, non-reactive
material
21

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• Seal drums when full
•	Score drum until transported
•	Monitor sealed containers of hazardous waste for signs of
damage, leakage or contamination
•	Arrange for transporter to transport drums to disposal site
•	Initiate manifest
•	Maintain permanent records for at least five years to assure
complete traceability of each material delivered to the facility
for processing
To perform these functions small quantity collection and storage facilitie;es
were designed using readily available materials. The initial investment f
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Table 3 - COMMON HANDLING, SAFETY, AND OFFICE EQUIPMENT
EACH HAZARDOUS WASTE COLLECTION AND STORAGE FACILITY
FOR
-- -nritv Item	Cost
I Four-Wheeled Drum Truck with Hand Brakes	$ 350
1 Portable Eye/Face Wash and Body Spray or	Emergency 402
Drench Shower with Eye/Face Wash
1 First Aid Kit, OSHA Approved	35
12 Plastic Goggles	46
5 Non-Toxic, Dry Chemical Fire Extinguisher ($64 each)	320
3 Dust/Mist Respirators ($10-72 each)	210
1 Desk	360
1 Desk Chair	115
1 Bookcase	76
1 Filing Cabinet	163
1 Work Table	93
As Miscellaneous Shovels, Hoses, Handtools,	Reference 500
Required Books, Alarms, etc.
1* Hyster H40XL or Two-Ton Clarklift, Dual Wheeled,	20,000
Pneumatic Tired, or Equivalent
Shipping and Handling (estimated)	1.500
TOTAL COST PER FACILITY:	$24,170
*For loading drums either singly or palletized on truck. Duals with
chains are required for winter and spring operations.
23

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Table 4 - ESTIMATED ANNUAL "CONSUMABLE SUPPLIES FOR ALASKAN
HAZARDOUS WASTE COLLECTION AND STORAGE FACILITIES
FAIRBANKS FACILITY
Quantity Item	Cost
110 55-Gallon Open Head Metal Drums with Lids	$ 3,330
(for one year, $33 each)
110 Units of Vermiculite (Sl/lb, 40 lbs per drum)	4,400
200 Plastic Waste Can Liners (55 gallon)	80
1000 Plastic Waste Can Liners (4+ gallon)	35
15 doz Plastic Work Gloves ($25/dozen)	375
A/.R .Manifest Jonas, DOT Labels, Marking Equipment & Tags	500
Freight, Handling and Tax	3,100
TOTAL COST FOR FAIRBANKS FACILITY:	$11,820
ANCHORAGE FACILITY
158 55-Gallon Open Head Metal Drums with Lids	5,215
(for one year, $33 each)
158 Units of Vermiculite ($l/lb, 40 lbs per drum)	6,320
300 Plastic Waste Can Liners (55 gallon)	120
1000 Plastic Waste Can Liners (4+ gallon)	35
30 doz Plastic Work Gloves ($25/dozen)	750
A/R Manifest Forms, DOT Labels, Marking Equipment & Tags	800
Freight, Handling and Tax	A,450
TOTAL COST FOR ANCHORAGE FACILITY:	$17,690
24

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•	Each 55 gallon drum in storage will be allocated 4 square feet
of floor space. A 4-foot aisle for each double row of drums is
planned to allow maneuvering in and out of full containers and
for leakage inspection
•	Each storage structure shall be constructed to contain all
spills, and will provide positive drainage to a dead end sump
for the collection and removal of waste or wash down effluents
•	A Hyster H40XL fork lift (or equivalent) will be required at
each site for loading filled drums onto transport vehicles. It
may be desirable to palletize and band four drums together for
more rapid loading of transport vehicles and increased security
to preclude cargo shifting in transit
•	The steel structure should be designed to accomodate local snow
and wind loadings. At least the office area in the storage
building should be insulated and heated
•	Lighting in the office and storage areas of the structures and
in the outside transport loading areas will be required
•	For fire control, 5 dry chemical fire extinguishers have been
included. Sufficient water should be made available to also
handle showers, eye wash, and facility washdown
•	All permits and licenses required by local, state and federal
statutes will be obtained by ADEC or its contractor
•	Small waste generators in outlying areas may arrange for surface
or air transport of their wastes to the nearest collection and
storage facility for processing and shipment. Sma 1 waste
generators in southeast Alaska may find it easier to manifest
and transport wastes directly to Seattle
. • All wastes generated by military DPDO will be picked up and
transported by an ADEC contractor "milk run" truck, or can be
transported to processing, storage, or disposal destinations by
military-arranged transport
•	Major generators (those who generate more than one drum per
month) will manifest their own wastes and arrange with ADEC or
"milk run" transport operator to transport those wastes directly
to the processing, storage, or disposal sites
In summary, and based upon the assumptions and operating constraints listed
above, it is recommended that two steel Butler Buildings (or equivalent) be
utilized for the small quantity collection and storage facilities. Each
structure should be mounted on an 8" concrete side curb which extends 12"
above grade. A concrete ramp should slope up to the entrance to permit
forklift access. The concrete floor should slope downwards toward the back of
the structure, approximately 3 inches per 10 feet of run, and all floor slab
25

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and side wall joints should be tightly sealed to provide a leak proof barrier.
A liquid collection sump should be located at the low end of the building to
catch spilled liquids and wash down effluent. The floor sump will allow for
return of wastes to empty drums in preparation for disposal. All concrete,
steel and utilities should be installed in conformance with local, state, and
federal specifications. Adequate washdown facilities should be provided for
equipment, personnel, and structures. A security fence with locked gate is
recommended. If possible, 24-hour building surveillance is suggested.
Sufficient lighting should be provided inside the building and in the truck
loading area. A latrine facility inside the building is recommended, or a
separate office facility with sanitary facilities should be provided within
walking distance.
Personnel work, areas should be heated. Care should be taken to locate atiy
heating system in an area where explosive fumes are not likely to migrate.
Ceiling and floor ventiliation should be provided. All motors, lighting, and
heating systems will be explosion-proofed. Appropriate cabinets or storage
units should be provided and prominently labled for the safety equipment
listed in Table 3. Eye wash and showers should be in close proximity to the
small lot packaging areas.
A structure 20' x 25' will suffice for the Fairbanks facility, and 20' x 40'
structure will be required in Anchorage. The intent is to initially build
minimum sized facilities. Additional modules may be added later if actual
volumes and operating experience warrant the expansion. The use of existing
building(s), if available, could greatly reduce the cost of implementing a
hazardous waste collection and storage system for Alaska. Even a wooden
structure might suffice if properly fire-proofed. The faciliites described
above have a combined construction and first year equipment cost of approxi-
mately $102,600, excluding land or land development costs. Approximate costs
for each facility are provided in Tables 5 and 6. Available technical
descriptions, together with a preliminary building design are included in
Appendix B.
Tables 5 and 6 also project 20-year annualized operating costs assuming 0.4
man years of on-site operation. It is projected that each facility would be
staffed by two persons, two days per week. Two persons are suggested for
safety purposes unless the facility is constructed adjacent to the currently
operating and staffed wastewater treatment plant, landfill, or other services.
The facility would be open to receive hazardous waste materials approximately
six hours each day. To accomodate all potential users of the facility, it is
recommended that operating hours flex across local labor work shifts, and
operate at least two days per week. A suggested schedule would be Tuesday, 2
pm to 8 pm; and Friday 8 am until 2 pm. This staggered schedule is more
conducive to the high percentage of military and other work forces in the
areas who have flexible or varied work shifts. The remaining four hours of
work effort each day should be dedicated to wastes handling and containeri-
zation, and to administrative functions associated with RCRA and ADEC regula-
tions. The total annual operating cost estimate for these two storage facili-
ties, including capital recovery, expendable supplies, and labor, is approxi-
mately $93,000. Almost $50,000 is dedicated to labor. Should the hours of
operation be shortened, or staffing be reduced from two persons to one, the
26

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Table 5 - METAL STORAGE BUILDING HAZARDOUS
WASTE COLLECTION AND STORAGE FACILITY
(Fairbanks Area)
I. Capital Construction
20' x 25' Steel Butler Building or Equivalent	$ 7,500
(500 sq ft @ $15/sq ft)
Set-Up Labor:
4 Millwrights, 2 days @ $35/hr	2,240
Miscellaneous Carpentry and Trimming; 2 Carpenters,	1,344
3 days @ $28/hr (All labor rates basic plus fringe,
no overhead or G£A)
Concrete:
Slab - 500 sq ft @ $3.20/sq ft	1,600
Footings and Curbs - 13 cubic yds @ $120/yd	1,560
Utilities:
Electrical	2,500
Plumbing and Heating	3,500
Freight on Steel, 4000 lbs:	2,050
Barge ¦ 15,000 lb minimum @ $7 cwt
Truck - $1,000 minimum	*
SUBTOTAL:	$22,294
Common Handling, Safety and Office Equipment, 24,170
From Table 3.		
TOTAL ESTIMATED CONSTRUCTION AND EQUIPMENT COST:	$46,464
II. 20-Year Annualized Cost
Capital Recovery, 20 years <3 12% (CRF - 0.1308)	$ 6,077
Annual Consumable Supplies, from Table 4.	11,820
Operating Labor (0.4 MY @ $30/hr, fully burdened)	24,960
TOTAL ESTIMATED ANNUAL COST:	$42,857
27

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Table 6 - METAL STORAGE BUILDING HAZARDOUS
WASTE COLLECTION AND STORAGE FACILITY
(Anchorage Area)
Capital Construction
20' x 40' Steel Butler Building or Equivalent	$12,000
(800 sq ft @ $15/sq ft)
Set-Up Labor:
4 Millwrights, 3 days @ $34/hr	3,264
Miscellaneous Carpentry and Trimming; 2 Carpenters,	1,296
3 days @ $27/hr (All labor rates basic plus fringe,
no overhead or G&A)
Concrete:
Slab - 800 sq ft @ $3.20/sq ft	2,560
Footings and Curbs - 18 cubic yards @ $120/yd	2,160
Utilities:
Electrical	4,000
Plumbing and Heating	5,600
Freight on Steel Structure, 6000 lbs (15,000 lbs	1,050
minimum @ $7 cvt)		
SUBTOTAL:	$31,930
Common Handling, Safety and Office Equipment,	24,170
From Table 3.		
TOTAL ESTIMATED CONSTRUCTION AND EQUIPMENT	$56,100
II. 20-Year Annualized Cost
Capital Recovery, 20 years @ 12% (CRF ¦ 0.1308)	$ 7,338
Annual Consumable Supplies, from Table 4.	17,690
Operating Labor (0.4 MY @ $30/hr, fully burdened)	24,960
TOTAL ESTIMATED ANNUAL COST:	$49,988
28

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total estimated cost of operating two regional hazardous wastes collenttion
facilities would be approximately $68,000 per year. It is postulated: .that
staffing costs could be reduced further if the facilities .are constructed in
conjunction with the local municipal solid waste landfill operations.
3.3 Intrastate Transport of Alaskan Hazardous Wastes
Once wastes are containerized and manifests are prepared by either the large
industrial or military facilities, and the owner/operator of the regional
waste storage centers, a mechanism for transhipment of these wastes tn> .an
¦ultimate TSD facility oust be realized. £eferring to Figure 2 and Xable ZL, it
is realized that the majority of hazardous wastes transported to a TSD
facility can occur in but a few directions:
1.	Wastes transported by rail or highway in the Railbelt between
Fairbanks and Anchorage
2.	Wastes transported by highway to Seattle via the Alcan highway
from either one or both of the metropolitan areas
3.	Wastes transported by barge to Seattle via Whittier, Seward or
other ice-free deep water port. Surface delivery to the deep
water port is provided by rail or highway
A discussion of each of the above transport scenarios follows.
3.3.1 Railbelt Transport of Wastes - The distribution of waste types and
quantities is such that approximately 70 percent of the total waste volume is
in the Anchorage area. Using a 40 to 45-foot tractor trailer, there are
sufficient waste generation rates in the Anchorage/Kenai area to warrant a
"milk run" to pick up these wastes on a monthly basis. In the Fort Greeley to
Fairbanks region, scheduled transport pickup to insure a full truck load will
occur every five to six weeks. A schedule and route of service can be
designed for the transporter based upon location of the wastes in storage and
the ultimate destination of the materials.
Wastes travelling between Fairbanks and Anchorage can go by highway truck, or
by boxcar or piggy back railcar. The analysis of costs for intra-state high-
way transport (see Appendix C) suggest that the price per drum to transport
wastes between the two cities is rather insensitive to whether a TSD is placed
in Fairbanks or Anchorage. Because only rates and tariffs vary, railcar total
costs suggest the same degree of insensitivity. However, about twice the
volume of wastes would be shipped north as shipped south. This tends to favor
locating any Alaskan TSD facility closer to Anchorage than Fairbanks.
A north region truck destined for Anchorage would begin its "milk run" at Fort
Greeley. Moving west along Highway 2, it stops at all military and industrial
waste generators. It picks up wastes at the Fairbanks small generator storage
site and proceeds south on Highway 3 to Clear Air Force Station. This is the
last scheduled stop and the truck run is complete; it now proceeds directly to
the Anchorage area TSD or transhipment point. Costs to transport by highway
the total wastes in the Fairbanks area is estimated at $21,000 per year.
Should weather preclude highway transit through the Alaska Range, the truck
29

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can turn back to Fairbanks and be placed aboard a railcar, or wastes can be
loaded into a boxcar. Costs to transport by rail a fully loaded truck trailer
(AO-foot, about 50,000 lbs gross) is approximately $980. (Note: There is a
railroad penalty of $13/foot for trailers over 40 feet in length.) Railcar
transport is a preferred mode of transit if the ultimate TSD facility is in
Seattle, and all wastes are to be transported by hydro-train out of Whittier.
The Fairbanks' hazardous wastes now stays aboard the railcar from point of
loading until offloading in Seattle (see Section 4.4).
A south central region truck destined for Fairbanks would begin its "milk. Tun"
in the fceaai Area, proceed north through Anchorage and Palmer, and thence to a
Fairbanks TSD facility. The cost to transport the total annual quantity of
wastes in the Kenai/Anchorage area over the highway is about $33,000 per year.
3.3.2	Alcan Highway Transport of Wastes - Wastes locally collected in either
the Fairbanks or Anchorage areas, and destined for Seattle by an all-highway
route, would be diverted east from the two metropolitan areas to Tok Junction
for the trip east and south by road. The costs incurred above would not
accrue, for there would be tu> north-south transport of wastes. Truck trans-
port rates quoted in Appendix C are those applicable from either Anchorage or
Fairbanks to Seattle.Current commercial rates for truck transport of
hazardous wastes are $25.29 cwt for 40,000-pound load weights up to $57.87 cwt
for 5,000-pound loads. These costs are treated as part of ultimate TSD
expenses and are addressed in Section 4.5.
3.3.3	Hydro-Train Transport of Wastes - At least one commercial barge opera-
tion serving Alaska via the Port of Whittier has the capability to transport
hazardous wastes by ocean barge. (?) it has not yet been called upon to
transport such wastes. The marine service involves barging of railcars
between the Seattle and Whittier rail-fitted barge terminals. Described
above, fully loaded boxcars or railcars with 40-foot tractor trailers
originate one each from Fairbanks and the Anchorage area. (Highway t'ravel is
not possible from Anchorage to Whittier; all highway vehicles must be placed
aboard the train for rail transit through the mountains.) To facilitate
greater efficiency of truck travel once the trailers arrive in Seattle, it is
recommended that the loads on all trailers leaving the Anchorage rail yard be
dedicated for either Seattle solvent recovery, or Arlington, Oregon secure
land disposal. This may require transferring of loads between the trailer or
railcar from Fairbanks, and the highway trailer from Anchorage/Kenai before
the latter trailer is lifted from the highway vehicle and placed aboard a rail
car. Any transfer of loads would also require the proper manifest transfers.
Total annual hydro-train transport ' costs approximate $56,800 per year. Of
this amount, approximately $25,800 is associated with the Fairbanks waste frac-
tions, and $31,000 with wastes generated in the Anchorage/Kenai area. Costs
to ocean barge hazardous wastes from Whittier to Seattle range from $5.36 cwt
for 60,000-pound loads up to $7.41 cwt for 40,000-pound minimum loads. In
addition, the 40-foot wheeless trailer (about 12,000 pounds net) will cost
$8.02 cwt. These ocean tranport costs are treated as part of ultimate TSD
expenses and are addressed in Section 4.0.
30

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3.4 Uniform Manifest for Transporting Hazardous Wastes
All wastes to be transported for treatment, storage, or disposal musst be
accompanied by a manifest form which describes waste types and quantities, and
serves to verify final disposition of wastes by "cradle-to-grave" log sheet
tracking of the hazardous wastes.
At the present time, most hazardous waste generators use manifest forms pre-
pared in-house, or those model forms prepared by EPA, the Department of
Transportation (DOT), or by more than 20 states. Though current RCRA regula-
tions allow for the use of an individualized manifest so long as it meets
minimum information requirements, differing requirements between states 'have
caused conflict in the number and types of manifests necessary to transport
waste across numerous state lines.
Wastes exported from Alaska by barge must meet federal manifest standards,, as
well as those required in at least the states of Washington and Oregon.
Should wastes be trucked .from Alaska, these manifests must also maec the
Canadian provincial requirements in British Columbia and the Yukon Terri-
tories .
To correct the confusion and compliance difficulties for the transport of
hazardous wastes that has resulted from numerous, but slightly different,
manifest forms used among the states and regulatory agencies, the EPA and DOT
have proposed the use of a nationally uniform manifest form.(8) \ draft of
the proposed rules, amendments, and an example of the form, were published in
the Federal Register on March 4, 1982. It is recommended ADEC review this pro-
posed rule change and determine if the proposed manifest will meet the
reporting requirements ADEC is calling for in the developing state hazardous
waste rules and regulations. A copy of the full text of the proposed rules
change (40 CTR Parts 123, 260, and 262) is enclosed in Appendix D.
It should be noted that for most waste shipments from Alaska, there will
likely be three or more transport carriers involved. This will require the
use of the "continuation sheet" as proposed by EPA/DOT. Space is provided for
special handling requirements or additional shipping instructions.
31

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4.0 HAZARDOUS WASTES TSD ALTERNATIVES EVALUATION
Generators of hazardous wastes in Alaska have been identified and scenarios
have been developed by which these wastes can be transported to one or more
central facilities for treatment, recovery and recycle, or permanent disposal.
Likewise, waste transfer facilities provided for in at least Fairbanks and
Anchorage can be constructed to act as short term storage for small quantity
generators of wastes. These repacked and containerized wastes, together with
larger quantities of wastes generated -at the military facilities and larger
industries, can provide the quantities of wastes on a monthly to bi-monthly
frequency to justify truck and/oT railcar transport of wastes.
This section focuses on the ultimate disposition of these wastes once they
have been collected and placed aboard a common carrier. The ADEC hazardous
waste program is being written to encourage resource recovery where practical.
The high percentage of solvents in the total waste stream makes solvent reco-
very a worthy objective, particularly if product resale value can offset the
costs of treatment. Also Federal regulations and the Oregon DEQ may soon
preclude the landfill disposal of drums of liquid hazardous wastes. The high
probability of mixed solids in the waste sludges, and the low rates of
generation, precludes a serious consideration for treatment and resource
recovery in any sludge or solids waste fractions.
In considering waste solvent management strategies, four TSD methods were
believed appropriate. However, one of these (out-of-state incineration) was
soon eliminated because there are no incineration facilities within a reason-
able hauling distance. The three chosen options included solvent recovery in
Alaska; solvent recovery in Seattle, Washington; and incineration in Alaska.
There is generally no other practical method of managing spent solvents except
for burial in a secure landfill. This method was not considered, "however,
because the mobility and toxicity of buried spent solvents create an
unnecessary risk of groundwater contamination.
The waste acids and caustics generated in Alaska could be managed by neutrali-
zation followed by solidification and landfilling. Since most neutralization
now occurs at the generator site, these wastes could either be solidified and
buried in Alaska or at the landfill site in Arlington, Oregon. The small
amounts of unneutralized acids and caustics could be decontainerized, neutra-
lized and solidified at either of the alternative landfill sites; hence, there
would be no need to separately consider an Alaska neutralization facility. Of
those wastes that are neutralized by the generator, some of these materials
may no longer meet the definition of a hazardous waste and therefore would not
be subject to consideration in this study. All of these neutralized wastes
were included, however, because they may "fail" the RCRA toxicity characteris-
tic—even after neutralization.
The TSD alternatives believed to be most prudent for the waste types and quan-
tities expressed in Table 2 included solvent recovery and recycle, incinera-
tion of solvents and other light crude combustibles (but not contaminated
petroleum sludges), and the ultimate disposal of hazardous wastes in a secure
32

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. ^ncriii. By combining to consider placement of one or more of these facili-
in Alaska, in concert with operational TSD facilities in Seattle,
. ;,;.:r.i::on and Arlington, Oregon, the cost evaluation of the three TSD systems
oe addressed in six different combinations. And last, by considering
. j-.oues of out-of-state hazardous waste transport, either by truck or hydro-
- :_r., RTC/'JRB was able to evaluate another set of three combinations. Thus
alternatives for hazardous waste treatment and disposal were addressed,
- :o project a level of sensitivity to quantity of wastes processed, it was
:.;-nc to consider the consequences to costs and TSD operations feasibility
: :otal statewide waste generation rates versus only that portion of the
. raxe genexared Jjy jaou-jailitary functions. All told, then, 18 cost
i-jacions have been evaluated from which ADEC can select the collection,
sport, treatment, and disposal system for Alaskan hazardous wastes
. indent.
¦aste Solvent Recovery and Recycle
;>:inately 66 drums per month of waste solvents are generated in the State
-astca. This represents approximately 60 percent of the total monthly
.. u'aous waste generation rate. And of these 66 drums, 53 are generated by
-.iiitary facilities.
solvents can be recovered and marketed as a recycled product with most
. -e original solvent properties restored if the waste product sent to a
meal reprocessor has not been seriously contaminated with pollutants that
'•ot readily removed, or it has not been cross-contaminated with a
:jrent solvent type so that the waste solvent mixture contains less than
roxisately 80 percent of the major chemical desired to be recycled.(9)
che large waste generation rates by the military, it is probable that at
is: 3D, and perhaps 90, percent of the total solvent streams could be segre-
gated into separate drums. so as to maximize the certainty for waste splvent
recovery, of the 13 drums per month generated in the commercial sector, per-
10 drums would be relatively pure as to chemical speciation, and will
•acilitate chemical recycle. The 150 gallons per month of waste solvents esti-
mated to originate at the Fairbanks and Anchorage transfer stations would be
packaged in numerous lab packs, each containing several small containers of
'->ne or more solvent waste types. These wastes would not be readily available
.or solvent recovery, but rather would be treated as a solid waste and trans-
ported co a secure land disposal site.
•Solvent recovery is accomplished by redistillation of the petroleum product.
> controlling temperature, pressure, and distillation recovery rates, one can
track the waste solvent stream into one or more recoverable products. Ulti-
mately a small percentage of the original volume of wastes is no longer econo-
mically feasible to recover. The resultant sludge is then containerized and
'haied **n 3 secure	For purposes of this study it has been assumed
>- at 95 percent of the waste solvent stream is recovered, and that five per-
cent of the mass is ultimately lost to disposal.
33

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Solvent recovery can be practiced by either transporting all waste solvents to
an operation solvent recovery facility in Seattle, Washington, or by construc-
ting a like facility in Alaska. Tables 7 and 8 contain cost assumptions used
to generate annual treatment costs for solvent recovery in these two facili-
ties. Excluding the costs to collect and transport the wastes, the estimated
annual cost to reprocess waste solvents in Seattle is $41,000 per year for all
wastes, and $8,080 per year for the non-military waste generators. To locate,
construct, and operate a comparable facility in the Anchorage/Kenai area would
result in annual costs of $158,200 and $57,900, respectively. These much
larger Alaskan costs are due primarily to capital recovery and operating
labor. However, one must recognize that transportation costs will t»e much
less if solvent recovery is done in Alaska, and second, that xhe recovered
solvent is now in Alaska and not in Seattle. Thus any realized resale value
will not be subject to a large transportation cost prior to resale to the
Alaskan industrial community.
A solvent recovery operation in Alaska would involve much more planning than
would be needed to ship all of Alaska's solvents to Seattle. The recovery
facility would have to obtain a RCRA storage and waste treatment permit, and
would need to be located In an area which is sufficiently dose to Alaska's
generators but not too close to area residents. The operator of the facility
would have to ensure a safe disposal method for all still bottom wastes
produced by the facility. This would probably result in the shipment of about
40 drums/year of still bottoms to Arlington, Oregon. The potential for
adverse environmental or health effects from such a facility would be low
assuming a safe and efficient operation.
Given these constraints, preliminary siting of the solvent recovery unit would
favor a location on the north Kenai Peninsula, or in the outlying areas of
Fairbanks or Anchorage. Only one acre of property would be needed to install
and operate all of the necessary equipment, including a storage area for the
drums. The recommended solvent recovery unit (Finish Engineering, Model
L5-15, or its equivalent) is based on the low acceptance rates of 66 drums/
month; or 13 drums/month without Alaska military wastes. As listed in
Table 8, these units cost $4,000 apiece and are capable of recovering 15
gallons of solvent per hour. Table 8 also shows how all of the construction
and operating costs for the facility were averaged to produce an annualized
cost of solvent recovery in Alaska over a 20 year period. To develop these
costs, it was assumed that labor, power and other costs in Alaska are 1.6
times the national average; construction costs in the Fairbanks area are 1.6
times the national average; and that construction costs in Anchorage are 1.44
times the national average. It was also assumed that little or no resale of
recovered solvents could be accomplished in Alaska because there are few
Alaskan industries that would cost-effectively use these recovered materials.
Once pure solvents become contaminated with other solvents, they become very
limited in the uses that can be applied to them. The State could use the
recovered solvents, however, by burning them in State-owned boilers after
mixing with fuel oil.
On a cost-per-drum basis, Seattle solvent reprocessing costs are about $52 per
drum, regardless of military waste contribution levels to the state total.
However, Alaskan solvent recovery costs jump from about $200 per drum to $370
34

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Table 7 - SEATTLE SOLVENT RECOVERY
Assume 66 drums per month of solvents can be reclaimed. Reprocessing rates
vary from $0.80 to $1.00 per gallon. A resultant sludge -volume of five percent
of the original waste solvent volume is containerized and transported to
Arlington, Oregon, at a cost of $45.00 per drum of sludge.

Total
No

State
Military

Wastes
Wastes
Average Annual Volume Waste Solvents
43,560 gal
8,580 gal
Costs to Reprocess @ 90c/Gallon
$39,204
$7,722
57. Sludge Generation Rate, 55 gal/drum
40 drums
8 drums
Costs for Sludge Disposal
$ 1,800
$ 360
Total Annual Costs for Solvent Recovery
$41,000
$8,080
Total Annual Cost/drum (no resale)
$52
$52
(792 drums/year)
Note: If processing company were given resale rights to solvents, and market
conditions were favorable to the reprocessing of the spent solvents, ADEC may
be relieved of any reprocessing costs. There remains the possibility that
the State of Alaska may have to incur costs to transport solvents to Seattle.
35

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Table 8 - ALASKAN SOLVENT RECOVERY
Full System:
66 drums/month = 3,630 gal/mo
Unit Size » 15 gal/8hr, therefore 242 8hr batch processes
per month = 300 gal/mo/shift
Since 66 drums is maximum, purchase 10 units (8 ±n service,
2 in cleanup or standby)
Assume 20 years:
Capital Cost: 10 distillation units @ $4,000
(5 year life); 40 units ¦
Building * 2,400 sq ft
Materials * 36,000
Construction ¦ 32,000
Miscellaneous * 2,000
Truck, Equipment, etc.
Land (1 acre), Property
Development, Fencing
Total
State
Wastes
$160,000
70,000
30,000
30,000
$290,000
No
Military
Wastes
$32,000 (8 units)
50,000
20,000
30,000
$132,000
20-Year Annualized Costs:
Capital Recovery (20 yr @ 12%; CRF - 0.1308)	$ 37,900
Operations: Labor (1.5 MY @ $41,600)	62,400
Supervisory Labor (0.15 x Labor)	9,400
Overhead & Fringe (0.40 x Tot Labor) 28,700
Building Maintenance (4% Capital)	2,800
Equipment Maintenance (6% Capital)	2,600
Utilities	5,000
General and Administration		800
Solvent Recovery Total Annual Costs	$149,600
5% Sludge Disposal Costs, 40 drums/yr to	8,640
Arlington, Oregon
Combined Total Annual Cost	$158,240
Net Solvent Resale @ $1/gallon	(41,300)
Net Total Annual Cost	$116,940
Total Annual Cost/drum (no resale)	$200
$ 17,300
20,800 (.5 MY)
3,100
9,600
2,000
1,700
1,500
200
$ 56,200
1,700
$ 57,900
(8,100)
$ 49,800
$371
36

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per drum should the U.S. Government (DPDO) not participate in the program.
This price sensitivity to volume of waste materials suggests a higher amount
of risk is associated with selecting an Alaskan solvent recovery scenario than
the risk (or relative absence thereof) associated with transporting waste sol-
vents to Seattle. In fact, there is a downward bias in the projected Seattle
solvent recovery costs should the chemical reprocessing company waive the
reprocessing costs for the resale rights of the recovered solvents.
4.2	Waste Solvent Incineration
A third solvent TSD option analyzed involves incineration of waste solvents
for total destruction purposes with no attendent heat recovery or other side
stream use. An incinerator facility in Alaska would require about the same
amount of planning as a solvent recovery unit in Alaska. The incinerator
would require a RCRA storage and disposal permit, and would again be located
on the Kenai Peninsula or in the outlying areas of Anchorage or Fairbanks. As
with an Alaska solvent recovery unit, only one acre of land would be required
to accomodate an incinerator of appropriate size and capacity. The Incinera-
tor unit, however, would cost more than twice as much as the solvent recovery
units, not including the added costs for occasional fuel-assisted operation.
Table 9 gives the itemized annual costs of operating an incinerator in Alaska
assuming a 20 year recovery period for capital expenditures. After adding the
increase costs of intrastate waste solvent transport (Appendix C), the total
annual costs of incinerating solvents in Alaska are $268,640 for all solvents
and $120,015 for only those solvents that are generated by non-military
sources in Alaska. On a unit cost basis, the cost per drum for incineration
alone ranges froms $320 to $758 for total waste disposal. These costs are
almost an order-of-magnitude greater than solvent recovery costs as can be
obtained in Seattle, and are approximately double the costs projected for
waste solvent resource recovery in Alaska.
4.3	Hazardous Waste Disposal In a Secure Landfill
The considerations and costs for disposal of petroleum sludges, acids and
caustic wastes, and other miscellaneous solid wastes involved secure landfill
disposal at an operational facility in Arlington, Oregon, or the design and
construction of a comparable facility in the State of Alaska.
4.3.1 Secure Landfill Disposal in Oregon - This option does not require any
new facility siting or construction considerations other than those associated
with in-state waste collection, storage, and transportation already discussed
in Section 3 of this report. To implement this option, the State would have
only to hire a private contractor to collect and haul all of Alaska's wastes
from the Alaska generator locations to Seattle and Arlington.
Costs for hazardous waste treatment and disposal at the Oregon-owned, and
private contractor operated, disposal facility currently average $26 per
drum. (10) Additional costs will be incurred in the collection, short term
storage, and transportation of wastes to the disposal site.
37

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Table 9 - ALASKA SOLVENT INCINERATION
Caoital Costs
Total	No
State	Military
Wastes	Wastes
Land Purchase (1 Acre, Property	$ 30,000	$ 30,000
Development, Fencing)
Building, 2400 sq ft	70,000	50,000
Incinerator, Bulk Storage, Supplemental	250,000	40,000
Fuel Storage
Truck, Equipment, etc.	30,000	20^000
$380,000	$140,000
20-Year Annualized Costs
Capital Cost Recovery (20 yrs @ 12%;	$ 49,700	$ 18,300
CRF = 0.1308)
Labor (2 MY @ $41,600)	83,700	41,600
Supervisory Labor (0.15 x Labor)	12,500	6,300
Overhead & Fringe (0.40 x Total Labor)	38,300	19,100
Supplemental Fuels for Preheat, etc.	20,000	10,000
Building Maintenance (4% Capital)	15,200	5,600
Equipment Maintenance (6% Capital)	22,800	8,400
Utilities	3,000	1,000
General Administration	1,000	500
Air Monitoring (Quarterly)	7,500	7,500
Incineration Total Annual Cost	$253,200	$118,300
TOTAL ANNUAL COST/DRUM FOR INCINERATION	$320	$758
38

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The total costs for disposal in Oregon of Alaska's acids, caustics, petroleum
sludges, and miscellaneous solids was calculated by using rates for tr-aicking
wastes through Seattle to Oregon, and adding the average costs of disposal
($26/drum) at the Arlington, Oregon site. These calculations (see Appendix C)
resulted in estimates of $112,826 and $67,664 per year for disposal of sll of
Alaska's hazardous waste and Alaska's non-military wastes, respectively.
4.3.2 Secure Landfill Disposal in Alaska - The development of a landfill in
Alaska would require a RCRA land disposal permit—the regulations for -wnich
are not expected to tie -finalised "for over a year. An Alaska landfill -would
also require a minimum acquisition and purchase of nine acres of land, pJLus an
additional 48 acres to be purchased or leased by the State as a minimum buffer
zone of 400 feet on each side of the site. For the purposes of this srudy,
siting was assumed to take place on the Kenai Peninsula. Though seisnriioally
active, the peninsula has surface geology suitable for secured sanitary land-
fills . It is also the area most frequently mentioned as the locatiara for
large petrochemical and related industrial development. The cost and time
involved in the actual siting process has not been included in this analysis
because of the extreme variability in hazardous waste landfill siting pro-
jects. The overall risk to human health and to the environment would be ®rach
higher for a landfill than for any of the other types of waste management
facilities evaluated in this report. The increased risk comes from the con-
stant potential for leachate migration and subsequent groundwater contamina-
tion in the area surrounding the facility.
Table 10 presents the annual itemized costs of constructing and operating a
landfill in Alaska. The costs of accepting all of the State's generated
wastes has been assumed equal to the cost of accepting only non-military
wastes at the landfill. This is because both sites have been costed according
to an acceptance rate of 600 drums per year—a decision based on the premise
that there is little difference between the cost of constructing a 576 drum/
year landfill total statewide wastes and a 336 drum/year landfill (excluding
military wastes). The cost estimation in Table 10 were based on a methodology
prepared by TRW, Inc. in November, 1980, to provide cost estimates for land-
filling and other disposal schemes for the EPA Office of Solid Waste.(H)
TRW's methodology incorporated unit cell construction costs updated from "Cost
Compliance with Hazardous Waste Management Regulations".(12) RCRA record
keeping costs were taken directly from the Preliminary Final Economic Impact
Analysis for Subtitle C of the Resource Conservation Recovery Act of 1976
(EPA, 1980). TRW unit costs were updated by assuming a 20% increase in
materials and labor costs since the TRW costs were prepared. Also, since the
cost of labor in Alaska is 1.6 times the national average, and costs for
materials in Anchorage are approximately 1.44 times the national average,
these multipliers were used to convert average costs to approximate costs in
Alaska. Equipment costs were scaled down by applying the Perry and Shilton
six-tenths factor where appropriate.(13) Means 1982 Building Construction
Cost Data was used to estimate other costs associated with site prepara-
tion. (1^)
Several physical assumptions were made for the purposes of estimating
landfilling costs. They are listed below:
39

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Table 10
ALASKAN SOLID WASTE DI-SPOSAL
(Assume 600 drums/year capability)
Capital Cost
Land Purchase (9 Acres @ S15,000)
48 Acre Perimeter Buffer Zone
<400 ft each side)
fenring ($10/£z x 2,M00 ft)
Office, Laboratory & Facilities
Buildings 6 Structures $160,000
Lab Equip 6 Supplies $ AO,000
Maintenance Building & Facilities
Equipment
o 9 Ac
400*
600'
II. Annua 2 Costa
Capital Cost Recovery (20 yr @ 12*)
48 Acre Buffer Zone Leasing (520/acre)
Operations
Annual Cell Construction & Closure
Labor (2 MY @ $41,600)
Supervisory Labor (0.15 x Labor)
Overhead & Fringe (0.40)
Building Maintenance (4Z Capital)
Equipment Maintenance (6Z Capital)
Taxes and Insurance (42 Capital)
Leachate Collection & Treatment
Hater i Air Monitoring (Quarterly)
Utilities
Fuel for Vehicles
RCRA Recordkeeping, Closure, etc.
($16/metrie ton)
III. Acid/Caustic Waste Shipment, Treatment and
Disposal at Arlington, Oregon
Shipment from Alaska to Seattle, concurrent
with sludges: 20 drums/mo ¦ 3.9 truckloads
per year, 31,000 lbs/truck. Use shipping
rate of $39.79/100 lb - $12,335/truck,
$48,100/year
Shipment from Seattle to Arlington, Oregon
$800/truck - $3,200
Arlington Treatment and Disposal
$26/drum - $6,240/year
Total Annual Cost "
Total
State
Wastes
$135,000
Annual Lease
24,000
200,000
100,000
130.000
$589,000
$ 77,000
1,000
14,000
83,200
12,500
38,300
5,000
7,800
23,600
5,000
15,000
2,000
8,000
4.000
$296,400
No
Miltary
Wastes
S135.000
Annual Lease
24,000
200,000
100,000
130,000
$589,000
$ 77,000
1,000
14,000
83,200
12,500
38,300
5,000
7,800
23,600
5,000
15,000
2,000
8,000
4,000
$296,400
57.540
$353,940
11.500
$307,900
Solid Waste Disposal Cost/drum " $614 for 576 drums/year
- $916 for present 336 drums/year
40

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•	One cell per year is constructed, filled with waste, and
completed.
•	.The total life of the landfill is twenty years.
« Each cell is 8 ft deep and holds one year's amount of drums
stacked two drums high. The bottom of each cell is sealed with
a hypalon elastic sheet and a bentonite layer. Each cell is
surrounded by a 3:1 slope earthen dike and sealed with a layer
xxf day a^H hpni-nn-i rp_ -F.?rli /-oil has zuo JysisiBters aad a -drain
pipe and a concrete sump for leachate monitoring and collection,
respectively. Each completed cell is covered with a 2 ft layer
of compacted clay, and graded.
•	Three wells are constructed to monitor groundwater at the land-
fill. Monitoring is carried out four times a year for comprehen-
sive analysis; twice for minimum analyses.
•	Major equipment costs consist of the purchase of a track mounted
backhoe/loader, drum handling equipment, safety equipment, and
security and snow fencing.
•	Two buildings are required; an office/laboratory for adminstra-
tive work, sampling and analysis; and a warehouse for 3 month
storage of contaminated waste during periods of inclement
weather.
These design assumptions are based on professional judgement and on the type
of facility that would be expected to comply with the forthcoming EPA land
disposal regulations. Although the final EPA landfill regulations cannot be
unerringly predicted, they will undoubtably contain provisions which vill
require the state of the art performance achievable through the above design
assumptions.
Total annual costs approximate $296,400 for waste volumes generated statewide,
with or without the military solid fraction contributions. Based on projec-
ted waste generation rates, the disposal cost per drum are estimated to range
from $614 to $916. These costs account for transportation, treatment, and
disposal of acids and caustics at the Arlington, Oregon secure landfill.
4.4 Hydro-Train Transport of Hazardous Wastes
Costs for in-state trucking and rail transport of waste between municipalities
has been addressed in Section 3.3. Trucking of wastes to Seattle or Oregon
must go via the Alcan Highway, a trip involving seven to ten days transit
time. Freight tariffs are identified in Appendix C, and were used to
determine the costs to truck hazardous wastes to both Seattle, and Arlington,
Oregon.
A comparative cost analysis was made of railcar and barge transport of wastes
from Fairbanks and Anchorage direct to Seattle. Table 11 estimates a total
shipping cost of $75,000 per year to hydro-train transport all wastes to
41

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Table 11
•COSTS TO TRANSPORT WASTES BY HYDRO-RAIL FROM FAIRBANKS/ANCHORAGE TO SEATTLE, WA
FOR SOLVENT RECOVERY AND ARLINGTON, OR FOR SECURE LANDFILL. DISPOSAL
Total State
Uagcet
No Military
Waste*
I. HTDRO-TRAIN SERVICE. FAIRBANKS TO SEATTLE
50-ft boxcar, 100 drum capacity; 552 drums/year
Boxcar loading fee: $500
Full car new weight, total state wait* mix
" dr™ e to " 33-400 lb* • S7*84 ewt • S4-19°'«r
($4,190 * $500) x 5.5 carload* per year -
Full car net weight, tto military viitti
45 drum* 9 500 lbs.
55 drua« 9 700 lbi'
• 61,000 lbs f $7.31 cvt - $4,460/cer
XI.
($4,660 $500) x 1.3 carloads par year -
HTDRO-TRAIN SERVICE, ANCHORAGE TO SEATTLE
50-ft boxcar, 100 drun capacity; 816 druae/year
Tloxrjr loading f««: $500
Full car nat weight, total state waate mix
71 drm* 9 500 lba.
} - 55.800 lbs t $5.88 cvt - S3.2S0/car
29 druB* 9 700 lbs
($3,280 + $500) x 8.2 carloads per year *
Full car nat weight, no military vaatas
59 M • WO " "'a00 lb' 1 ,5-36 CWt "
($3,312 * $500) x 2.4 carloads pet year "
III. UKLOAD COX CAR, LOAD WASTES TO DEDICATED TELC^S It.' SEATTLE
A. Total Statewide Wastes (schedule slaultaneoua arrival of
two rallcars six tl»es per year)
Unload to truek trailer tranafsr, $650 per carload
14 carloads x $650 •
Seattle solvent In-city transport, $150/truck
2U trailer trips x $150 •
Arlington, OR haxardoua waste transport, $800/craller
8 trips x $800
8. Ho Military Uastes In State Total (schedule simultaneous
arrival of two rallcars once each year)
Onload co truck trailer transfer, $650 per carload
5 carloads x $650 "
Seattle solvent in-city tranaport, $130/truck
5 trailer trips x $150 ¦
Arlington, OR haxardoua waete tranaport, $800/traller
5 trailer trips x $800 ¦
ESTIMATED TOTAL ANNUAL TRANSPORT COSTS)
IV. SEATTLE. VA SOLVENT RECOVEW (Sea Table 7)
V. ARLINGTON. OR SECURE LANDFILL DISPOSAL (• $26/dm»)
TOTAL ANNUAL TRANSPORT, TREATMENT AND DISPOSAL COSTS
ANNUALIZES COST PER DRUM
SOLVENT RECOVERY RESALE. DISCOUNT IN TREATMENT COSTS
NET ANNUAL TSD COST
AVERAGE NET COST PER DRUM
$25,800
31,000
9.100
3.000
6,400
$75,300
41,000
$131,276
96
(sti.ooe)
$90,276
166
$ 6,450
9,150
3.230
7S0
4.000
S23.6U0
8,080
8.424
$40,104
84
($8.080)
$32,024
$67
42

-------
Seattle and Arlington. Costs to treat solvents and dispose of solids adds an
additional $55,000 to this figure.
Assumptions used in the railcar analysis can be subjected to additional
scrutiny to reduce even more the above costs. Whereas the railcars contain
mixed wastes types which are offloaded onto dedicated trucks in Seattle for
delivery to the TSD facilities, a refinement of the evaluation should investi-
gate the possibility of dedicated rail cars from the point of origin to the
TSD destination. Both the Seattle solvent recovery facility, and the
Arlington secure landfill have rail sidings on or adjacent to the TSD sir p.
By fully loading a railcar with a given waste type, and double stacking the
drums, the costs associated with off-loading onto trucks can be eliminated and
the hydro-train tariff rate lowered. It may be possible to trim an additional
$10,000 to $15,000 per year from the total annual cost estimate for total
state hazardous waste disposal.
4.5 Sugary Costs of TSD Alternatives
A summary of treatment and disposal costs for the predetermined quantities and
types of wastes in Alaska is summarized in Figure 4. The line schematic
differentiates between TSD costs for all state waste generated (the solid
lines, and 114 drums/month) and those wastes generated by non-military indus-
trial activities (the dashed lines, 39 drums/month). In addition, the figure
differentiates annual operating and maintenance costs associated with:
•	Hydro-train transport of solid wastes and sludges to Arlington,
Oregon
•	Truck transport of solid wastes and sludges to Arlington, Oregon
•	Construction and operation of an Alaskan secure landfill site
•	Solvent recovery and reclamation in Seattle
•	Solvent recovery and reclamation in Alaska
•	Solvent incineration in Alaska
The latter three solvent treatment and disposal alternatives were examined
independently for each of the three alternatives listed above for disposition
of the solid waste and sludge fractions.
Total annual costs for each of the nine TSD alternatives are summarized at the
right, with cost-per-drum figures adjacent to the annual total.
The table infers that rail car and barge transportation of wastes will help to
control total annual disposal costs, and that the two most preferred scenarios
would be to export all sludges and solids to Arlington, Oregon and either
export solvents to Seattle for reprocessing, or reprocess solvents in Alaska.
To help clarify these conclusions, Tables 12 and 13 examine more fully total
costs associated with collection, storage, transportation, and treatment and
43

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Figure 4
SUMMARY OF ADEC HAZARDOUS WASTE
TSD ALTERNATIVES AND ANNUALIZED TOTAL COSTS
Total
Hazardous Wastes
66 Slv
20 PS
20 AC
8 Sdg
State Hastas Only
(Ho Milltary Wastes)
13 Slv
IB PS
4	AC
5	Sdg
Hydro-
Train
Transport
$43,280
Oregon
Solid
Wastes
Disposal
Chempro Solvent Recovery - Seattle
	>,
66 Slv
SI3.734 .
13 Slv'
Alaskan Solvent Recovery
	$156.240
>-
20 AC
20 PS
8 Sdg
-66 Slv
557,900


13 Slv

$26,370



18 PS
5 Sdg
4 AC
Alaskan Solvent
Incineration
S253.200
-W-
66 Slv
$118,300.
13 Slv
Chempro Solvent Recovery - Seattle
	SI98,570 ^
Truck
Transport
$112,826
Oregon
Solid
Wastes
Disposal
20 AC
20 PS
8 Sdg
$67,660
18 PS
5 Sdg
4 AC
66 Slv
$39,120
13 Slv
Alaskan Solvent Recovery
	$158.240 ^
66 Slv
$57,900
13 Slv
Alaskan Solvent Incineration
	$253.200 ^
66 Slv
$118,300
13 Slv
Chempro Solvent Recovery - Seattle
	$198.570 w
$353,940
Alaskan
Solid
Wastes
Disposal
(Acids Co 20 PS
Arlington 20 AC
Oregon) 8 Sdg
$307,900
18 PS
5 Sdg
4 AC
66 Slv
Alaskan Solvent Recovery
	$158.240 >|
66 Slv
$57,900
13 Slv
Alaskan Solvent Incineration
	S253.200 ^
Slv - Solvents
PS - Petroleum Sludges
AC - Acids/Caustics
Sdg - Sludges, Solids
66 Slv
5118,300 >
13 Slv
Total
Annual
Cost
$131,276
40,104
201,520
84,270
296,480
144,670
311,400
106,780
271,066
125,560
366,026
185,960
552,510
347,020
512,180
365,800
607,140
426,200
Total
Drums/
Year
1,368
480
1.368
480
1,368
480
1,366
480
1,368
480
1,368
480
$/Drmn
96
84
147
176
217
301
227
222
198
262
1,368
480
1,368
4S0
268
387
404
723
374
762
1,368
480
444
888
44

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Table 12 - DETAILED EXAMINATION OF COSTS FOR COLLECTION, STORACE, AN!) TOTAL
EXPORT BY HYDRO-TRAIN OF HAZARDOUS WASTES COMPARED WITH IN-STATE SOLVENT RECOVERY

Alternative 1
Total Export of
Hazardous Wastes
Alternative 2
Alaskan Solvent Recovery,
Export of Hazardous Wastes

Cost Element
la
All State Wastes
lb
No Military Wastes
2a
All State Wastes
2b
No Military Wastes
Notes
Collection and Storage
92,845
39,950
92,845
39,950
Equivalent among all
alternatives
Intra-State Transport
NA
NA
15,440
1,715
Intra-state costs in-
curred to ship solvents
to Anchorage-Kenai
area. $7. 15/100 cwt
Inter-State Transport
75,300
23,600
28,304
17,946
Export to Seattle and
Oregon from both Fair-
banks & Anchorage
regional storage sites
Sludge Solids, Petro-
leum Sludge, Acids/
Caustics Treatment &
Disposal
14,976
8,424
14,976
8,424
All treatment and dis-
posal at Arlington,
Oregon secure landfill
Solvent Recovery Costs
41,000
8,080
158,240
57,900

Total Annual TSD Cost
Average Cost/Drum
224,121
164
80,054
167
294,365
215
124,220
259

Solvent Recovery Resale
in Alaska
NA
NA
41,300
8,100
Assume $l/gallon
resale value
Solvent Recovery Resale
Discount in Transport
41,000
8,080
NA
NA
Assume ADEC not
liable for treatment
cost
Net Annual TSD Cost
Average Cost/Drum
183,121
134
71,974
150
253,065
185
116,120
242


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Table 13 - DETAILED EXAMINATION OF COSTS FOR COLLECTION, STORAGE, AND TOTAL
EXPORT BY TRUCK OF HAZARDOUS WASTES COMPARED WITH IN-STATE SOLVENT RfcCOVERY

Alternative 4
Total Export of
Hazardous Wastes
Alternative 5
Alaskan Solvent Recovery,
Export of Hazardous Wastes

Cost Element
4a
All State Wastes
4b
No Military Wastes
5a
All State Wastes
5b
No Military Wastes
Notes
Collection and Storage
92,845
39,950
92,845
39,950
Equivalent among all
alternatlves
Intra-State Transport
NA
NA
15,440
1,715
Intra-state costs in-
curred to ship solvents
to Anchorage-Kenai
area.. $7.1 5/ 100 wt
Inter-State Transport
255,420
90,276
97,850
59,240
Export to Seattle and
Oregon from both Fair-
banks & Anchorage
regional storage sites
Sludge Solids, Petro-
leum Sludge, Acids/
Caustics Treatment &
Disposal
14,980
8,420
14,980
8,420
All treatment and dis-
posal at Arlington,
Oregon secure landfill
Solvent Recovery Costs
41,000
8,080
158,240
57,900

Total Annual TSD Cost
Average Cost/Drum
404,245°
295
146,726^
306
379,355
277
167,225
348

Solvent Recovery Resale
In Alaska
NA
NA
41,300
8,100
Assume $l/gallon
resale value
Solvent Recovery Resale
Discount in Transport
41,000
8,080
NA
NA
Assume ADF.C not
.liable for treatment
cost
Net Annual TSD Cost
Average Cost/Drum
363,245°
265
138,646d
289
338,055
247
159,125
332

(a)	Total cost would be reduced to $346,825 (253/drum)If solvent shipping rates are same as solids fractions
(b)	Total cost would be reduced to $135,360 (282/drum)1f solvent shipping rates are same as solids fractions
(c)	Total cost would be reduced to $305,825 (224/dtum)if solvent slilppfhg rates are same as guilds fractions
						— 	 	 		.—	. 	: 	 		^ —		

-------
disposal of state hazardous wastes. It should be noted these costs do not
include the costs of the containers nor expense to initiate manifests. These
costs total approximate $35 per drum, and would be borne by the hazardous
waste generator.
Table 12 examines the costs of total export of wastes against in-state solvent
recovery. In both instances hydro-train is the primary transport carrier.
Given costs associated with collection and storage (Section 3.2.2), transporta-
tion, and TSD costs, a total annual cost savings of approximately $70,000 may
be realized by choosing to export hazardous wastes rather than attempting to
recover solvents in-state. There is little cost sensitivity on out-of-state
costs per drum should the military elect not to participate in an ADEC
program. There is a negative sensitivity, or about a 20 percent increase in
per drum cost, should the military desire not to participate in an Alaskan
solvent reprocessing program.
Table 13 examines similar costs for the same TSD alternatives, but where
highway truck trailer is the primary transportation mode. Both annual costs
and price per drum are significantly higher. Greater transportation costs
associated with trucking do not offset the high capital and operating costs of
an Alaskan solvent recovery facility. Estimating error may be sufficient
reason to judge the costs per drum equivalent for alternatives 4a and 5a.
However, it should be observed in the footnotes to the table that a flat rate
shipping tariff can lower costs in 4a to well below costs to treat solvents in
Alaska. Additionally, there is a greater cost sensitivity associated with
in-state solvent recovery compared to Seattle reprocessing should the military
not participate in the ADEC program.
47

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5.0 CONCLUSIONS AND RECOMMENDATIONS
A review of the work study findings, interpretations, and analyses ailows us
to summarize overall conclusions and make several specific recommendations for
further action. These include:
Hazardous Wastes Generation Rates
Conclusions:
•	Approximately 350 to 400 tons per year of hazardous wastes
subject to RCRA or proposed state regulations are generated in
the State of Alaska.
•	Additional unknown quantities of waste oils and lubricants are
incinerated, or disposed of in landfills and road oiling acti-
vities .
•	Hazardous wastes are generated at approximately 114 drums per
month. Approximately 58 percent of the wastes are solvents; 18
percent petroleum sludges; 18 percent spent acids and caustics;
and 6 percent pesticides and other solid hazardous wastes.
•	There are an estimated 25 to 40 industrial and commercial facili-
ties which generate more than 1000 kg of hazardous wastes per
month. Of these, 9 are known to generate at least 1 drum of
wastes per month. Many petroleum development companies inject
wastes into deep disposal wells.
•	U.S. military installations generate approximately 65 percent*of
the hazardous wastes which require proper collection and dispo-
sal.
Recommendations:
•	ADEC needs to institute a comprehensive notification program for
all facilities presumed to generate, treat, or store more than
100 kg of. wastes per month.
•	Field inspections of all known or suspected generators of hazar-
dous wastes should be conducted at least once per year.
•	An annual inventory should be made of waste types, quantities,
and generator or TSD locations. Current disposition of identi-
fied wastes should be identified and tracked.
•	ADEC needs to institute a comprehensive awareness program for
the general public on the state and federal hazardous waste
program to explain how this program affects them.
48

-------
•	Regional offices of ADEC should hire personnel to give technical,
assistance to the general public, small businesses and industry.
Hazardous Waste Collection and Transport
Conclusions:
•	40 percent of statewide waste quantities are located within th&
Tanana Valley, and 60 percent within the Anchorage/North Kenai
Peninsula regions.
•	Military bases have initiated exporting PCB wastes and other
hazardous wastes to DPDO centers for final disposition of"
treatment and disposal.
•	Some large industries are routinely exporting hazardous wastes
to treatment and disposal facilities in the contiguous United
States.
•	Generators of small quantities of hazardous wastes are currently-
disposing of those wastes in local landfills, waste oil burners,
or on-site storage/disposal.
•	No central receiving facilities or transfer stations exist for
hazardous waste management, except for the U.S. Government DPDO
facilities.
•	Railway transport is a viable alternative to highway transport
between Fairbanks and Anchorage.
Recommendations:
•	ADEC must prepare and implement state regulations for the
management of hazardous wastes.
•	Central transfer stations should be coordinated and placed in
all localities where wastes generated in quantities sufficient
to meet state regulated thresholds need to be properly treated
or disposed. At a minimum, one transfer station should be
constructed in both Fairbanks and Anchorage.
•	Central transportation facilities should be coordinated around
the transportation hubs of Anchorage and Fairbanks.
•	Railway transport of wastes from Fairbanks should be considered
in any resultant TSD scenario.
•	Any Alaska TSD facility should be located in the Anchorage/Kenai
area rather than Fairbanks, to respond more favorably to future
industrial (petrochemical) growth, and to provide greater flexi-
bility between in-state and export transportation systems.
49

-------
•	ADEC should evaluate the ownership and operating responsi-
bilities, liabilities, and RCRA permit and other compliance
assurance activities associated with public and private
ownership of regional transfer stations.
•	ADEC should consider the development of a "milk run" transport
system to pickup and transport on a monthly to quarterly basis,
regional hazardous wastes to a TSD facility. An intense public
relations and awareness compaign should encourage all waste
generators to participate in the program. At the end of the
first year, reevaluation should be made of waste types and
quantities and compared to the TSD scenarios contained in this
report.
Hazardous Waste Treatment, Storage, and Disposal
Conclusions:
•	TSD costs are greatly influenced by high costs of transporta-
tion, regardless of the in-state or out-of-state location of the
TSD facility.
•	Hydro-train transport of wastes from Alaska to Seattle provides
the lowest annual cost for hazardous waste movement to Seattle.
•	Transportation cost savings associated with not exporting
solvent wastes are more than offset by high costs of capital
construction and operating expenses associated with in-state
solvent recovery.
•	Current liability Insurance requirements associated with 'oil
spill prevention and response countermeasures has caused many
ocean carriers not to entertain the transport of hazardous
wastes.
•	The relatively small monthly rate of hazardous wastes generation
precludes any Alaskan TSD facility from benefitting from
economies in scale. Uncertainties in the waste types and quanti-
ties suggest an upward bias in per drum treatment or disposal
costs.
Recommendations:
•	ADEC should institute a program to form the basic collection and
transportation system common among all statewide TSD scenarios.
•	All generators of hazardous wastes, including the lay public,
should be informed of and encouraged to utilize local transfer
stations.
50

-------
Drum integrity and safeguards for shipping should be evaluated
before state hazardous waste regulations are finalized.
Industrial and military waste generators should be encouraged to
participate in a scheduled "milk run" pickup of wastes. Trans-
port tariffs are minimized with full load shipments in either
highway or railcar units.
ADEC should consider underwriting costs to construct two
regional transfer stations. Storage facilities should be
constructed and operated in accordance with RCRA and state
hazardous waste regulations.
ADEC should consider underwriting first year transportation
costs associated with total export of state hazardous wastes.
To encourage small generator participation, collection, transpor-
tation, and disposal costs could be waived for the first five
drums. Industries and commercial participants generating more
than 5 drums would be liable for costs to containerize wastes,
prepare manifests, transportation, and ultimate waste treatment
and disposal. ADEC may also wish to exclude cleanup or other
cost liabilities for any spillage, leaks rais-labeling or illegal
waste shipments. U.S. military facilities should finance total
costs per drum to package, transport, treat and dispose.
A multi-task program should be undertaken by ADEC to facilitate
the operation of a statewide hazardous waste collection,
transportation and disposal program (see Figure 5).
51

-------
in
ADEC Activity
Finalize State Hazardous
Waste Regulations
Finalize Conceptual TSD
Program, Present to
Municipal Officials
Conduct Site Evaluations,
Site Preselection
Public Notification, Final
Site Selection
RCRA Part B Permit
Application/Approval
Site Investigations,
Facility Design
Solicitation/Selection of
TSD Operator & Transporter
Contractor Selection,
Bid Award
TSD Facility Construction
and Equipment Supply
Industrial Notification,
Logistics Coordination,
Small Generator Awareness
Facility Operation, Program
Initiation
Scheduled Period of Performance
1982
3rd Quarter
4 th
1983
1st Quarter
2nd
3rd
4tU
1984
1st Quarter
Figure 5 - IMPLEMENTATION SCHEDULE FOR DEVELOPMENT OF ALASKA HAZARDOUS WASTE COLLECTION AND TRANSPORTATION

-------
REFERENCES
1.	Summary of Hazardous" Waste Sources in Alaska, Field Investigations of
Uncontrolled Hazardous Waste Sites, FIT Project EFSR 8011-01ZC2<1D),
prepared for EPA Region X, Ecology and Environment, Inc. (1980).
2.	Alaska Department of Environmental Conservation, Summary and Kecom-
•mermlatitrcis foT Hazardous Waste ContTol Legislation (1981).
3.	Small Quantity Collection and Storage Facilities in Oregon for Hazardous
Wastes, Draft Report for EPA Region X, Resource Technology Corporation,
March 26, 1982.
4.	Personal Communication, G. Chris Stotler, Battelle Columbus Laboratories,
Columbus, Ohio, March 26, 1982.
5.	Personal Communication, L. G. Nieuwenhuis, Western Processors, Inc.,
Kent, Washington, April 19, 1982.
6.	Personal Communication, R. Miller, Lynden Transport Co.,Seattle, Washing-
ton, April 6, 1982.
7.	Personal Communication, E. Sterling, Crowley Maritime Services, Seattle,
Washington, April 20, 1982.
8.	EPA, Department of Transportation Joint Proposal on Uniform Manifest Form
for Transporting Hazardous Wastes, Notice of Proposed Rulemaking, 47 FR
9336, March 4, 1982.
9.	Personal Communication, R. West, Chemical Processors, Inc., Seattle,
Washington, April 20, 1982.
10.	Personal Communication, P. Taylor, Chem Security Systems, Inc., Kirkland,
Washington, April 6, 1982.
11.	Yu, K.Y., Letter to Ms. Penelope Hansen, Office of Solid Waste, U.S. EPA,
November 18, 1980, Environmental Engineering Division, Energy Systems
Group of TRW, Inc., Redondo Beach, California.
12.	Battelle Laboratories, Cost Compliance with Hazardous Waste Management
Regulations, Submitted to U.S. EPA Office of Solid Waste, Contract
#68-01-4360, May, 1978.
13.	Perry, R.H., and C.H. Shilton, Chemical Engineers Handbook, 5th Edition,
McGraw-Hill Book Company, New York, 1973.
14.	Godfrey, R.S., Editor-in-Chief, Building Construction Cost Data: 1982,
Robert Means Company, Inc., Kingston, Massachusetts, 1981.
53

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APPENDIX A
Alaska Hazardous Waste Generator Inventory, Partial Listing, March 1982

-------
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PIAKT
	?<>10 HOtiTM PDIF PtFT'T,'v	J* lf.M?,£f'J]*"			 	 f»ro Tii_rr| i	^	q	
•"170 IO IMT* "•*""• - -	- "«roin offr 0	C
1311 smOP #K Pfc T'Ot Fl"* ri«» ppimnrf HA*	e i M r !'(*( _ _?i&_	AH	
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7P0 HAtlCCl MP VICE 5			CP PH'OHPf 9»Y	HTTil V»T|i »J f		"PHUMff n»y	_f	jj	
1300 PRUDHCC BAY Tit eTFI H Hit *VlAtAPIF	pc nonf F «#v ?e>;	t;tj
	Jljtil	ST El i		«P< 111					ynrfML	m	L	
*170 PiTpriti* siCt* gin'MI PFiivfPv	r>i it. o	t.
	$711	N#Ul_Sl*ligN_AfL«K »!L_	»V/!l»Ptr		 _ 	 _ M'CHVI	'TS iliii	
?b 11 AlAJI-A tU"*tR ~ Pl'l p SA.4PUI r»ifc in	7W	?*pl
3^90 TPl-CHIP TNC	J*P«f_!«£	!L*r-W£Y	W.	L	
u» fibO rtia fafh *mo r.«*hoFM en* »n	F '"iTe" TMf	H1L f ? ?WAkSnM PTV'P P«	rTfpj fur /tl	M!f
4900 5TEBLIHG SPECIAL VMTf	1,*, hi H "p rrif|(^r. mwy nn fw»f.snn HtV	«IfPJ I»»•"				Ihi	iili	
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*
-------
APPENDIX 3
Conceptual Structural Design and Equipment for Transfer Station Storage 
-------
THE BASIC COMPONENTS AND ACCESSORIES C
All of the Widespan structural systems use the same
engineering standards and conform to those of the American
Institute of Steel Construction and the American Iron and
Steel Institute. And, registered engineers and computer
calculations coupled with carefully controlled production
methods assure uniformity and predictable strength and
performance. Widespan systems may be designed and
fabricated to conform to specific national, slate or local codes.

EAVE STRUT
SAG ANGLE
(OPTIONAL)
GABLE ANGLE
ENDWALL ROOF BEAM
BASE ANGLE
ENDWALL GIRT
ENDWALL POST
CORNER POST
ROOF BEAM
PURLIN
FLANGE BRACE
RIGID FRAME ENDWALL
(FOR EXPANSION)
CANOPY BEAM
BRACE ROD
OVERHANG BEAM
COLUMN
SIDEWALL GIRT

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k WIDE5PAN BUILDING
FIELD INSULATION FOR BUTLERIBII—Options
range Irom lour mil vinyl lacings and
fiberglass blanket lo exclusive Butler 25.
RIDGE PANELS —Ridge panels are precision
formed in one piece lo meet and match roof
panels on both sides.
in
oo
FASTENERS—Options range Irom heavy duly
Scrubotts and sheet metal screws to exclusive
Butler Lock-Rivets—the most positive
connections available in the industry today—
complete with building-color-matching
cover caps.
MET At AND COLOR FINISHES—A variety
ol materials is available Standard color
Imtsh is the superior Butler-Tone'
•nth proven performance Other finishes are
available Compare Butler linishes and
warranties with those ol other companies
before you |udge all color finishes equal
VENTILATORS—Low-profile. continuous
rldge-type, or gravity lype. are available
SKYLIGHTS - Lite'Panl". a translucent plastic
panel, lits neally into Butler rool systems and
oilers natural lighting wilh controlled solar
glare and heat
CANOPIES—Canopies are available lor
handsome and functional rool promotions
DOORS AND WINDOWS-Custom quality
aluminum or laclory-linished steel doors and
windows are available as complete units
Windows and doors are available in a variety
ol sizes and types
WALL SYSTEMS -Options range Irom
handsome, single skin, galvanised steel panels
to factory insulated, interlocking longue-
and groove panels to large expanses ol
boldly trimmed glass or even color fit) and
distinctive rock or stone aggtegate panels
POOF SYSTEMS — Options range Irom
"Induilry Slandnid" t/npunchitl panel# 10
exclusive factory cut. pre-pUilctled. Single Skin
pdliels to lactory-insulated panels Id
•he lines! rool protection available in the
Industry today — the Butler MR-24 double
lock, standing seam roof syslern

-------
WIDESPAM
Dimensional
Roof Slope: in 12"
Bav Lengths: 20". 25'
STANDARD WIOTHS ANO EAVE HEIGHTS
BUILDING
width
NOMINAL EAVE HEIGHT
8
10
12
10'
X
X

15'

X
X
20'

X
X
rigidframel
Roof Slope: 4" in 12"
Bay Lengths: 20'. 25'. 30'
STANDARD WIDTHS ANO EAVE HEIGHTS
BUILDING
width
NOMINAL EAVE HEIGHT
14
16
20'
40
X
X

50'
X
X

60
X
X

80

X

120

X
X
WBE*
Roof Slope: v," in 12"
Bay Lengths 20'. 25'. 30'
STANDARD WIDTHS ANO EAVE HEIGHTS
BUILDING
WIDTH
NOMINAL EAVE HEIGHT
12
14
16
40
X
X
X
50
X
X
X
•0
X
X
X
WIDTH EXTENSION'
Roof Slope: '/>" in 12"
Bay Lengths: 2025'. 30'
standard wm« and eave heights
BUILDING
WIDTH
NOMINAL EAVE HEIGHT
IV
13'
15' I 19'
30'
X
X
X X
MODULAR RIGID:FRAME
Roof Slope: '/r in 12"
Bay Lengths: 20'. 25', 30'
Frame Modules: 40'. 50'. 60'. 75'
STANDARD WIDTHS AND EAVE HEIGHTS
BUILDING
NOMINAL
EAVE HEIGHT
NUMBER OF MOOULES
WIOTH
14'
16'
20'
24-
40' MODULE
50' MODULE
80' MODULE
75' MODULE
80
X
X
X
X
2



100'
X
X
X
X

2


120'
X
X
X
X
3

2

150
X
X
X
X

3

2
160
X
X
X
X
4



180'
X
X
X
X


3

200
X
X
X
X
5
4


225
X
X
X
X



3
240'
X
X
X
X
6

4

250'
X
X
X
X

5


300'
X
X
X
X

6
s
• 4
SBF*
> -
LQWRIGIETFRAME
Roof Slope:'/»" in 12"
Bay Lengths: 20'. 25'. 30'
STANDARD WIDTHS AND EAVE HEIGHTS
BUILDING
WIOTH
NOMINAL EAVE HEIGHT
12'
14'
16'
20'
24'
40'
X
X
X


50'
X
X
X
X

60'
X
X
X
X

70'

X
X
X

80'

X
X
X

90'


X
X
X
100'


X
X
X
120'


X
X
X
Roof Slope: S&" in 12"
Bay Lengths: 20'. 25", 30' *
STANDARD WIOTHS ANO EAVE HEIGHTS
BUILDING
WIOTH
NOMINAL EAVE HEIGHT
10
12'
14'
16'
20
X
X


25'
X
X
X
X
30'
X
X
X
X
35'
X
X
X
X
'Nott 30' Day longm avaiiaoit only
with 12 oil Itvt lood
Butlor Building Products tro eonatanify bolng improved. Thorafora. tho information contamod on this thaat *• aubioct to cha«pa without
none*. Boforo finalising proiact dataila, contact your naarost Buttar Bulldog or Butlor Manufacturing Company lor tatatt information.
59

-------

Roof Slope. Vi" in 12"
Bay Lengths: 20°, 25 , 30'
STANDARD WIDTHS. EAVE HEIGHTS, AND MODULES
eUlLOtNG WIDTHS
EAVE HEIGHTS
MODULES
30' THRU 240'

30'. 40'. 50', 60", AND 70*
IN 10' INCREMENTS
14' THRU 24'
(MAY BE USED IN ANY
(SINGLE OR DOUBLE SLOPE)

COMBINATION TO OBTAIN A

BUILDING WIDTH OF 3ff THRU 240 )
60

-------
DRUMHANDLiNG-
Richer
AuaiUry
To Pbc&An Older CaIb.TOmHEEJ':800-(BS-7540u- •.
> In tWVarfrSun Tkwi - »tn Oot»" Crft 71M8S4H5S.L.
Single Column Drum Truck With Kick Stand
ALL WELDED STEEL CONSTRUCTION
CAPACITY - 1200 LBS.
A popular single column drum truck that is easy to store in
upright position when not in use. Will handle most 30 and 55
gallon steel -drums.
•	Moldon rubber wheels with roller bearings roll easily and
protect floor. 10* diameter x 214" f®c« W cold rolled
steel axle.
•	Overall height, 59*. Finished with baked green enamel.
•	Handles steel and fiber drums 24" to 48* high.
•	Truck stands upngnt when idle by using kick stand.
•	If operator lets go of handle, auxiliary stop automatically
stops arum in 2/3rd upright position.
Weight, 49 b».
MODEL DH-120 $167.35
Handle Drums The Easy Way
Easy Balance Drum Truck With Spring Loaded Wheels
CAPACITY 1000 LBS.
Optimum balance for efficient operation. Self-standing —
keep aisles and docks clear. Lightweight and durable. All
welded construction. Will handle both wooden and steel
30-55 gallon containers. International Harvester Red, lead-
free. OSHA approved.
The truck carries the weight — not the operator. The long
60* handle provides leverage for easy "breaking* the load.
Rubber or steel wheels — 10* diameter, 214" face with roller
bearings and 1" steel axle.
Both wheels are on slide plate to permit the coil spring to
assist in the automatic loading action of the drum truck.
DH-121
DH-122
TWO WHEEL
Sp ring loaded
chint hook
•utomWicaDy
Replaceable
1'dMl
,'MODEL	teh'	.	-
60*
JSL
24"
24*
Rubber
Sieel
62
72
S105.00
S 126.50
F O.I Nl
STARTING
Place Mat of truck against
bimi and plact hook owe
dnanchmt.
LOADING
Step on foot lever, put
back on handle. Retract-
ing irame automatically
pushes iocs under drum.
LOADED
The continued down-
ward pul on the handle
brmgi the bid to a com-
lonatse balance.
The Only Drum Truck With
Hand Controlled "Wheel Brakes"
tOO and 1000 fc. Capacity — For 30 & 55 Col. Drum*
The only hand trucks available with two wheel hand brakes. A slight
pressure on hand lever gives operator control of truck going down ramp*
'or curbs by transmitting equal pressure to wheels. The 4 wheel model is
ideal for loading pallets. The entire load rests on 4 wheels. No weight on
operator. Equipped with 10" dia. rubber tired wheels (roller bearings).
TWO WHEEL TRUCK
Rubber face
Roller bearings
Replaceable
.ihoo


mcE
DH-624
DH-ttS
Without Brake 70 S00
With Brake 10 1000
SM7JS
2W.75
FOUR WHEEL TRUCK
DH426
DH-627
Without Brake 80 1000
Wrth Brake 90 1000
S2S1.M
339.70
Kick stand
'truck
•teres
unM ponton
"Safety Brake*
Give you com'
pleie control on
ramp* or curbs.
Load ralett
FOUR
WHEEL
61

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ROTATING
DRUM
rour wneei urum Drainer 1 ruck
A FOUR WHEEL DRUM TRUCK THAT DISPENSES INTO 5 GALLON CONTAINERS
1000 LB CAPACITY CORRECTLY BALANCED
Unique Rotating Rollers
Unique rollers on the frame allow drums to be rotat-
-ed u/tthout removing from the truck — drum may be
picked up from any side since the spigot may be ro-
tated to the bottom from any position.
Large 1CT x 2V,' moidon rubber tireo or steel front
wheels with 1" roller bearing* — 6" * 2* moidon rub-
ber tired or steel rear wheen with V roller bearings.
All wheels equipped with grease fittings lor long lilt.
Specially designed chine hook does not need to be
disengaged when draining — fits beneath spigot, does
not interfere with dispensing operation. Orange
enamel.
MODEL DH-129 with rubber wheels 86 bt ... S158.70
MODEL DH-273 with steei wneeu 40 bi	S1&3.4S

*X>lt
Low Cost — Dual Handle Drum Truck Moves Drums
Quickly and Easily — No Weight on Operator
CAPACITY 1000 LBS.
Width 22', Height 53*
10" Molded Rubber
Front Wheels and
6" Rubber Rear Wheels
MODEL DH-128
5195.00
Weight 41 lbs.
Spring Loaded
Foot Trip Stand Permits
Storing in Upright Position
Load Drums 
-------
*• First Aid Kits Fqr Business And Industry

> Eveq? bifsiiMM wUfi J
or mar* Bmpfayw*
1 aid supplies. On*
**' Mqukfntfn/ts.
»

I
9
ttiykta
SSUnif
Kit
Ov
CO
FIRST AID KITS'
Strong heavy gauge steel box with hinged mounting bracket. Has
strong handle to carry kit to location. Painted white or blue rust
inhibilive enamel. Contains bandages %*, 1*. 2", adhesive, ab-
sorbent cotton, antiseptic cream, merthiolate, gauze pads, eye
wash. Wash N Dry packets, aspirin, scissors etc. The larger the kit,
the more is supplied. Includes two hanging tabs. *
~fioDEL Pearfe r!"---I' '--: §*?v.V..*j Uf.w#» :?.*::•£¦
> no. . i StvA 4K 33 ¦ MOO
f A-3S ICO 13'/.'«9'«2K' sj{ 35 80 40
Shatterproof PlasticGoggles
G2S1-PH
Grid Pallet*
G2I1-PR
WnliUKd Frai-
ler ItuxdoiM Condii Ion
Replaceable Lena • Shatterproof Plastic
General purpose, far use Ui hazardous and humid environments.
Ventilated to reduce inner fogging Clear plastic replaceable lens.
Frame is tinted green with clear soft nose mt.Th* rubber headband
icacfut tabic.
MODEL G2eiPft	MODEL G2 It-PR
Quant it im t II	$4.20 «*. Quantities 1 II 	$$20 ea.
Package el 12	$3.25 n PaclU9C ot 12 .:	$3 JO ca.
IOC — Ckw mlra Ian*. Quantities 1 11 	|M# «a.
12 to 71		fl.ttea.
' MINIMUM ORDER $2000	_
				f.9!"*
Etnergency
Drehch Shower


¦ • Drench tmtbe body — quickly
to help decontaminate body as fast
•	as possible. ¦
•	Free slandiitg shower with heavy
duty 9" diameter floor flange,
Tire upright is I V4" galvanized painted
pipe and live supply is' i%" pipe.
Shower head and bowi ate cor-
rosion resistant Cycolac*.
The emergency shower has a 1* stay
open ball valve and the eye wash
operates b\» push flag handle at-
tached to a H stay-open ball valve.
• A sign is supplied. Weight 65 lbs:
Model 933»	,
' $401.50 ea. ' 1
S*jir;l4
J-P
K..A-
•«f.W

Portable
^^Eye/Face Wash
And Body Spray
Provide protection in remole
• areas where normal water sup-
ply is not available. Has 5 gal
stainless steel tank with cariy
ing handles. Model 600 equjp
r>d with hand squeeze valve,
leet of rubber hose, pressure
gauge and tire filler valve. A
dual action safety valve pre-
vents over pressurization and
also allows the user to vent the
pressure for cleaning and main-
tenance. Wglit. 15 lbs. (empty)
Model 604 includes 6' of hose
and dual eye/face wash spray.
Wght, 23 Ibi. (empty).
MODEL 600	$293.55
MODFL 601 Same as above «*
c#pt mcMing tank mounted ?ye
wash. Wglit. 23 »>s	$351.35

-------
i!BW$F RESPIRATORY-HEAD-EAR PROTECTION
FULL FACE RESPIRATOR
',g V *72.09
\J \w 1' A full faeeplece. car-
^i' 7 - 1 ; (Hdce-trae respirator
tor protection against
¦ w organlo vapors, acid
M ¦11 ' gases, duet* end mlsta.
W Br ]ft Provide* eye as well
\HBl as respiratory protec-
yi V ,0*\f tloa fo atmosphero
xtzSTX where eoncentratlon
I LW /iM of contaminant |« not
\ CSJ/w? Immediately danger-
\ 7*SW V^Tr one to lift. Norton
^ brandn«3).Wt.l%lbi.
No. SX80S. Rot. Iin.lt. Ea. $84.09; lots 3, *7l.0»
PROTECTIVE HARD HATS
*4.14 T
/r \ \ IHkw Oalar
g \ \ Meet or exceed Fed.
f \ \ apeca for Impect and
/f 1 . 1 \ penetration, plus dl-
lli 1 1 ¦ '—olectrlc roqulro-
	 ments of EE1 specs.
«w" • Made of high density
polyethvleno. Rein
trough design. High edgo (trength tor extra
protection from head-oa and side Impact. Size
114 8. Adjustable headgear. Sweatband. 1* lb*.
Calar Mfr«. Madal 8tk. Na. ftetall Each Late *
Yellow 410YL 4X637 80.00 S4.B3 *4.14
While 4I0WII 5X808 0.00 4.S3 4.14
REPLACEMENT CARTRIDGES ft FIITERS
Pkg. 4 cartridges, • preflltera for No. 6X80], I lb.
N«. SX804. Rot. $18.30. Ea. $I1.J2> loU 3. *11.1*
WINTER 1INER
Full atylo. Tor hard hats and bump eap. Norton
brand (4150 3). Wt. 1 01.
Ne. 5X910. Retail $4.30. Each *1.07| loU 8, $UI
WHITE BUMP CAP
' to oeProtooto
S* ¦ - \ ~X.03 against acalp
• f/ // \ Lata it l«eerjtlon«.
#/ ../ .1 bruises.
re-VW 1 minor concussions. (Not
J a safety hat.) Molded
/•^Qat. - / plastic with foam-backed
V • r aweatband and 8J4-7H"
\ >•' headgear. Norton brand.
(MWII). Wt. • Oi.
Ne. 5X421. Retail *4.73. Each *3-33i lots 11, *I-»5
HEARING PROTECTORS
/Wi \ Standard . . 1 -
/ / y^DaluxT\
// \ *8.56 /> ""* \
u,,,
Standard model give* protection In moderate
noise areaa up tollO dbi: detune model In high
noise treas exceeding 110 dba. (Protection 1*
generally required wnen 80 dba Is exceeded.)
BROW BANDS
*5.83 »rfed«
,w°Jh'ab?el:"?.fhV
weight and non-toile. Absorb* pertplratlon,
keeps glasses from togging. Sold only in boaea
of & band*. Norton brana (8010). Wt. 1 ot.
N*. SX80S. Retail *9.71. Each *<.!«> lota 8, **•*!
. Mtra. Sletk Lata SIm.
Type MmM Ne. RateN Each 0 WL
Slaadwd i»0 MOM IJJJ7 *1.88 ISH lias.
Oalaa «M 1X121 U.0I 11.18 8.M II m.
NORTON EQUIPMENT MEETS er EXCEEDS THESE SAFETY SPECS
The American National Standard* Institute tor persona) protective equipment required by
specs below constitute the source ot standarda the Occupational Safety t Health Act (OSHA).
Our
«wt N. AooMcablo ANSI Specification
Our
Stock No. AppHcoblo ANSI Specification
2X418 287.1-1870, Sacijoe 8.2
4X251 M7 I-I079. Seclloii 81 J. Model !
4X633 Z87.1-1878. Section 6.1.1, T.l Modal 1
4X635 £87.1-1078, BacUoo 5J
4X637 • Z8».l-l86».Type3.Cfaaa A AB
4X070 Z87.I-I070, Section 8.I.®, Modal m
5X605 Ne SpecilH-ation el Present
5X606 £87.1-1879. Section 6.1.2. Til, Btyla C
5X607 I87.I-I079, Section 8.1.1, Til, 8I7I0 C
S X6P| *87,1 -1 Wf. Berth* »•»
!»fl iliEEiH
5X612 £87.1-1879, Section 6.1.0.1*6
5X613 287.1-1079. Btetion 6.1.1.4 ¦
5X614 K8T.I-I079. Section 6.1.4.1.7
5X615 No Siieeilrration at Proent
5X616 No Biwrificelion at Preaenl
5X619 NHWII/MSUA Approval fTC-MCT*
5X620 ZH8 2-IPII0
5X621 NoS/ieriSratlon of IVaeent
JX622 Tealmi f> eccorrfaace wHh ZU.2Z-I9S7
.. -rlM.
SX624 /For in-plant re 25
Up to 50
133
218
or
CONTRACTOR KITS—Meet OSI1A require,
ments for outdoor use by contractors. While
steel cabinet has rubber gasket and pulldown
latches to make It water and dust proof Each
box contains Individual packages so unused
treatments won't become contaminated.
' Lots Shp|.
Each	I	Wt.
Slock
Ne.
Retail
Contractor
Contractor
Up lo 10
Up to 34
81
ins
7lfic
7240
5X624
5X625
15100
80 10
*38.44
60.66
5X806
5X807
33 83
74.00
23 80
52.49
*32.97
51.95
20.42
45.02
2
CONTENTS OF FIRST-AID CABINETS LISTED ABOVE
REPLACEMENT ITEMS—Available Individually from Chicago Cutlomer Service Dept.
Ordor from niiml Groinper iddr«ti for fittest shipping ttrvlco*
Fei Par
5|»,		IHwripfhw 	
No. 5X624—INDUS. KIT (Up lo 25 PeopU)
It)* Adkwlvi Biodtit (NfiX)
tti t 3!** AdKtoW* Utmltte (608)*
Bun	16 fi© T»b» ((/ON)
Firai-Anl Oititmtnt, II in Tobo (671)
Ammoiiii lehafsat (COO)
Ajrptt'm T»\let, ?i VtckrU ot 31». (Ml)
V » 6 Yd. SUeiefc rUndw <811)
t A Yd. AdlMin Ti|« (842)
I %r hWAdbmat (8171)
! es. ttolUt l*vr loriift* (MOP)
I oi. Dottle Ef \\*sh (Ml)
1
40
1
8
1
1
1
t
1
10
t
to
1
|
1 .
1
1
18
1
1
1
1
1
I
1
J
1
1
1
—
i}f Fofcej* fill)
r Bloat Rn«
No.
i
i
a
I
40
<
I
4
i
«
1
IS
. ........ (&w«(l*M
Ftrtt-Aid ImIwIw* llfiotlcl (8t3l
Mvlat Cm .ill Carrying tlin^i
5X107—CONTR. KIT (24 Man Crow)
'* 11 3* Adbwire	(606.IX)
IM i SW AHKnm	<«*>*
t'fliMHfCoiArw 16721)'
40"	IUmUu (MM
I'll Yd. Oium Rinoi|« (639)
jlere Cremf, J |n 1ufi« (68010
Bar* umm, II |m Tulie (WON)
Ammonia l.botAPt (lull)
l'VP loOmrS».k t)M)
IS
18
4
I M.
Stiaireal Snln (711)
Ere lftrwi** Kit (M»ll
Ho. I Kjte Ikntini Kit (OMX)
Tourniquet rod f orma (7*0)
Fir»M/rf fnilmcljon llnokltf
MetMl Cane. M ater and IM
No
WH
re. Pit
PH.
D.icrtptlon
No. 5X625—INDUS. KIT (Up fo 50 People)
»
N*
I
I
I
I
I
I
W	i
40 I * 3* AiJh*irt fltnjtg* (809JX)
• i'( « -W Adho«ir« lUndtc* (W>6)*
I ('IliniliK* OomprM (62(1)*
) Dura	16 fm Tub* (670N)
3 FiitV-A'hl Ointment, 15 tm Tub# (671)
10 Animwii InUUnt (000)
100 Aipirin TsMcl, Po(U« of 100 (666)
I Tmirniniwt (7St)
I ' I llU. SlrM^h Dinitiii (Hit)
9'11 Yd. Ftrctrh Ptfidw (ffl?)
Ji* I 6 Yd. Atlhrsiu T»r* (942)
)i V Non-A«lh*fffil P»i||)f
Fint-Ai
-------
W.7//y
EYE-FACE-RESPIRATORY PROTECTION
WELDERS CUP GOGGLES
~4.48 of lh*r'
bbli
mal plaatlc
with hard-
ened lensea.
Adjustable bridge.
Neeta ANSI apee. 2*7.1
Norton brand litll-
niS). Shpg. «t 4 •«.
Ma. SJH77. RotaH |7.
WELDERS SOFT GOGGLE
~5.73

Ilk
I
O*
Ui
.Soft
nta over or* cli
vinyl. 1-pc. tram* with In-
direct ventilation. Front
lens holder. 2a4H~ (No. I
• hade) hardened filter
lena meet* USASA. ZST
ipw. Norton brand (M70H5). Shpg. wt. I OL
No. 4XS7S. Retail t» H. Bath *4.70; Iota 8, <1.71
WELDERS RIGID GOGGLE
$3.96 V
Low coat, enablonod
rigid (ram* goggle
with beat treated 1 t
4M* Alter plain (No.
atiade). Norton brai
(9074H5). • OS.
Ne. IUM. Retail Hit. Kaeh 94Mi loU S. $S.M
S a «" REPLACEMENT LENS. NO. S SHAOR
F»r 4XS74, SXMO. Norton brand (MI IS). 1 ox.
Ne. ntlL Retail $1.74. Each (l.lll lota 1J, $1.14
1 * 414" CLEAR COVER FLAT!
For «S7». SXMS. Norton brand (NNN). S M.
He. SX414. Retail 44c. Each >0cf lota M	4>
ARC WELDING HELMET
~12.79 lr
Strong Sberglasa fcetmot re-
als la beat and weld anatter.
Lena holder molded Into
•hell prevents light leaks.
Has aweatband and pin-stop
(or helmet a ogle. Large
headgear knob tor eai/ ad-
justment. even with gloves
on. Fed. Smc. lens. No. 19
abado. Norton brand.
(NO!*). Shpg. wt IH lbs.
Ne. 4»4M. Retail glJS. Ea. $I4.M| lola S. (U7>
I * W REPLACEMENT LENS, MO.IS SMAOI
For No. 4X41S. Norton brand (MUM). Wt. t at
Na. Mtll. Ret.ll *174. Each $1 JJ> lota IS. $1.14
1»W CLEAR COVER N.ATI
For No. 4X4». Norton brand (NNN). Wt. * ox.
Me. 4X414. Retail 84c. Each H>W lota 11	4h
LIFT FRONT ATTACHMENT
*3.57
lab 4 tlt-ft. molded,
Bied-tront types to
• IIR front. Fits over lens
holder, locks with I hlojeed
dips. Norton brand (SttS-3).
Bhpf. wl. • ea.
Ne. 9X414. Retail fS.«3. Each *4.14| lota I, $1.47
1
'V)
DUST MASK
SO 11 Safeguards
*• I a wearer from
Lata 4 nuisance dust
and mlsta.
Soft, pliable, non-aller-
(onlc feceplece has re-
leverage headband. Washable polymer
•Iter. Norton brand (7290) Shpg. wt. J ox.
Me. 5X41$. Retail mi. Each |t44) loU 4, |l.|)
REPLACEMENT FILTERS. FKO. OF •
Five polymer alters for 1X411 (above). WL 1 ox.
Ne. 1X414 Retail SUS. Each |I.W> lota «. $IJ7
DUST/MIST RESPIRATOR
Protects against pneumoconi-
osis and systemic poison dusts
and mists. N10S11 approved.
TC-llC-m. Norton brand
(7100). • ox.
Na. 5X401. Retail $17 J». Each
	>11.04j lota 4 .	$10.14
REPLACEMENT FILTERS, PKO. OF S
Five electrostatic felt BHera for SX401. Wt. 1 ox.
Ne. 1XS01. Retail $141. Each $1.»7i lots S, $1.4t
PAINT SPRAY RESPIRATOR
fc.93

~16.93 V,"
Protects against paint
and lacquer mlsta, and
organlo vapora. Keif
mask elastomerlo face-
piece has reverse lever*
ago heedbend. Organic
vapor cartridges with
I laminated premier held
on by retaining ring,
I NIOSH approved, TC-
21C-7S. Norton brand
(7631). S Of.
Ne. 4X174. Retail <24 21.
Ea. $19.74| lota IS, $I4.»>
REPLACEMENT CARTRIOOES A FILTERS
Fkg. 4 cartrldgea, 4 preflltera for No. 4XZ74.1 lb.
Ne. 4X173. Hct. $a.0». Ea. $11.44) lets 6. $13.14
PESTICIDE RESPIRATOR
it / 7B Provldea
^IO./jF protection
fecit
cldea, Insecticides and
fungicides. Half mask
faeeplece features m-
vorae leverage heao-
\ bands. Use NIOSH ap-
proval, TC-J3C-74. Nor
7 / urn brand (7MB). Shpg.
f J wt. 14 ox.
J- Me. SXttf. RetaU 3I7.94.
JJa. f |f,$4| lota 4, f 14.7t
RIFlACIMfNT I
(w'i
Ne. 3X430. RetaU I12.W. Ea. $».1«| loU «, $7.7»
IIHACIMCNT eARTRIDaei A PILVm
g. of 4 |»r*-Slleft IM Cartridge assemblies
' Nn. SXilS reepltaior. Shpg. wt. 1 lb.
Spray Paint In 39 Industrial Colors
Fast-drying, durable Dem-Kote- See Index.
ixOtt-iOAtfC, liKY CHEMICAL HKE EXTINGUISHERS
For All'

-tC
ri
mu
fa
f
rdi
m

j

mn
M isa n
tti Ih.

A:B:C RATED FIRE EXTINGUISHERS
a—Weed, Fabric, Rubblih, Oreaie, Flammable Liquid (Catollne, Oil) 4 Electrical
Compact, reflllabte extinguish-
ers with top quality feature*.
Lightweight sleel cylinders.
Nun corrosive parts Inside and
out. Durable brass valve Is
standard. Waterproof, easvto-
read pressure gauge. Positive
squeeze grip operation with
stainless steel Handle. Heavy
duty mounting bracket. All
units charged with specially
formulated alllconlted dry
chemical, UI. rated A:B:C for
fighting wood, paper, and fab
lie (Iree—plus grease, flam
roable liquid (gasoline, oil) and
electrical equipment fires (mo-
tors, appliances, switches, etc.).
All model* exceed Dept. of
Transportation aafety require-
ments. U.S. Coast Guard ap-
proved (except models 2W0tS
and 2W357). Pem-AII brand.
<1it.*
Hi. tW«W
•MM*
R». iwafr
a* MS s
Re. IWJI7
ISA Ml A
NIM.
OL LISTED. U.S. COAST OUAROt AND DEFT. OF TRANSPORTATION (DOT) APPROVED
Ratings: The higher the rating, the higher the capacity for fighting Cless A:B:C flrei
Rallnf
IX 108.-C
1A 10B:C
2A 108:C
4A C0B:C
20A S0B:C
Sliaaf
Chacga
PtMawa
tndtcalor
Dbnanatalia
(Ht. x DM.)
Mfr'i.
Motftl
lldtk
N».
Retail
Each
*%¦
2 H Iha.
5
tH
10
20
Oaug.
Gauge
Gauge
(laug.
Gauge
It x 3"
IS X 4
21) ¦ t
17 s S
25 Hit
Pa27AIic;
PA50AHC
f A57AHC
rAlOOAUC
PA200AUC
2 W327
2W086
2W0S7
2W08SI
2W3S7
*29.50
4200
50 00
WOO
linoo
*14.94
21.9$
25.24
37.71
43.22
e
10
it
20
3fl
(t) ModaU 2W048 end 2W3S7 not U.S. Cout Quktd Approved.
llOil 00|1 A:B:C RATED FIRE EXTINGUISHERS
Far All Types Of Fires—Wood, Fabric, Rubbish, Creole, Flammable Liquid (Gasoline, Oil) A Electrical
M» lwioe Compact, reflllable Ore ex-
•A	jc. Ik,, tingulshera charged with
ammonium phosphate dry
chemical rated A:I):C by
Underwriters Laboratories
(or flghllng wood, panrr
and fabric Ores—plus irrnw. flammable
Na. tWlM
M iae.c_iy, its.
Dil«iW
IAIMS-IU
m i«n	to (.n
^11.20
n*iu infitv hi	piua |i rnje. iii»iiiiua»it
liquid fgasollne, oil) and electrical equip-
ment fires (motors, appliances, etc ). I-lght-
welglit aluminum cylinder, except No.
2W207 Is steel. Non clogging DuPom valve
on No. JW204; others have aluminum head.
Durable non-corrosive parts Inside and out.
Waterproof, ensy-toread pressure gauge
for vlaual check of pressure conditions.
Positive, squeeze grip operation; dimple to
reflll. fleavy duty wall mounting bracket.
All models are U.S. Coast Guard approved
(except No. 2W204), all meet Department
of Transportation requirements. Durable
red enamel finish. Red Cap brand.
UL LISTED. U.S. COAST OUAROt ANO bEPT. OF TRANSPORTATION (DOT) APPROVED
Ratings! The higher the rating, the higher ftie capacity for flghllng Clesa A:B:C flree
tlisaf
fibril
Prttawa
Dlmanilwfl
IMUPii
Pali
r*7_

-------
CLERICAL OFFICE FURNITURE
Steel Construction. Jf Deep a 41" Wide Desk Tap. Ad|uslable (hall en iMkctu hat 1 positions.
*73.64
Lets I
Bookcase. All alaal construction. Ona open ad
Juatable ahelf provide* imm («> ltdnn, rtf.
erence books, catalogs, ate. Low profile height
, offers convenient access while seated In ode*
chair. Inside dimensions: 1ZH D * 34V* W s 28Vt*
H. Black enamel Anlah. Waico brand.
DsscrlpMsa
—Ovaratl OSmhImi—
WDM
Mlrs.
Medal
Slack
Ns.
Hated
Cadi
LMi
S
Shpf.
WI.
Datk
Chair*
Bookcase
42*
Mr
13
2#K*
30
91330
2I4A
«0(MS
3W121
3W123
3W124
SZ8S.II
138 65
I02.A0
$197.11
102.91
76.80
$189.01 132
98.68 2I1K
73.64 65
ON *W«eo chair* meat all known fin lalaidut codaa aecpt Dosteu and Port of New York.
CT»	
SEE WARRANTY INFORMATION ON PAGE BEFORE INDEX
449
INDUSTRIAL OFFICE DESK AND CHAIR
AH Slaal Construction. ir Wide I IT Daap Datk Tap. Mam redded Chair
Executive Deslfn Oatk. Traditional style daak
haa completely enclosed double padeatal bot-
tom; provides ample storage apaca In (our bos
drawers. ona lUa drawer, ooa allmllna canter
drawer and two elide out posting ahelvea.
Center drawer locka all drawara. Heavy-duty
four channel Inner construction provMeo a
rigid basa for steal auto-top. Laminated plaatle
top la specially treated (or qatetnaaa. Satin
Anlsh aluminum hardware.
Overall dimensions: UWxMDl 28V4* H.
Color: gray with (ray laminate top. Wesco
brand.
EaecvtWe Design Chair, a ray vinyl and fabric
aeat ts styled to match desk No. SWUt listed
above, lilting mechanism with torsion bar
action tilts and awlval* aeat cushion, backrest
and arms aa ona unit. Seat height la adjustable
— .. —- 		••. -oTii„( j» chrome
it cuahl
		_		.rinrt eo.	
foam backresl lalli 1tl£ > IH* tiict. Vinyl
Smooth ro—,
han padded aea
from l« to »M'
finish casters. roam	----
IIU W « 17* D * Stt* thick. Vlnj
krest la II * II
padded armrests. Wasco
I covered
Dessrlp- Mlra.
Ilea **
Ratal Each
Lets
1
Desk MM JWIJ9 *510 85 U5I.H IMJ iJ
Chair* SUA VWJ20 105 IS J14.97 110.25
*343.89
una
*110.25
UK I
STEEL OFFICE FURNITURE & FILING CABINETS
(9 OFFICE OfcsK, SO x 60*—I* thick colhpoil-
ITon lop Is flnlshed In walnut-tona hard plaslle
Ismlnafe. 2t-ga. ateel pedestals have baked on
black enamel diilsh, measure 14V4 \V * 25 t> *
IM1' II. Sleet drawers have aluminum handles
and move on tiylon and ateel bearings. Center
drawer locks ill I pedestal drawers (Incl. deep
Die drawer). Chrome plated 1* sq. ( 28* long
tubular steel legs with leveling glide# are
shipped dismounted from desk. Assembled desk
height	Modesty panel. Wesco brand. Use
wltn l>esk Extension No. SW122 below.
B5 CUSHIONED SWIVEL CHAIR—niack Vlnyl-
cuslUoDed desk chklr with fabric seat had wal-
nut tone hardWbod arms; 1" square tubular ateel
arm supports and seat bracing Anlsheil la lilack
enamel, chroma Anlsh swivel base with t x 44"
swivel castcra. Seat height Is adjustable from
17 to 11*. Torsion bar action, tilling seal and
swivel casten add to working maneuverability.
K«>
A
B
C
D
E
Seat cushion li i T i im W > «* D, back
cushion 2 T * 20 W * 12* P. Wesco brsnd.
PCI CUSHIONED ARMCHAIR—Comfortable ol
Ace chair matrhes desk and swivel ciialr—
Is normolly used In groupings of two or three
chairs per office for visitors, salesmen, etc. Dur-
able blark vinyl cushions have fabric seat. Wal-
nut tone hardwood arms. 1* sq tubular steel
legs are Anlshed In black enamel. Seating lit.
mi*. Seat cushion J T x 1914 W x 22 ' I), Wk
cushion tT>10Wi 12* D. Wesco brand.
P 4 If] FILE CABINETS'-Letter alza files are
sturdy 24 gs. steel and won't tip with loaded
drawer open alt tlie way. Drawer (runts of 12 ga
steel have aluminum pull handles and caril
holders Full suspension drawers move eaiily
on steel bearings and rollers. Attractive baked
on black enamel finish. In 2 drawer (29* II) and
4 drawer (52" II) styles. Wesco brand.


itti
stipg-
RtUll
EtcN
3
Wl
•312 90
$240.57
$227 58
17ft
188 50
126.11
120.93
;irt
Uft.QO
es.4s
81 92
30
\T2 25
113 31
100.66
78
221.65
162.91
156.22
134
Ovarsll Dlmtnilofit	Mlf'a.	Stock
Daatrlptlea	H	W	t>	Medal	N».
Olfiee I leak	20X*	«0*	JO*	IM030	3W049
BmvelChait*	32	»	27	I45A	3 W050
Armcbait*	22	21	I35\	IW051
2 I)rw. Cabinet	»	IS	28	40*	3W0SZ
«l>i». Cabinet	S3	It	28	40 1	3W053
~Waaoo chaira meat all known lire reUidant eo
-------
INDUSTRIAL GRADE WOOD AND STEEL TOP BENCHES
|a+ NEWIUM I
Available it and 72" Wide X M end 3V Dtp.
Optional Drawer, (half. Hall Kit Available

.*¦ nil	'It	Ihs.	•
PiWSSiC^;.


> • ¦ V
w • ¦___—, Lower Shelf,
Drawer, and
Rill Kit
N	Available
A variety of ilm and top aurfacee to meet most
aliop needs. All use 32* nigh lags of all welded
ileel having Ufa. formed T-aecllon uprights
and 12-ga. lop and lower cross members, l/iills
shipped unassembled with legs In separate
carton. Necessary mounting hardware Included.
Dayton brand.
Steal Tip Benches—Smooth gouge-proof, 13-
gauge sleel surface reinforced wttn IJga. chan-
nels at each end. No ahan edges or comers.
Baked enamel phosphatlxed Bnlsn resists rust.
Laminated Compresssd Wood Top Benches—
Tempered wood top and bottom aurfaces are
:J	Jf
WmIVwUmI
„ Misr
<91.51
; "•»
Oswsrseeed Veed
Wertheaea
Mi ar
*1 25.91
Ubi
Solid Mapto
Top ,
w»tSSr *
m a sr
~152.05
Latst
laminated to Ugh density compressed wood
core with finished edges. Top Is ltt» thick.
Smooth, sealed Snlsh gives a durable, non-
porous surface. A very sturdy bench for labora-
tories, factories, assembly plants and shops.
Edge-Laminated Solid Maple Top Benches—
Solid laminated maple top resists damage by
aharp tools and solid Mows, yet Is harmless to
delicate machined parts and dlea. "Butcher
block" construction la warp resistant, self-eup-
portlne and stronger than Solid panels. (H*
thick lop Is accurately machined and aanded.
Level working surface can be restored by re-
sanding. OH rubbed natural laltk.
STEEL WORKBENCH DIMENSIONS AND PRICES
Osstrlsllse
Wwk Surface Dkmnstoas
WMtk Depth Thick ns it
Bench
Height
Lege
Depth
Stack
Ns.
Retail
Each
Late
3
stag.
wt.
Complete Workbench
oo-
Tt
72
XT
•0
30
12-Oa.
12
13
Ji-
lt
34
30-
30
30
ooo
09*4
NOV
SI26SS
I3B.4S
167.00
$96.30
107.45
121.SO
$91.51
102.10
111.26
104
111
147
Bench Top and
Cross Stringer
Only
00
72
72
30
30
3*
13
12
12

-

1W939
1W940
1W941
7010
30.00
104.10
SO.SS
72.00
B3.2S
St.tl
60.40
74.93
70
•0
I0S
Laminated compressed wood workbench dimbnsions and prices
Complete Workbench
tw*
73
72
30*
30
34
IK*
iff
34'
34
34
30*
30
30
5S*i
sss
SI ASM
184.20
203.0S
*132.49
149.21
169.49
9129.91
141.S4
157.17
103
110
ISO
Bench Tea and
Cross Stringer
Only
00
72
72
30
30
M
1
1
1
'

—

1W947
1W94S
1W949
I1S3S
I34.7S
1C0.7S
97.00
113.76
127.10
92.21
108.14
120.S2
•7
110
130
BOGS-LAMINATED SOLID MAPLB WORKBENCH DIMENSIONS AND MICBS
Complete Workbench 60- air 1
72 30 1
72 30 I
84 K* 30*+7W194
atX io 47W1SS
34M3e47WlSS
$21300 S160.0S $152.09 127
217 OS 183.65 174.S0 140
28300 210.SO 200.2S 110
Bench Tea end 00 30
Cress Stringer 73 SO
Only		72 M
B
•f 3W202 180.11
43W203 197.00
43*204 230.10
I24.CO 11B.3S II
14B.20 140.S0 117
172.5S 163.90 129
BACK ANO SIDE RAIL KIT
Kit attachea te aide and back of No. 7W073,
TWOU, or TWtM SO x CO* work benches with
mounting hardware Included. Prevents elec-
tronic componenta, tools and other imill artl-
FOR ABOVB BENCHES
cles from falling. Provides S" Inside height.
10-ga. steel back, 1J ga. stoat aides. Shpg. wt.
IS lbs.
M«. 3W1SV. Hot. $23.10. Ea. $lg.47| loU 3, $I73S
LOWER SHELF FOR ABOVE BENCHES
Adda antra rigidity, provides eterege space.
(Ml
W 0
60"
72
SMtt
He.
1W9I4
Lltl Shag-
fUtall tick 3 Wl.
S27.SC S22.40 ill.00 22
1W9I9 12.IS 26.09 24.40 ft
STEEL DRAWSR FOR ABOVE BENCHES
Inelde dlmenalona are IS W * IU fl x 23%" D.
Attachea eaally to usderalde of ateel or wood
bench top. Two auppert brackets furnished.
Full-length slide. 20 gs. steel, grey finish. Pad-
lock hasp (lock not Included). Shpg. wt. 22 lbs.
No. IWS3S. Each $1I.M> lots S	IlltS
| STEEL FOLDING-LEG TABLES
[El STEEL FOLblNO-LGO TABLES WITH
HARDBOARD OR PLASTIC LAMINATE TOP—
For commercial, Industrial and Institutional
uses Including displays, banf|ilete, packaging
and other light duly functions. Topi are I*
tlilrk cellular cdre construction Willi brown
slalngard hardbokrd surface that resists mo Is
' lure; Nos. JWllO. 3WIII and 3W1I3 have
' walnut grained plastic laminate finish with
1 black vinyl edge. Frame has pedestal type It
esiiee tubular lets that are held open by posi-
tive lock hinges for firm support. Drown vinyl
bullnose edees are decorative and absorb bumps.
Tables are 29' high set up, 2H" hlgli folded.
Beige enamel Anlsli. Krueger brand.
HARDBOARD TOP TABLES
Toe	Mfre. Sletk	latt	Shpg.
rif. Sits	Medet Ne.	Relel	Each	4	Wt.
E JOiJJ"	Mill	|wo29 IGI7I	IM.7I	152.(0	tl_
E 10iH	HMI	IWOJO	10II	14 Jl	Mil	71
E III71	*MI	(Win	10M	IMS	N.77	13
E 31 III	ffMl	JWIIl	M.20	71.14	71M	II
PLASTIC LAMINATE TOP TABLES
E so • 71 Nf* rwi ii	wijr	n
E 30 ¦ M Nri J Will f| SO 7140 7111	tl
ElllH WI1 )WII1 116 AO 12.41 17.20	71

-------
$22
ToPl»c*»AnOrdo>CiIUTOU.FHEEl-a00-8Z8-7540* DprFPTACTC I IMrmc
•InNf—VmfcSu»HiMi»ilnQi«i«BrCafcJlfrSBSfllSSE. nL-V-Lr I rlV-Li-LUNl—iACTr-
triMrOiaigc^CafcJlMB&OISSK
Heavy Duty — Industrial Strength Plastic Waste Can liners
A®*'/ *•
1
Less Than 2G Each in Quantity ..
. * LiNERS PROTECT CONTAINERS from cor- """"
rosive or harmful substances.
•	ELIMINATES MESSY CLEAN-UPand keeps
containers sanitary.
•	LIGHTWEIGHT LINERS make handling
trash easy.
•	SPECIALLY PACKED CARTONS allow for
compact storage.	. - '
•	TOUGH POLYETHYLENE is leakproof and
strong.
INDIVIDUALLY FOLDED LINERS make
. counting and removal easy.
MOOet_>cMiCC<3rc.'* Dt
1810
2210
2410
3310
i.o	34- »iir
1.0	40'«2T
1.0	24"k24*
i.o	ar^r
~~
7*
10-
15
Small Wastcoukat
Small Wasttuskct
Mad. Waucbukct
Lmto*
1000
1000
soo
500
3715	1.5	60-*3r	30
4015	1.5	A6'«40~	33
4715	1.5	80->48'	40
6020	2.0	1TMT	55
30 Cation Can
33 Gallon Can
40 Gallon Can
55 Gallon Can
250
250
250
100
PRICE PER CASE.. - T'
$31.95	$25.85	523.85	$20.65
45.95	3930	36.60	32.75
31:95	24.95	23.10	20.35
41.95	3435	31.75	27.68
S36.95	30.85	27.75	24.96
42.95	38 89	34.10	31.05
63.95	M-15	49.85	45.70
39.95	34.95	29.25	27.15
Carton Opener
A MUST FOR '
SHIPPING ROOMS
¦ • ' * ¦	FOIL
No cxpotad blade* - eaa be earned in
pocket or belt. Will nr—carton*, cut
plastic tapes, cords aad twine. Each
opener contains 2 txttm blades.
MODEL SCO-100 ...... $12.99
. 12 or more, each 	S 10.85
72 or more, each 		S 9 JO
68

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APPENDIX C
Supplemental Assumptions and Economic Analyses Associated with Collection,
Storage, Treatment and Disposal of Alaskan Hazardous Wastes

-------
COST INFORMATION "FOR ALASKA"HAZARDOUS WASTES
Trucking
Assume 55 gallon drums; place in 85 gallon salvage drums (3 ft O.D.).
Full Weight: Solvents and Acids -500 lbs; Sludges and Solids =700 lbs.
45 foot trailers, 62 salvage drums per trailer maximum.
•	Transit costs between Anchorage and Fairbanks: Dedicated
truck, minimmn of 24,000 lbs ax a rate of $7.15/100 vt.
Thus minimum transport cost is $1,715.
•	Transport of hazardous materials between Anchorage/Fairbanks
and Seattle must go by Alcan Highway. Barge and Ocean Express
carriers do not allow hazardous wastes. Travel time is 7 to
10 days. Shipping rates are:
Load Weight: 5,000 10,000 15,000 20,000 40,000
Rate $/100 lb: $57.87 $49.62 $43.76 $39.79 $25.29
•	Transport between Seattle and Arlington (Oregon) is $800/
trip on dedicated trailer. There is no rate basis on weight.
Solvent Recovery
•	Costs to Process (includes sample analysis): 80c/gallon for
thinners, light solvents; $1.00/gallon for TCEs, chlorinated
organics. (Product returned to source—Seattle virgin material
prices range from $l-$4/gallon now.)
•	Chempro charges $45/drum for disposal at Arlington (Oregon) of
resultant sludges. Assume 5% of waste volume will result in
sludges.
Hazardous Waste Disposal
Arlington (Oregon): Chem Security Systems, Inc. Costs to treat/dispose:
$26/drum (either liquid or solid). CSSI is finding that most military
wastes are being coordinated through Utah DPD0. They say it is not
probable that the military participates in ADEC program.
Construction Cost Indices
Anchorage: 1.25 x Seattle (a 1.44 x National)
Fairbanks: 1.40 x Seattle (= 1.61 x National)
Operations/Maintenance
Assume a 1.60 multiplier for labor, power, costs, etc.
69

-------
COSTS ASSOCIATED WITH INTRA-STATE TRANSPORT
Assume waste types and locations (monthly generation rates) (S-n drums):
Northern Region		South Central Region

Solv
Pet
Slud
A/C
Slds Total
Solv
Pet
Slud
A/C
Slds Total
Military
33
1
0
1 35
20
1
16
2 39
Other
_3
_5_
_2_
_L 11
10
_13

_4_ 29
Total
36
6
2
2 46
30
14
18
6 68
Assume Southeast Region is negligible, or shipped to Seattle direct.
Five Ovtlons Available
Solvents and
Acids/Caustics
Petro
To Fairbanks
To Anchorage
Build 2 TSD
Facilities
1
2
If wastes destined for
Fairbanks TSD or Seattle
3
4
If Wastes Destined for
Anchorage/Kenai TSD
5

Assume local costs are negligible (i.e., Kenai to Anchorage not included)
Weights: Solvents and A/C » 500 lbs/drum
Sludges and Solvents » 700 lbs/drum
Total Waste Fraction
Annual
Truck Trans-
Non-Milltarv Waste Fracrion
Annual
Truck Trans-
Drums/ loads/ port $/
Option Alternative
Year tear Cost Drum
Year Year Cost Drum
A 1+4
Solvents co Fbnks
AC,Slds 4 Slud to Anch
360 5.8 812,870
120 1.9 4,976
$17,846 .$37
120 1.9 $ 4,290
96 1.5 5,660
$ 9,950 $*6
B 1+2
All Wastes to Fbnks
816 13.2 $32,600 $40
348 5.6 $15,350 $U
C 3+2
Solvents to Anch
AC,Slds6Slud to Fbnks
432 7.0 $15,440
456 7.4 19.734
$35,174 $40
36 0.6 $ 1,715*
228 3.7 11,070
$12,7S5 $48
D 4
All Wastes to Anch/Kenai
552 8.9 $21,100 $38
132 2.1 $ 5,750 $44
E 5
Construct Regional TSD:
Fairbanks Area
Kenai
552 Costs by Shipper
816 Costs by Shipper
132 Costs by Shipper
348 Costs by Shipper
~Minimum costs to secure a dedicated truck for hazardous wastes shipment.
Conclusions
•	Coses per drum are insensitive to locating a TSD at either
Fairbanks or Anchorage/Renal.
•	About twice Che volume of wastes would be shipped north to
Fairbanks as shipped south to Anchorage/Kenal; however, worst
case is about one truck per aonch.
70

-------
COSTS TO TRANSPORT AND DISPOSE OF
ACIDS/CAUSTICS, PETROLEUM SLUDGES AND
OTHER SLUDGE SOLIDS AT ARLINGTON, OREGON
SECURE LAND DISPOSAL SITE
I. Shipment from Anchorage/Fairbanks to Seattle
20 drums/mo of Acids/Caustics 20 x 500 lbs = 10,000 lbs/mo
20 drums/mo of Petroleum Sludge., 2g 7Q0 . 1? 600 lbs/mo
8 drums/mo of Sludge Residuals
48 drums/mo x 12 mo/yr x 1 truckload/62 drums M 9.3 truckloads/vr (5.2)
Net Truck Weight m 26 dxums @ 500 + 36 drums
@ 700 ¦ 38,200 lbs/truckload
Use shipping rate equal to $25.29/100 lb
Shipping Cost: Alaska to Seattle ¦ $9,660/truckload (10,470)
« $89/850/vear	(54,440)
II. Shipment from Seattle to Arlington, Oregon
Rate ¦ $800/truckload x 10 truckloads • $8,000/year (4,800)
III. Treatment/Disposal at Arlington, Oregon
Rate «$26/drum" $14,976/year	(8,424)
Summarv
Transport and Disposal at Arlington, Oregon
576 drums/year ¦ $112,826/year	(336 drums/year * $67,664)
¦ $196/drum	¦ $201/drum
71

-------
APPENDIX D
EPA, DOT Joint Proposal on Uniform Manifest Form for Transporting Hazardous
Wastes

-------
1465

Fifiill Text
EPA, DEPARTMENT OF TRANSPORTATION JOINT PROPOSAL
ON UNIFORM MANIFEST FORM FOR TRANSPORTING HAZARDOUS WASTES
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Parts 123,260 and 262
ISWH-fRL 1M7-4)
Hazardous Waste Management
System: General, Standards for
Generators of Hazardous Waste, State
Hazardous Waste Program
Requirements.
agency: Environmental Protection
Agency.
action: Notice of proposed rulemaking.
summary: Today, in a joint rulemaking
effort the Environmental Protection
Agency (HA) and the Department of
Transportation (DOT] are publishing a
draft Uniform Hazardous Waste
Manifest form and proposing ita
required use by generators for the
interstate and intrastate transportation
of hazardous waste. A manifest form is
a control and transport document that
travela with the waste from Its point of
generation to its point of disposal. EPA's
Resource Conservation and Recovery
Act (RCRA) regulations presently
require generators who transport or
offer for transportation, hazanious
waste for offsite treatment, storage or
disposal to prepare a manifest which
must accompany the waste. Although
the regulations specify certain required
information that muat appear on the
manifest there are no requirements for •
standard form to be used.
Since the RCRA regulations became
effective, numerous States have
developed their own manifest forms
which meet Federal requirements but
require additional State information.
These differing manifest requirements
among States have resulted in confusion
and compliance difficulties for the
transport of hazardoua waste. EPA and
DOT are proposing to resolve these
difficulties through a joint rulemaking
effort EPA. in this rulemaking action, is
proposing to amend its regulations to
require the use of a specific manifest
form. DOT, in a companion action, ia
proposing to amend its Hazardous
Materials Regulations to require that
shippers and carriers of hazardous
waste comply with EPA proposed
3-12-82
[47 FR 9336, March 4, 1982]
amendments pertaining to the proposed
manifest andioxlaafyJhal, whether*
State haa interim or final authorization
by EPA, any requirement of a State or
polititeal subdivision of a State
specifying a different or additional
manifest Is inconsistent with the
Hazardous Materials Regulations.
DOT» proposal appears in a separate
section of today's Federal Register.
Bates: EPA wiQ accept comments on
the proposed rule on or before May 3,
1982.
ADDRESS: Comments should be sent to
the Docket Clerk (Docket 3002—Uniform
Manifest), Office of Solid Waste (WH-
562),	U.S. Environmental Protection
Agency, 401M Street SW„ Washington.
DC 20460
The official docket for this proposed
rule is located In Room 2S36 U.S.
Environmental Protection Agency, 401 M
Street SW„ Washington. D.C, and is
available for viewing from 9:00 am to
4.-00 pm. Monday through Friday,
excluding holidays.
poo further information contact:
Rolf P. Hill or Maty McCaffery, (202)-
7S5-41S0, Office of Solid Wests {WH-
563),	U.S. Environmental Protection
Agency, Washington. D.C. 20460 or the
RCRA Hotline at (800M24-93M (in
Washington, D.C. call 544-1404).
SUPPLEMENTARY INFORMATIOtC
L Authority
This proposed rule Is issued under the
authority of sections 2002.3001 through
3007, and 3010 of the Solid Weste
Disposal Act a* amended by the
Resource Conservation and Recovery
Act of 1878 (RCRA), as amended, 42
US.C. BB12,6821 through 6927,663a
1L Background Information
A. History of the Manifest On
February 28, I860, EPA established a
manifest system to aaaure that
hazardous waste designated for delivery
to an offslta treatment storage or
disposal facility actually reached its
destination. The central element of that
system ia the "manifest", * control end
transport document that accompanies
the waste from its point of generation to
its point of destination.
Although EPA considered requiring a
uniform manifest form when it
Envwenmtnl R«pon«r
72
developed its regulations, the Agency
¦decided to reqttne that ¦pciifii
Information accompany the waste. (45
FR 1ZT26-9, February 2B.1S80) At that
time, the rcguUted community was
already required by the Department of
Transportation to use Kaihjpping paper
for the transportation offtazardous
materials. DOTs regulations allow
industry to use a shippinyjpaper format
of their choosing for thcarequired
information.
The Information requirements for the
DOT shipping paper and the manifest
were similar, thus, EPA concluded that*
shipping paper could be used to satisfy
RCRA manifest requirements If
additional information required by EPA
was included. By not requiring a specific
form. EPA's intent was la pro vide the
regulated community wtfth the option of
adapting their existing DOT shipping
papers to function as manifests or
designing their own foaaa to fulfill
specific needs.
R Manifest Implementation Problems.
Since the introduction of the Federal
manifest system, there has been a
proliferation of manifesto** various
States decided to devefaep and print their
own forms. At least 21 States require
generators to use specific manifest
forms, often with varying additional
information requiremeata.The current
system hss caused two anjor problems.
First the lack of unifonaky in the
manifests required by States has created
a burden for both generators and
transporters. Currently, a transporter
carrying hazardous waste may be
required to carry tha manifest of each
Stete in which he travels in order to
comply with its manifest requirements.
Failure to carry a particular State's
manifest may delay or ptevent
shipments bom reaching their
destination or subject the transporter to
a State enforcement action. Under these
conditions, a generator may be required
to go through the costly end inefficient
procedure of filling out several manifest
forms with duplicative information in
order to ensure that the waste shipment
reaches the designated facility.
Second, the lack of uniform
requirements prevents generators with
plants In more than one state (ram
standardizing their manifesting

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1466
ENVIRONMENT REPORTER
procedures. This prevent* multlstate
corporations frotn achieving efficiency
in their information collection activities.
C.	State and Industry Involvement, la
order to examine the feasibility of
developing a uniform manifest document
to solve these problems, EPA and DOT
asked two-organizations representing
the States and the regulated community
to submit comments to EPA. The State
group, the Association of State and
Territorial Solid Waste Management
Officials (ASTSWMO) and the industry
group, the Hazardous Materials
Advisory Council (HMAC). each
developed recommendations concerning
the content and use of a uniform
manifest and submitted them to EPA
and DOT in March of 1081. EPA and
DOT reviewed the recommendations,
prepared a draft manifest form and met
with the ASTSWMO and HMAC
committees in July of 1981. During
ASTSWMO's September. 1981 national
meeting, its members reviewed the
Uniform Hazardous Waste Manifest
form and subsequently submitted fiullicr
comments to EPA. A discussion of
ASTSWMO's latest recommendations it
included in Part nr.
D.	EPA end DOT Joint Rulemaking.
Since the current problems associated
with the manifest involve both POT ami
EPA. the Agencies have worked together
to devise a regulatory solution.
Therefore, several amendments mtt
being proposed in this area. 	
EPA is proposing to amend 40 CFR
Part 202 to require generators to use the
Uniform Hazardous "Waste Manifest
form in order to meet manifeat 	
requirements. Amendments to 40 CFR
Part 123 would make use of the form a
requirement for State interim and final
authorization. DOT is proposing to
amend its regulations to require that
transporters of hazardous waste comply
with EPA's proposed amendments and
to clarify that any State law or
regulation requiring a different or
additional manifest is inconsistent with
DOTs Hazardous Materials
Regulations.
The efTect of these amendments is
twofold. First the use of a nationally
uniform manifest would be required for
all offsite transport of hazardous wast*.
Secondly, no State could require a
transporter to carry additional
information on or with the manifest.
Thus a transporter could not be held
legally liable for failure to carry a
State's particular manifest form-
Neither the EPA nor DOT proposed
amendments would prohibit a State
from requiring additional information
concerning each shipment of bazardoua
waste from the generator or treatment,
storage or disposal facility. For exsmple.
a State may rrquirr that certain dttso&al
3-1S-S2
related data be present at the facility
before the facility accepts the waste.
The proposed amendments do not
preclude the transporter from
voluntarily carrying such information
but do prohibit any State from requiring
him to do so.
This regulatory approach is
authorized by the Hazadous Materials
Transportation Act (HMTA), 49 (JSC
1801 eL seq.. and RCRA. HMTA
expressly preempts any Slate or local
require.-r.ent that is inconsistent wtth
HMTA or the regulations issued "
thereunder. As stated in its preamble.
DOT believes that national uniformity is
necessary in this area to avoid a
patchwork of differing State
requirements inconsistent with the
HMTA regulations. In addition, section
3006(b) oHiCRA authorizes EPA to
disapprove any State application for
final authorization to administer and
enforce the Federal hazardous waste
program if a State program ta
inconsistent with the Federal or other
StateprngErmi. As explained is the next
section. EPA proposes to exercise the
section 3006(b) authority in this area to
require national consistency.
£ State Authorization under RCRA.
EPA is proposing to charge the Part 123
State program requirements to require
any State applying for Phase 1 or Phase
II of interim authorization or final
authorization to require the use of the
Uniform Hazardous Waste Manifest
form. The revised manifest requirement
in 1123.34 will be applicable to a0
States applying for final authorization.
The revised manifest requirements in
i 123.128 will be applicable to any State
which applies for any component of
Phase n of Interim authorization which
is announced after the effective date of
today's amendments (see 40 CFR
123.122(d)(2)). These changes will assure
that a uniform format is used for
manifest information, that State
programs will be In compliance with
DOT regulations and that, In the case of
final authorization, the consistency
requirements in 3006fb) of RCRA are
met
The DOT preemption regulations
operate independently of RCRA and
apply to aO Slates, whether or not they
have received interim or final
authorization. Thus. DOTs broader
preemptive authority will extend to all
authorized States and will ensure a
comprehensive solution to the manifest
problem.
F. Implementation Dates. CPA and
DOT are proposing common effective
dates for the proposed amendments.
Since DOT regulations apply
independently of RCRA regulation,
coordination is necessary for consistent
implementation of the uniform nationul
manifest.
After considering the alternative of
phasing m the use of the uniform
manifest form. EPA and DOT have
chosen to require a uniform effective
date. This approach was selected in
order to avoid confusion concerning the
compliance date. Use of the form will be
required for all transportation of
hazardous waste 160 days after the
publication of the final rule. This
effective date was chosen in order la
provide quick relief from the current
situation and also to provide Stales and
industry with time to Implement the aae
of the new form.
EPA has received comments
requesting that the effective date allow
the States time to update their data
management systems with a minimum of
disruption to their current operating
procedures. The Agency soliati
comments from both States and industry
on whether the proposed effective date
allows sudaenl time to implement the
form
As stated in a previous section. J30T
requirements would apply to all
hazardous westes transportation in
States with and without interim
authorization. Accordingly, all State
manifests will be subject to Federal
preemption at the time DOTs
amendments become effective.
IIL The Uniform Hazardous Waste
Manifest
EPA, with DOTs agreement proposes
the Uniform Hazardous Waste manifest
with the foDowing features.
Form Design. EPA incorporated ideas
from several existing State and Industry
manifest forms in urder'to design a
uniform manifest tlvat would satisfy the
majority of users. The form itsalf is the
standard paper size of by 11" to
allow for easy filing. The form wes also
designed to facilitate the processing of
data from it into automated data
processing systems. Therefore, all the
information which would be entered by
a data machine operator wea placed on
the right hand side of the fonn. The left
hand margin indicates what Information
is filled in by the generator, transporter,
and the designated facility.The form
also contains three inches of horizontal
space for listing the proper DOT
shipping name.
The manifest document is designed to
contain an optional continuation sheet
(EPA fonn 8700-22A) on which the
generator may list both additional
hazardous wastes and transporters. This
eliminates the need for industries,
notably laborctories with many different
waste stream. to fill out multiple
separate manifests for one shipment
Instructions for filling out the Uniform
Hazardous Waste Munifrnt are inclu;i.-d
in tpri
-------
CURRENT DEVELOPMENTS
1467
instruction arc required to be lollowj-d,
EPA i* not mandating that they b«
Included with the form. Additional
•pecial instructions or emergency
information may be printed outiride the
margin or on the back of the form at the
user's discretion.
Information Requirmenls. hi
developing the Uniform Hazardous
Waste Manifest. EPA has transferred Its
existing information requirement* onto a
standard form. EPA ha* not increased
Its requirements except for ooa minor
item: the inclusion of the treatment
storage rod disposal facility's telephone
Tram bar. The Agency believes that 1he
inclusion of the phone number will aid
the transporter in contacting the facility
in the event of an emergency or delay.
Two existing information
requirement*, the manifest document
number and the EPA assigned generator
identification number have been
comouea fo lorm a unique manfiest
document number. This manifest
•document number will allow each
generator to manifest up to 100.000
shipments before repeating a number.
Because every generator ha* a separate
EPA ID number, each document number
will be unique and therefore easily
identifiable within the hazardous waste
management system. Further, die newly
defined manifest document number
reemphaiizes the Agency's belief that
the generator shoald assign the number
for each shipment of wa*te.
The proposed form contains two
optional spaces. The first is the
hazardous waste number space in which
the EPA or State hazardous waste
identification number can be filled in.
This is not an information requirement
Rather. It is a convenient feature of the
form to aid the States and Industry in
their recordkeeping task*. The second
optional space is entitled "Special
Handling Instructions." The generator
may use this space to record extra
instructions, comments, or an alternate
designated facility's address in the
event an emergency prevents delivery to
the primary designated facility.
A third optional space for the vehicle
identification number is being
considered. During the drafting of the
uniform manifest. EPA and DOT
debated whether or not to include the
vehicle identification number as a
Federal Information requirement It was
decided not to include that requirement
in this proposal for practical reasons.
During the transport of one hazardous
waste load, several vehicles may be
used if shipments are consolidated or
the equipment fails. The generator, who
is responsible for filling out the
manifest, may be unaware of these
possible changes and therrfdrc could
not be reasonably expected to provide
3-12-S2
sUch information on the manifeaL For
this reason the vehicle identification
number is not being proposed as a
Federal information requirement DOT
and EPA would appreciate comments on
whether or not to include an optional
space for the vehicle ID number on the
form.
The Agency has also included a
manifest discrepancy indication space
on '*¦*» tnrrr, EPA regulations require
owners or operators of facilities to note
on each copy of the manifest any
significant discrepancies between the
quantity or type of hazardous waste
designated on the manifest and the
quantity or type of hazardous waste a
facility actually receive (40 CFR 264.72.
26S.72). When recording significant
discrepancies on the Uniform
Hazardous Waste Manifest the TSDF
owner or operator wiii be required to
use the discrepancy indication apace.
Form printing and number of copies.
The Federal government will not print or
distribute uniform manifest form*.
Generators may print their own forms or
obtain them from commercial form
design companies and. in this way,
retain the flexibility of selecting
manifest package that fit their needs.
For example * generator may decide
to vary .the number of copies in a
manifest package depending upon
where he ships his waste. EPA requires
that the manifest consist of two copies
for the generator, one for each
transporter and one for the designated
facility. In addition to the EPA
requirement some States mandate that
a manifest copy be sent to them at the
initiation and completion of each
shipment. In order to easily comply with
the State requiremont the generator can
obtain a manifest package that include*
: the number of copies to fulfill the
Federal requirement plus additional
copies for the State. Or the generator
may dedde to photocopy legible copies
to satisfy tracking requirement*.
IV. Request tor Additional Modification*
by States
As explained in section IIC. the draft
uniform manifest was reviewed by
ASTSWMO's Hazardous Waste Task
Croup during its September 1901
national meeting. The Task Croup
supported the form's information
requirements and format but
recommended that it be modified to suit
the broader needs of the various State
manifest systems.
ASTSWMO requested that EPA
include these latest recommendations of
its Task Croup iq this preamble. EPA Is
aware of the concerns of the States and
is taking this opportunity to obtain
comments on the various State
recommendations in the hopo of
Environment fttponw
74
designing a manifest form that fits tha
needs of all its users.
The recommendations advocate that
EPA allow the inclusion of additional
State information on the form, modify its
design to allow for a larger special
handling instruction box. and eliminate
the continuation sheet In addition, the
issue of State printing and distribution
of the uniform manifest form was raised.
Additional Ztate Information. The
States have the authority to request
information from treatment storage or
disposal facilities and generators. Some
States, through ASTSWMO. have
indicated that they ¦desire information
concerning each hazardous waste
shipment beyond that required on ihe
manifest The amendments proposed by
EPA and DOT would prohibit States
from requiring additional information to
be carried with the waste. However, It is
within s State's authority to require that
such information be present at the
designated facility as a condition of
acceptance of the waste. Some States
have indicated that they will require
such a condition in order to obtain this
information.
Therefore, rather than require the
generator to fill out both a manifest and
a State form, the States are proposing
that the uniform manifest be redesigned
to contain optional spaces for the
inclusion of State information.
ASTSWMO's recommendations include
the following:
•	Add spaces for State identification
numbers under the designsted EPA
identification number spaces for
generators, transporter and treatment
storage and disposal faqilibes.
•	Add a space within the
Descrepancy Indication box for the
recording of codes which indicate the
treatment storage or disposal processes
utilized in handling the hazardous
waste.
•	Modify the design of the form to
allow both the weight and volume of the
waste to be easily recorded. Current
Federal regulations only require the
weight or volume to be listed.
The Agency recognizes the need on
the part of the States to obtain certain
information for the efficient
management of their hazardous waste
programs. The adoption of ASTSWMO's
suggestion could benefit industry by
providing the opportunity of meeting all
Federal and State requirements on one
form. However. EPA believes that tha
addition of State information spaces
would complicate the form making it
more difficult for the generator to
comply with Federal manifest
requirements. Generators would once
again be subject to dealing with varying
Information requirements since
individual States would require different

-------
146B
ENVIRONMENT REPORTER
information be filled in ai a condition of
acceptance of the waste at tbe facility.
The purpose of the Uniform
Hazardous Waste Manifest form is to
ease the regulatory burden on
generators and transporters by
providing a uniform format for
informationnecessary for the
transportation of hazardous waste. In
designing the form, the Agency has
striven for uniformity but is well aware
of the advantages of a more flexible
form which contains optional spaces, la
order to design a form that best suits the
needs of its users, the Agency invites
comments on the preferability of a
strictly uniform manifest form (i.e. no
optional spaces included) or form that
could contain additional State
information.
Special Handling Instructions box. In
order to provide room for State
information. ASTSWMO suggested
reducing the number of waste listing
spaces on the manifest from six to four.
This additional space could then be
used to maximize the ares of the Special
Handling Instructions box. Tbe Agency
solicits comments on whether four
spaces are sufficient to list the majority
of hazardous waste shipments on one
manifest and tf the need exists to
maximze the area on the Special
Handi.na Instructions box.
Elimination of the Continuation Sheet
The States also indicated that the
addition of a continuation sheet to the
manifest will significantly complicate
their data management system*. As
noted above, the primary reason for the
inclusion of a continuation sheet was to
eliminate the need for generators,
notably laboratories with many different
waste streams, to fill out multiple
manifests for one shipment. In its latest
series of recommendations, ASTSWMO
has advocated that the Department of
Transportation create classification
codes for various groups of laboratory
waste streams, thereby eliminating the
need for a continuation sheet Creation
of such codes would require rulemaking
action on the part of DOT. EPA believes
that the continuation sheet is a
necessary component of the uniform
manifest form in the absence of such
rulemaking. Comments concerning
classification codes for laboratory waste
should be addressed to DOT.
State Printing and Distribution of
Manifest Forms. A final ASTSWMO
recommendation advocates-the
expansion of the top margin of the
uniform manifest form to provide room
for States to print their names and State
assigned document number. Further,
some Slates have indicated a preference
to print and distribute the manifest
forms because it allows them to print
their own emergency instructions. In
addition. ASTSWMO assets that Stat*
document numbers are necessary for the
effective use of any automated State
manifest tracking system.
EPA and*DOT are concerned that the
implementation of this recommendation
could result in situations in which the
generator may be required to fill out
multiple manifests for one shipment. A
generator shipping his waste interstate
could be required by his State to use its
printed manifest form and also be
required to use the destination State's
form as a condition of acceptance of the
waste by the TSD facility. This type of
Interference with the transport of
hazardous waste is what the uniform
manliest form was designated to
prevent. Comments on the desirability of
State printing and distribution of forms
are requested.
V. Classification
EPA has determined that today's
proposed rule will not result in: an
annual effect on the economy of SI00
million or more: a major increase in
costs or prices for consumers, individual
industries. Federal. State, or local
government agencies, or geographic
regions; or significant adverse effects on
competition, employment investment,
productivity, innovation, or the ability of
United StatesJbased enterprises to
compete in domestic or export markets.
Today's action is expected to reduce tbe
current burden on the regulated
community. Therefore, today's proposed
rule is not subject to the major rule
provision of the Executive Order 12231
and a regulatory impact analysis is not
required.
The Uniform Hazardous Waste
Manifest is subject to the OMB
clearance requirements of the
Paperwork Reduction Act of 1980. Hie
Agency has already received clearance
for tbe information requirements of the
manifest system. If. on the basis of
comment the Agency revises the form to
include additional information
requirements that would increase the
information burden of the regulatory
community, the form will be resubmitted
to OMB far clearance.
Furthermore, this proposed rule, if
adopted, would not have a significant
impact on a substantial number of small
entities, thereby triggering the
requirements of the Regulatory
Flexibility Act Tbe required use of a
Uniform Hazardous Waste Manifest will
reduce the burden faced by regulated
hazardous waste generators and
transporters, including small businesses
as defined by that AcL Since the cost to
industry due to the manifest form is
realized largely in terms of labor costs
and labor is a large percentage of small
business's cost the uniform manifest
should provide small businesses with
significant relief. Accordingly. J certify
pursuant to 5 U.S.C S COT etsea. that
the proposal, if promulgated, wiil not
have a significant economic impact on
small entities.
This proposal regulation waa
submitted to the Office of Management
and Budget for review as required by
Executive Order 12291. Any written
comments from OMB to EPA and any
EPA response to those comments are.
available farrpubbc Inspection at the
Office of Solid Waste Docket Room
2636. US. EPA. M St SW. Washington.
DC. 20460.
VL Request for Comment
EPA invites comments on aD aspects
of the proposed rule and all the issues
discussed in the preamble. AO
comments should be addressed to the
Docket Clerk (see Addresses above) and
should contain specific documentation
in their support
Oatedr'Februaiy 23.1982.
Ann* M. Gorsuch.
Administrator.
Title 40 of the Code of Federal
Regulations is amended as follows:
PART 260—HAZARDOUS WASTE
MANAGEMENT SYSTEM; GENERAL
1.	The authority citation for Part 280
reads as follows:
Authority: Sees. 1000.2002(s). 3001 through
3007, 3010. and 700*. of the Solid Waste
Disposal Act as amended by the Ruoum
Conservation and Recovery'Act of 1876, as
amended (42 VS.C. 890S. 6tt2(«). 6321
through 8927.693a 6874).
{260.10 (Amended)
2.	Section CFR 260.10 is amended by
revising the following definitions to read
as follows:
1260.10 Definitions.
•	•	t	I	«
"Manifest"—means the shipping
document EPA form 8700-22. and. if
necessary. EPA form 6700-22A.
originated and signed by the generator
io accordance with the instructions
included in Part 262, Subpart B.
Appendix II of this Chapter.
"Manifest document number"—means
the EPA identification number assigned
to the generator plus a 5 digit
sequentially increasing number assigned
to the manifest by the generator for
recording and reporting purposes.
PART 262—STANDARDS FOR
GENERATORS OF HAZARDOUS
WASTE
3. The authority citation for Part 2G2
reads as follows:
Authority: Sees. 2002(a). 3001.JOQi3003,
3001 and 3003 of the Solid Waste Disposal
Act. as amended by the Resource
3 12-S2
Published by THE BUREAU OF NATICSAL AFFAIRS. INC.. Washington. D C. 20037
75

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CURRENT DEVELOPMENTS
1469
Coniervation and Recovery Act of 1876. as
amended (42 U.S.C 6912(a). 6921. 6922. 6923,
£924. 6925).
4. Section 262.20 i> amended by
revising paragraph (a) to read a*
follows:
i 262.2© -Ganaral r»qulrem«nU.
(a] A generator who transports or
otters [or transportation. hazardous
waste for oflsite tr&almrnl. storage or
disposal must prepare a manifest on
EPA tons 670CKZ and. tf neoeury,
£PA form S700-22A according to the
instructions tnfchided in the Pari 262.
Subpart B. Appendix n of this Chapter.
• •_ • • » -
12S221 fRvsmwdJ
S. 40 CFR 262 it amended by removing
and reserving § 26221.
6- Section 282.50 Is amended by
revising the introductory text of
paragraph (b)(3) and the introductory
text of pvnpvpk (d) to md ei folfowt:
{ 262.50 international shipments. -
• * • « «
w-
(J) Ilaet the nfuiiwii»iil>i ender
282.20(a) for the manifesto except that:
t	•	I	•	«
(d) When importing hazardous vrsste
¦ l^earun tmrat meet all t&e acquirements
specified in 252^01 a) loctfhe manifest
except (hat
7. Part 262 is amended iy adding a
new Appendix to read aafoQsws:
Appendix—Uniform Huubui Waal*
Mudm fCFA forms C7DO-5S and ZTtQ-ZZA)
miiMG COOC SMO SO II
UNIFORM HAZARDOUS WASTE MANIFEST
k • i»lTC tvM (13	»•>
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1470
ENVIRONMENT REPORTER
t -1* C¦¦¦>¦) m (EPA r«m 83W-
22)
Generator Name and Mailing Address
En I or yaur company s name and mailing
addreaa. 'Enter a (tuepocne nutnber where a
knowledgeable person may be reached who
can information in response to an
emergency.
Manifest Document Number
EPA ID.Vumber
Entsr yoar SPA CD number in the 12 spaces
to the left of ths vertical line. In the apace to
the right-of tbrs ime.enter« fiie-digit
aequentMiUf ¦-niiiin «ua>bar of tout
¦choice.
Transporter *1
Ents the name and EPA ID Number of tht
company you will use to be the first
transporter.
Transporter *2
If than is a cocoad transporter «olar (be
name and EPA ID Nutnber of the company.
Space for additional transporters is provided
on the Continuation Sheet [EPA form-B700-
22A)
Treatment. Storage or Disposal Facility
Enter the mme. address. tclephurg number
and EPA ID Number of the treatmerC. storage
or disposal facility to which you are fending
the wana.
Proper VS. DOT Shifting Name and Horard
Oast
Enter die proper DOT shipping nam* tor
the material. The U.S. DOT (Department of
Transportation) regulations will help in
completing this part You can find these
regulations in Title 46 of the Code of Federal
Regulations ftfi CFR Pan VQ
UN/NANumbe.
Enter the UYfUoited Nations) or MA
(North American) number far each waste
aconrding to Tills C9CFX fart 1/4.101.
Enter the amount of each waste you are
•htppia'g. and the appropriate abbreviation
irom Table I below {or either the weight or
the volume of each wajtr you axe shipping-
Table I
C»f>UOB
Pa pound
T>toa
V" cubic yanl
L-lifcr
K-kilograai
N«m»tnc ua
M«cubicaetar
Container Number and Type
Enter the number of containers for each
entry, and the appropriate abbreviation for
the type otf each container you are using from
Table U below.
Tabic D
DM-Metal drums, barrets, kegs.
DW—Weodta drums. Ixnth. fcejs.
DF«Fiberboard or plastic drums. barrels.
kega.
PT« Portable tank*.
CT"Cargo tanks (tank cam).
TC«Tank car.
CY »C*'liad«-s.
CM ^Melal boxes, cartons, cases.
CW—Wooden boxes, cartons, cases.
CF—Fiber or plastic boxes, cartons, cases.
BAw8«ga «ade of feorlfrp. ctoth. paper, or
plastic.
Waste Ma. (Optional)
Tor your own recordkeeping purposes, you
may enter the Federal or State Hszardoua
Waste Number for each waste you are
shipping. Additional space for Proper U.S.
DOT Shipping Descriptions are available on
the Guutiimalma Skcet (EfA Fata 6TW-2IAJ.
Special Handling Instructions
Ester any special handling instruction!
here. You may use this space to enter tbe
name, address and tcirpliranc number of any
alternate trentrrnn- stor«Mro>r'di«paMai
facility.
Certification Statement
Sign and type or print youor full name Enter
the date voa snip the awe fin the toiei to
the ngnt). If continuation sheets are required,
indicate this by placing ata "X" in tht box.
Then indicate the numberarf additional
continuation ariegts in tbe apace pnnjded.
Inatructions for Tranaportaoa:{D!A ftra
8700-22)
Transporter I Certification Statement
Sign and pnnt or type yourijull name
acknowledging that you received the
materials described by the .generator an the
uiawitjt. true: the tsvte of receipt tr t>e
bones to the nght.
Transporter S CertiTicotiac Statement
Sign and pnnt or type iw full name
acknowledging that you reccwed the
materials dmchbed om 
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CURRENT DEVELOPMENTS
1471
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78

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1472
ENVIRONMENT REPORT
Initraetioni for Cootiaua&oo Sboet (HP A
Form 87DO-22A)
intiruciiont for Generator (EPA Form 6790-
Z2.V
77iij ii Continuation Sheet of
Fill-in the spaces with the appropriate
numbers.
Manifest Document Number
EPA ID Number
Enter the tame number here that appear*
on the first page of the manifeit (EPA Form
B700-Z2).
Transport**
II. you require more than two transporter*
to complete the shipment of the tmrardoua
watte described od this manifest enter the
name ud EPA LD. Number of each is the
order ia which (hey will transport the watte.
Be sure to indicate io the space following the
worii "Transporter" their order of carriage of
the wade. (e.g. 3rd 4th etc.)
*roper US DOT Shipping Nam* and Hazard
Clou
If yen require additional apace to hat the
barardous waates detenbed by this manifest,
enter the appropriate information her*. I See
Instructions for Generator* (EPA Fcra 6700-
Z2)J
Instructions for Transporter* (EPA Farm
i7C0-£ZA)
Sign and print or type your full name to the
appropriate ipace. For example, if your are
the third transporter, put a "3" In the space
following the word "transporter". With your
signature you acknowledge that you received
the materials described by tne generator oa
the manifest. Enter the date of receipt «n the
boxes to the nght.
PART 123—STATE HAZARDOUS
WASTE PROGRAM REQUIREMENTS
8. The author ty citation for Part 123
reads at follow*:
Authority; Resource Conservation and
Recovery AO. 42 U.S.C. 690] et seq^ Safe
Drininng Water Act 42 U.S.C. 300(0 et »«).;
and Qean Water Act. 33 U.S.C. 1251 et «eq.
S. Section 123.4 it amended by
revising the text preeeeding the note in
paragraph (d) to read as follows:
| 12X4 Program description.
• • « • •
(d) Copies of the permit form(s),
application form(s) and reporting
form(s) the State intends to employ in its
program. Forms used by the States need
not be identical to the forms used by
EPA but should require the same basic
information, except in two cases. State
NPDES programs are required to use
standard Discharge Monitoring Report*
(DMR) and State RCRA programs must
require the use of EPA manifest forma
8700-22 and 8700-22A. The State need
not provide copies of uniform national
forms it intendj to use but should note
Its intention to use such forms. Stat*
section 404 application forms must
Include the information required by
i 123.94 and State section 404 permit
forms must include the information and
conditions required by i 123.97.
• • « • •
10. Section 123.34 is amended by
revising paragraph (f)(1) and removing
paragrapn (h) to read as follows:
112134 Requirements for generators of
hazardous waste.
t •	I	t	•
(*)••*
(1) Use a manifest system that ensures
(hat interstate and intrastate shipments
of hazardous waste are designated for
delivery, and. in the case of intrastate
shipments, are delivered to facilities
that are authorized to operate under aa
approved State program or the Federal
program. The manifest system must
include the required use of EPA manifest
forms 6700-22 and 8700-22A. No other
manifest form, shipping document, or
additional information may he requn
by the State to travel with the snipm
•	•	•	t	•
11.	Section 123.124 is amended by
revising paragraph (d) to read as
follows:
{ 12X124 Program description.
•	• • « •
(d) Copies of the forms that the Stat
intends to use in its program. Except f<
the required use of EPA manifest form
8700-22 and E700-22A. forma used by
the State need not be identical to the
forms used by EPA but should require
the same basic information. If the Stati
chooses to use uniform national forms
should so note.
« « • » •
12.	Section 123.128 is amended by
revising paragraphs fb)t")(i) and (c)(5) t|
read as follows:
1123.121 Program requirements for
Interim authorization for Pnase 1.
• • • • •
fl>»* * *
n * * *
(i) A generator who transports or
offers for transportation, hazardous
waste for offsite treatment or storage or
disposal must prepare a manifest on
EPA form 8700-22. and if necessary EPA
form 8700-2ZA. in accordance with the
instructions included in Part 282.
Subpart B Appendix U of this chapter
• • • •
(c) * • *
(S) The State program must requin
that transporters carry the manifest
(prepared on EPA form 8700-22 and if
necessary EPA form 8700-22A) with all
shipments, except in th(Tease of
shipments by rail or water specified in
40 CFR i 283.20(e) and (f).
•	*	t	t	«
in Doc. as-Maa FW4 a«i ua|
HUMO cooc esas aa-M
79

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