United States Solid Waste and EPA530-R-99-025
Environmental Protection Emergency Response NTIS: PB99-156 002
Agency (5305W) April 1998
EPA Background Document
for Analysis of the
Land Disposal
Restrictions-Phase IV:
Underground Injection
Data and Issues
Printed on paper that contains at least 30 percent postconsumer fiber
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Background Document for Analysis of the
Land Disposal Restrictions - Phase IV:
Underground Injection Data and Issues
Office of Ground Water and Drinking Water
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
April 1998
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[This page intentionally left blank.]
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TABLE OF CONTENTS
1.0 INTRODUCTION 1
1.1 Organization of Background Document 1
1.2 Legal Background 2
1.2.1 Land Disposal Restrictions 2
1.2.2 Toxicity Characteristic Metal Wastes 3
1.2.3 Mineral Processing Wastes 6
1.2.4 Phase IV Rulemaking 6
1.2.5 Types of Wastes Covered by the Phase IV LDRs 7
2.0 UNIVERSE OF INJECTED PHASE IV WASTES 11
2.1 Affected Class I Universe 11
2.2 Facilities Injecting Phase IV Wastes 12
3.0 LDR EXEMPTIONS 21
3.1 Land Disposal Program Flexibility Act (LDPFA) Exemptions 21
3.2 No-Migration Petitions 22
4.0 PHASE IV WASTES PROHIBITED FROM INJECTION 25
4.1 Newly Identified TC Metals Wastes 25
4.2 Newly Identified Mineral Processing Wastes : 26
5.0 CAPACITY DATA AND ISSUES 29
5.1 On-site Management 29
5.1.1 Dupont - New Johnsonville 29
5.1.2 Dupont - DeLisle 29
5.2 Off-site Management 29
5.2.1 Transport to Off-Site Management 30
5.2.2 Availability of Commercial Injection Capacity 30
5.2.3 Availability of Commercial Treatment Capacity 30
6.0 SUMMARY 33
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LIST OF EXHIBITS
Exhibit 1-1 Summary of Previous Land Disposal Restrictions Rulemakings
Exhibit 1-2 Existing and Final UTS Levels (Non-Wastewater Metals)
Exhibit 2-1 Class I Underground Injection Wells
Exhibit 4-1 Facilities Injecting TC Metal Non-Wastewater
. 4
. 5
13
27
LIST OF APPENDICES
Appendix A - Methodology for Identification of Facilities that Potentially Inject Phase IV Wastes
Appendix B - Methodology for Estimation of the Volume of Phase IV Waste Managed
by Underground Injection
Appendix C - Phase IV Wastes Prohibited from Injection
Appendix D - Estimate of Time Required to Build an Acid Waste Treatment System
Appendix E - Alternative Treatment and Injection Capacity
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1.0 INTRODUCTION
This document presents data and issues related to the effects on underground injection
from the Land Disposal Restrictions (LDR) - Phase IV: Treatment Standards for Newly
Identified Mineral Processing Wastes and Toxicity Characteristic Metal Wastes. In this rule,
EPA is promulgating LDRs for the newly identified mineral processing wastes and toxicity
characteristic metal wastes that have not been covered in previous LDR rulemakings. In
addition, this rule makes changes to the Universal Treatment Standards (UTS) for non-
wastewaters for selected metals requiring certain wastes covered in previous LDR rulemakings to
meet more stringent treatment requirements for some metal underlying hazardous constituents
(UHCs).
EPA compiled this information to evaluate the impact of the Phase IV LDRs on
underground injection of hazardous wastes and the need for national capacity variances from the
land disposal prohibitions.1 This document provides estimates of the quantities of wastes that
will require alternative commercial treatment prior to land disposal as a result of the LDRs and
estimates of alternative commercial treatment capacity available to manage wastes restricted
from land disposal.
1.1 Organization of Background Document
This document is organized as follows:
• Section 1 - Introduction provides (1) background on the legal basis for
the LDRs and capacity variance determinations, (2) background on the
newly identified mineral processing wastes and newly identified toxicity
characteristic metal wastes, and (3) a description of the types of wastes
potentially affected by the Phase IV rule;
• Section 2 - Universe of Injected Phase IV Wastes provides background
on the underground injection control (UIC) program Class I well universe,
identifies facilities potentially injecting Phase IV wastes, and provides
estimates of the volume of Phase IV wastes being injected in Class I wells;
• Section 3 - LDR Exemptions provides background on the exemptions to
LDRs, analyzes the effect of exemptions on capacity, and identifies
injection facilities that are exempt from the LDR prohibitions;
'The LDRs are effective when promulgated unless the Administrator grants a national capacity variance
from the otherwise applicable data and establishes a different date (not to exceed two years beyond the statuary
deadline) based on: "... the earliest date on which adequate alternative treatment, recovery, or disposal capacity
which protects human health and the environment will be available" (RCRA Section 3004(h)(2)).
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• Section 4 - Phase IV Wastes Prohibited from Injection provides EPA's
methodology and documentation for identifying and quantifying wastes
restricted from injection by the Phase IV rule;
• Section 5 - Capacity Data and Issues provides documentation and
analysis of the availability of on-site and off-site alternative treatment and
injection capacity;
• Section 6 - Summary discusses the major categories of injected waste
affected by the Phase IV rule and the availability of alternative treatment
and injection capacity for underground injection facilities subject to the
Phase IV rule.
Several Appendices are included that provide additional detail and supporting data for these
sections.
1.2 Legal Background
1.2.1 Land Disposal Restrictions
The 1984 Hazardous and Solid Waste Amendments (HSWA) of the Resource
Conservation and Recovery Act (RCRA), enacted on November 8, 1984, set basic new priorities
for hazardous waste management. Land disposal became the least preferred waste management
option. Under HSWA, EPA must promulgate regulations restricting the land disposal (including
underground injection) of hazardous wastes according to a strict statutory schedule. As of the
effective date of each regulation, land disposal of waste covered by that regulation is prohibited
unless: (1) the waste meets the treatment standards that have been established; or (2) it can be
demonstrated that there will be no migration of hazardous constituents from the disposal unit for
as long as the waste remains hazardous. Under the LDR Program, EPA must identify levels or
methods of treatment that substantially reduce the toxicity of a waste or the likelihood of
migration of hazardous constituents from the waste. The LDRs are effective immediately upon
promulgation unless the Agency grants a national capacity variance from the statutory date
because of a lack of available treatment capacity (see RCRA section 3004(h)(2)). For every
waste, EPA considers—on a national basis—both the capacity of commercially available
treatment technologies and the quantity of restricted wastes currently sent to land disposal for
which on-site treatment capacity is not available. If EPA determines that adequate alternative
commercial treatment capacity is available for a particular waste, the land disposal restriction is
effective immediately. If not, the Agency establishes an alternative effective date based on the
earliest date on which adequate treatment capacity will be available or two years, whichever is
less. During the variance period, management of the wastes is still subject to specific, though
less restrictive, land disposal requirements (40 CFR 268.5(h)). Once the variance expires, the
wastes must meet the LDR treatment standards prior to being disposed.
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^ICF
CONSULTING GROUP
ICF incorporated
9300 Lee Highway
Fairfax. VA 22031-1207
703/934-3000 Fax 703/934-9740
MEiMORANDUM October 9. 1997
TO: Robert E. Smith
FROM: Debra Favre and Jim Laurenson
CC: Howard Finkel
SUBJECT: Progress Update - Class I Injection Well Study in Support of Phase IV Rule
In response to the August 4, 1997 Technical Directive (TD) that ICF received from EPA
under Work Assignment 0-11 of EPA Contract No. 68-C6-0026, this memorandum presents a
summary of our progress on preparation of an exhaustive study of the Class I injection well
facilities that may be managing Phase IV Land Disposal Restrictions (LDR) wastes. Throughout
this memorandum, we address each of the 13 subjects listed in the TD. (As we discussed, we
have addressed these subjects in a slightly different order to facilitate a process-of-elimination
approach to this analysis.) This memorandum is organized into four sections: Introduction;
Methodology; Preliminary Results; and Next Steps. We expect that expanded versions of these
sections will form the basis of the final report of the analysis. Please call Debra Favre at (703)
934-3677 or Jim Laurenson at (703)934-3648 if you have any questions or comments on this
memorandum.
INTRODUCTION
The 1984 Hazardous and Solid Waste Amendments (HSWA) of the Resource Conservation
and Recovery Act (RCRA) enacted on November 8, 1984, set basic new priorities for hazardous
waste management. Land disposal became the least preferred waste management option. Under
HSWA, EPA must promulgate regulations restricting the land disposal (including underground
injection) of hazardous wastes according to a strict statutory schedule. As of the effective date of
each regulation, land disposal of waste covered by that regulation is prohibited unless (1) the
waste meets the treatment standards that have been established, or (2) it can be demonstrated that
there will be no migration of hazardous constituents from the disposal unit for as long as the
waste remains hazardous. Under the LDR Program, EPA must identify levels or methods of
treatment that substantially reduce the toxicity of a waste or the likelihood of migration of
hazardous constituents from the waste. The LDRs are effective immediately upon promulgation
unless the Agency grants a national capacity variance from the statutory date because of a lack of
available treatment capacity.
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HSWA's schedule divided hazardous wastes into three broad categories: solvent and dioxin
wastes; California listed wastes: and "scheduled" wastes. LDR rulemakings for these three broad
categories were completed by EPA by May 1990. For hazardous wastes that are identified or
listed after November 8, 1984 ("newly identified wastes"), rulemaking has proceeded in phases
based on the requirement to promulgate land disposal prohibitions within six months of the date
of identification or listing. However, the statute does not provide an automatic prohibition of
land disposal of such wastes if EPA fails to meet this deadline.
In May 1980, the Agency promulgated the final rule on the use of the Extraction Procedure
(EP) toxicity test to identify a waste that poses a significant hazard due to its potential to leach
significant concentrations of hazardous constituents. Metal and organic constituents were
identified that, if present in the EP waste extract in excess of a specified concentration, cause the
waste to be identified as hazardous (EP Toxic). After several revisions to the existing hazardous
waste identification regulations, EPA finalized the Toxicity Characteristic (TC) rule in March
1990. This rule replaced the EP leaching test with the Toxicity Characteristic Leaching
Procedure (TCLP). Since promulgation of the TC rule, the TCLP has been used to determine the
toxicity of characteristic metal waste. A waste that is characteristic by the TCLP but not by the
EP is considered a newly identified waste and currently is not subject to LDRs.
Under Section 8002 of RCRA, commonly referred to as the Bevill Amendment, wastes from
extraction, beneficiation, and mineral processing operations were excluded from regulation as
hazardous wastes under Subtitle C pending further study. The Agency completed its study of
extraction and beneficiation wastes in 1985, and issued a regulatory determination in 1986 that
removed these wastes from Subtitle C regulation. The Agency established criteria for what
constitutes a special waste in September 1989, and these special wastes were excluded from
Subtitle C requirements. The Agency's study of mineral processing wastes was completed in
June 1990, and it focused on high-volume, low-hazard wastes referred to as special wastes. All
but 25 mineral processing wastes were permanently removed from the Bevill exclusion. Five
more wastes were later removed from the exclusion leaving 20 mineral processing wastes in the
special waste category. All wastes removed from the Bevill exclusion and found to exhibit any
of the RCRA hazardous characteristics became newly identified wastes subject to RCRA Subtitle
C requirements; these wastes are not currently subject to LDRs.
On December 6, 1990, wastewaters, process residuals, preservative drippage, and spent
formulations from wood preserving processes generated at plants that currently use or have
previously used chlorophenolic, creosote, or inorganic arsenic-containing or chromium-
containing preservatives became listed hazardous wastes subject to Subtitle C regulation. LDR
rulemakings for these newly listed wastes were grouped with TC metals and mineral processing
wastes initially. However, EPA finalized treatment standards for wood preserving wastes
separately on May 12, 1997 (62 FR 25998), and these wastes currently are subject to LDRs.
The final Phase IV rule is part of a collection of rules to establish treatment standards for
newly listed and identified wastes that were proposed in five previous Federal Register notices.
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• Phase IV Proposal - August 22. 1995 (60 FR 43654. Issues Associated With Clean Water
Act Treatment Equivalency, and Treatment Standards for Wood Preserving Waste and
Toxicity Characteristic Metal Wastes
• Phase IV First Supplemental Proposal - January 25. 1996 (61 FR 2338). Clarification of
Bevill Exclusion for Mining Wastes, Changes to the Definition of Solid Waste For Mineral
Processing Wastes, Treatment Standards for Characteristic Mineral Processing Wastes, and
Associated Issues
• Phase IV Notice of Data Availability - May 10. 1996 (61 FR 214171. Issues Associated With
Clean Water Act Treatment Equivalency, and Treatment Standards for Wood Preserving
Wastes and Toxicity Characteristic Metal Wastes
• Phase IV Second Supplemental Proposal - May 12. 1997 (62 FR 26041). Second
Supplemental Proposal on Treatment Standards for Metal Wastes and Mineral Processing
Wastes, Mineral Processing and Bevill Exclusion Issues, and rhe Use of Hazardous Waste as
Fill
• Phase IV Notice of Data Availability - November 10. 1997 (62 FR 60465). Second
Supplemental Proposal on Treatment Standards for Metal Wastes and Mineral Processing
Wastes, Mineral Processing and Bevill Exclusion Issues, and the Use of Hazardous Waste as
Fill
The Agency proposed LDR treatment standards for Phase IV wastes at various levels in these
rules. After considering public comment on the rules and reviewing additional data, EPA
proposed, in the Phase IV Second Supplemental Proposal, final treatment standards for 14
underlying hazardous constituent (UHC) metals. We summarize below the current status of the
UTS for the metal UHCs:
• Arsenic will remain the same as the current level and at the TC level;
• Mercury is lower than TC level but the same as the current level;
• Four of the UTS (antimony, total chromium, silver, and zinc) are lower than TC levels and
lower than the current UTS;1
• Seven of the UTS (barium, beryllium, cadmium, nickel, lead, thallium, and vanadium) are
lower than TC levels and higher than the current UTS; and
• Selenium is higher than the TC level and higher than the current UTS.
' Based on recent Office of Solid Waste (OSW) meetings, however, antimony and silver may be finalized at levels
higher than proposed in the Phase IV Second Supplemental Proposal.
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STUDY METHODOLOGY AND INFORMATION SOURCES
General Approach
Our general approach to preparing a Class I injection well study to support the Phase IV rule
regulatory impact analysis (RIA) and assess the need for a national capacity variance for Class I
wells subject to the LDRs, is to first eliminate from the analysis facilities that will not change
management practices as a result of the Phase IV rule. Thus, we narrow the focus to those wells
that would be significantly impacted by the rule. The study will proceed in two stages: (1)
identify facilities significantly impacted by the Phase IV rule: and (2) analyze the availability of
alternative treatment and injection capacity. This approach addresses the items specified in the
TD in a different order than requested. Therefore, for clarity, the steps in our approach are
described below indicating which item from the TD they address. We are currently completing
the first stage (A). These findings are presented in the Preliminary Results section. We will
proceed with the second stage (B), after the results of the first stage of the study are finalized and
outstanding issues are resolved.
A. Identification of Entities Managing Wastes by Underground Injection Potentially Affected bv
the Phase IV LDRs
1. Identify the types of wastes covered by the Phase IV LDRs.
(Addresses, in part, item 8 of the TD)
2. Identify facilities that manage of Phase IV wastes by underground injection.
(Addresses items 1, 2, and the remainder of 8 of the TD)
3. Identify facilities with LDR exemptions.
a) Determine which wells inject hazardous characteristic wastes that are exempt
from the Phase IV LDRs because of the Land Disposal Program Flexibility Act
(LDPFA) of 1996.
(Addresses item 12 of the TD)
b) Determine which wells inject Phase IV wastes and have an approved no-migration
petition.
4. (Addresses item 9 of the TD)
5. Identify facilities without a no-migration petition covering Phase IV wastes or a
LDPFA exemption.
(Addresses items 6 and 7 only for sites that are subject to the Phase IV land ban)
B. Analysis of the Availability of Alternative Treatment or Injection Capacity
1. Determine which facilities and generators managing Phase IV wastes in Class I wells
subject to the Phase IV land ban (those without a no-migration petition or LDPFA
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exemption) have on-site treatment capacity to meet the Phase IV treatment levels or
can recycle or recover the waste eliminating the need to dispose by underground
injection.
(Addresses items 3, 5, and 11 of the TD)
2. Determine the existence of adequate alternative off-site commercial treatment
capacity for facilities and generators managing Phase IV wastes in Class I wells
subject to the Phase IV land ban that do not have on-site treatment capacity.
(Addresses item 4 of the TD)
3. Determine the existence of adequate alternative off-site commercial injection capacity
for facilities and generators managing Phase IV wastes in Class I wells subject to the
Phase IV land ban that do not have on-site treatment capacity.
(Addresses item 10 of the TD)
4. Identify any facilities and generators subject to the Phase IV land ban that cannot
eliminate management of their waste by underground injection and have no off-site
commercial treatment or injection alternatives.
Item 13 of the TD specifies that a study be performed to characterize the wood processing
industries' management of wastes by underground injection. We propose that this study be
conducted separately following similar methodology.
Information Sources
Information sources reviewed and identified to date for the Class I injection well study
include the following:
• UICWELLS - Class I Injection Wells Database Version 5 (updated through 1994) provided
by EPA;
• Public Comments to the Phase IV Second Supplemental Proposal;
• EPA, Background Document for Capacity Analysis for Land Disposal Restrictions - Phase IV
(Second Supplemental): Toxicity Characteristic Metals Wastes and Newly Identified Mineral
Processing Wastes (Proposed Rule), April 1997;
• EPA, Background Document - Identification and Description of Mineral Processing Sectors
and Waste Streams, December 1995;
• Federal Register Notices 60 FR 43654, 61 FR 2338, 61 FR 21417, 62 FR 25998, and 62 FR
26041 establishing treatment standards for newly listed and identified wastes.
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PRELIMINARY RESULTS
We are currently completing the first stage of the analysis — the identification of entities
managing wastes by underground injection potentially affected by the Phase IV LDRs. This
section summarizes our preliminary findings and discusses issues that have surfaced that may
affect the completion of the study. We note that some of these findings may be subject to change
as additional information becomes available.
Types of Wastes Covered by Phase IV LDRs
The complex history of proposal, withdrawal, reproposal, and finalization of certain aspects
of the Phase IV LDRs has led to inclusion and exclusion of certain wastes in this rule. For
example, previous analyses of the impact of the rule included wastes not part of the current
proposed rule. Thus, for clarity, the types of wastes regulated by the Final Phase IV rule are
described below.
Newly Identified Mineral Processing Wastes Containing Characteristic Hazardous Wastes. EPA
established definitions and techniques for determining which operations and wastes streams
might be subject to LDRs. The decisions concerning whether individual wastes are outside the
scope of the RCRA Mining Waste Exclusion are based on a number of different factors
discussed in detail in the Agency's background document that describes and characterizes mineral
processing wastes." Determining which mineral processing wastes are de-Bevilled newly
identified hazardous wastes is not a straightforward process. However, in general, a de-Bevilled
newly identified hazardous mineral processing waste has the following characteristics:
• The waste must originate from primary mineral production operations only defined as those
using at least 50 percent ores, minerals, or beneficiated ores or minerals as the feedstock
providing mineral value. (Thus, secondary production of mineral commodities such as
wastes from scrap recycling, metals recovery from flue dust, and similar activities have
always been subject to Subtitle C regulation.)
• The waste must not be one of the 20 special wastes.
• The waste must not originate from the beneficiation and/or extraction as defined by 40 CFR
261.4(b)(7).
• The waste must meet the criteria for characteristic hazardous waste as defined by 40 CFR
261.20.
The Phase IV rule requires these wastes to meet LDR requirements for the first time.
2EPA. Background Document. Identification and Description of Mineral Processing Sectors and Waste Streams.
December 1995.
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Toxicity Characteristic (TC) Metals Hazardous Wastes (D004 - DPI 1). Wastes that were
previously identified as TC metal-only hazardous by the EP — including listed wastes that were
TC metal-only hazardous — and remained TC metal-only or listed and TC metal-only hazardous
after testing with the TCLP were subject to less stringent LDR treatment requirements (i.e.,
treatment down to TC levels) and will be required now to meet more stringent UTS for all UHCs.
A newly identified group of TC wastes, those that were not identified as hazardous by the EP, but
were identified as hazardous by the TCLP, are subject to LDRs for the first time.
Listed Hazardous Wastes with UHCs that Exceed the Revised UTS for Metals. These wastes
previously were subject to LDRs. The Phase IV rule revises the UTS for four UHCs (chromium,
silver, antimony, and zinc) downward, and thus, listed wastes containing these metal UHCs
would be affected by a requirement for more stringent treatment if these metals are above the
revised UTS.
Other Characteristic Wastes (Toxic Organic. Ignitable. Corrosive, or Reactive) with UHCs that
Exceed the Revised UTS for Metals. Wastes identified as hazardous based on the characteristics
of ignitability (D001), corrosivity (D002), reactivity (D003), or organic toxicity (D012-D043)
previously were subject to LDRs. These wastes would only be affected by a requirement for
more stringent treatment if they contain chromium, silver, antimony, and zinc above the revised
UTS.
Facilities Injecting Phase IV Wastes
To identify facilities injecting Phase IV wastes, we reviewed data contained in the
UICWELLS database and examined the types of wastes and concentrations of constituents being
injected at both hazardous and nonhazardous Class I wells. Theses results are presented in the
following sections that describe the Class I universe of wells and the facilities potentially
injecting Phase IV waste by waste type.
Class I Universe of Wells. According to 1994 Agency data, there are a total of 227 Class I
underground injection facilities operating 537 Class I wells. Table 1, at the end of this
memorandum, presents a list of all Class I underground injection facilities and their identification
numbers, and indicates whether they are noncommercial or commercial facilities. Presented
below is a summary of selected characteristics of Class I wells and facilities.
Type of Well
Hazardous
Nonhazardous
Commercial
Hazardous
Nonhazardous
Noncommercial
Total Wells
165
372
60
21
39
469
Type of Facility
Commercial
Noncommercial
Total
Total Facilities
41
186
227
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The final rule will prohibit disposing Phase IV wastes in Class I underground injection wells,
unless the wastes are treated to meet the UTS, the Class I facility has or can successfully petition
for an exemption from the ban, or the waste is exempt per the LDPFA.
Facilities Injecting Newly Identified Mineral Processing Wastes. To identify generators of newly
identified mineral processing wastes (wastes removed from the Bevill exclusion and found to
exhibit RCRA hazardous characteristics), we relied on EPA's 1995 study of mineral commodities
that may produce hazardous wastes as defined by RCRA Subtitle C.3 (Note that this study is
being updated to reflect potential changes in the definition of solid wastes for these wastes, and
therefore, the analysis conducted for this memorandum also may need to be updated at a later
point.) From this study, 128 facilities were identified that generate newly identified mineral
processing wastes. These generators were compared to the 227 operators of Class I underground
injection wells. From this comparison, the five facilities listed below were identified as mineral
processing facilities that appear to be managing newly identified mineral processing wastes by
underground injection. Information regarding the type of facility, number of wells, and waste
source descriptions for these facilities is presented in Table 1.
• DuPont, MS
• Dakota Gasification Company, ND
• Zinc Corporation of America, OK
• DuPont, TN
• Asarco-Amarillo, TX
To identify any mineral processing facilities that may have been overlooked by EPA in its
1995 study, we conducted a series of searches of the UIC database to identify facilities with SIC
codes covering the mineral processing sectors. The waste codes and descriptions entered for
facilities identified in the searches were reviewed to determine if any of the facilities potentially
manage "newly identified" mineral processing wastes by underground injection. All of the
facilities that were identified by using SIC codes were eliminated because they appear to be
Bevill excluded wastes only(i.e., extraction/beneficiation wastes from industries such as mining
and bromine extraction), or the injectate waste source descriptions clearly indicated that all of the
waste was not a mineral processing waste or was nonhazardous.4 At this point, these five
facilities should be considered as only potentially injecting Phase IV wastes. Additional
information on the types and compositions of the wastes being injected and the processes
generating the wastes must be researched to verify that the wastes are Phase IV wastes. The
identification of commercial wells that inject newly identified mineral processing wastes are
discussed below in a separate subsection.
Facilities Injecting TC Metals Wastes. To identify facilities that potentially manage TC metal
wastes by underground injection, we conducted two separate searches on the UIC database: the
3Ibid.
4For injected wastes, the point at which a waste can be determined to be nonhazardous is at the point of injection.
Wastes disposed, treated or stored in other management units must be determined to be nonhazardous at the point of
generation.
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first, for facilities with waste codes (D004-D011); and the second, for facilities with metal
constituents that exceeded the revised UTS. Although under the Phase IV rule, all UHCs in TC
metal wastes would be subject to treatment, in the second search, we used metal constituents as a
way to identify other injected TC metal wastes in the database that may not have a TC metal
waste code. We assumed, in this search strategy, that uncoded TC metal wastes would contain at
least one metal constituent. Waste source descriptions for facilities identified through these
database searches were reviewed and facilities that did not potentially inject TC metal wastes
were eliminated. We found twenty-four facilities that listed a TC metal waste code in their waste
source description, and three additional facilities, based on their waste source descriptions or
constituent data, that likely inject TC wastes. These facilities are listed below and highlighted in
Table 1.
TC Metal Waste Codes
Allied-Signal, Inc., IL
Bethlehem Steel Corp., IN
CECOS International, LA
Rollins Environmental Serv., LA
DuPont, LA
The Upjohn Co., MI
Parke-Davis, MI
BP Chemicals, OH
Monsanto, TX
DuPont-Victoria, TX
Rexene. TX
Hoeschst-Clear Lake, TX
DuPont-Sabine, TX
Disposal Syst.-Corpus Christi. TX
Asarco-Amarillo, TX
Malone Services, TX
CECOS International. TX
Empak, TX
Chemical Waste Management, TX
BP Chemicals, TX
Wastewater, Inc., TX
Disposal Systems, TX
Hoechst-Bishop, TX
Texas Ecologist, Inc., TX
Likely TC Wastes
Koch Underground Storage, KS - Arsenic > TC
Rockwell International, OK - metal finishing rinsewater with UHC > UTS
Loving Disposal, TX - Spent metallic solutions and alkaline wastes, no constituent data
At this point, these 27 facilities should be considered as only potentially injecting Phase IV
wastes. Additional waste information will be required to verify that Phase IV wastes are actually
injected at these facilities and whether additional treatment would be required to meet UTS for
all UHCs.
Facilities Injecting Listed Hazardous Wastes With Metal UHCs. The Phase IV rule may revise
the UTS for four UHCs downward, affecting some listed wastes already subject to previous
LDRs. However, for many of these wastes, adjustments to meet the new treatment levels likely
will be minor, and meeting the land ban deadline may not be a hardship. Nevertheless, to
identify facilities that manage listed wastes with UHCs above the Phase IV land ban levels, we
conducted a search of the UIC database for facilities that had any of the 12 metal constituents
addressed by the Phase IV rule above UTS. This search was expected to be over-inclusive, since
only four of the metal UTS were revised downward (and to comply with previous LDRs the other
eight metal constituents should already have been treated to UTS unless the facility has an LDR
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exemption or extension). Nevertheless, searching for all 12 constituents had the added benefit of
verifying that our assumptions regarding compliance with previous LDRs were correct. Based
on the database search, the following eight facilities were identified with listed wastes containing
metal constituents above UTS. The waste codes in the database for Bethlehem Steel also
indicate that TC wastes are injected at this facility. Table 1 also highlights these facilities.
Listed Waste Code With Metal UHC > UTS
LTV Steel Co., IL
Bethlehem Steel Corp., IN
Midwest Steel, IN
AK Steel Co., OH
Chemical Waste Management, OH
Likely Listed Waste With Metal UHC > UTS*
Hoskins Manufacturing Co, IN - Neutralized waste pickle liquor (possibly K062 wastes)
Vulcan Chemical, KS - Organic chemical production (possibly K071 or K106 wastes)
Hoskins Manufacturing Co, MI - Neutralized waste pickle liquor (possibly K062 wastes)
Mackanburg-Duncan, OK - Aluminum anodizing wastewaters, zinc plating wastewaters
(possibly F006-F009 wastes)
*There are no waste codes in the database for these facilities, and they are identified as likely
to be listed wastes based on waste descriptions.
Facilities Injecting Other Characteristic Hazardous Waste With Metal UHCs. As discussed
above for listed wastes, some characteristic hazardous waste may require additional treatment to
meet the land ban. To identify facilities that manage hazardous characteristic wastes — other than
newly identified hazardous mineral processing wastes — that may require additional treatment,
we searched for facilities with wastes codes D001-D003 and D012-D043 with metal constituents
above UTS. Careful review of source description data, waste codes, and constituent data for
facilities from the database search identified the following facilities as potentially managing other
characteristic hazardous waste with metal UHCs above UTS. Table 1 also highlights these
facilities.
D001-D003. D012-D043 with UHC >UTS
Kaiser Al, FL
Bethlehem Steel, IN *
Rollins Environmental Serv., LA *
CECOS International, LA*
DuPont, LA*
The Upjohn Co., MI*
Parke-Davis, MI*
BP Chemicals, OH*
Monsanto, TX*
DuPont-Victoria, TX*
Hoechst-Bay City, TX
Rexene, TX*
DuPont-Sabine, TX*
Disposal Systems-Corpus, TX*
Asarco-Amarillo, TX*
Malone Services, TX*
Empak, TX*
BP Chemicals, TX*
Wastewater, TX*
Disposal Systems,TX*
Hoechst-Bishop, TX *
Texas Ecologist, TX*
*Co-dispose with TC metal wastes.
10/9/97
Paae 10
-------
Other Class I Facilities That May Manage Phase IV Wastes in Class I Wells. There may be other
Class I facilities that manage Phase IV wastes; however, because of incomplete waste code,
description, or constituent data in the database, they have not been identified. We will attempt to
identify these facilities, if they exist, by searching the 1995 Biennial Reporting System (BRS),
which is EPA's tracking system for hazardous waste generation and management.
Facilities That Generate Phase IV Wastes and Manage the Wastes Off-site in Commercial Class I
Wells. Facilities that generate Phase IV wastes and manage the wastes off-site at commercial
underground injection facilities cannot be identified by reviewing the UIC database because the
database does not identify the generator of specific waste streams injected in commercial wells.
We will identify these facilities by searching the BRS for wastes received at specific commercial
underground injection facilities. We will narrow the BRS search by focusing on those
commercial facilities that do not have an approved no-migration petition. This strategy assumes
that commercial facilities with approved no-migration petitions will not require modification to
cover Phase IV wastes, and therefore are exempt from the LDRs. The following section
discusses no-migration petitions in more detail. Commercial wells with no-migrations petitions
will be evaluated for available capacity during the second stage of this analysis.
Facilities With LDR Exemptions
Hazardous waste underground injection restrictions are codified in 40 CFR, Part 148. These
regulations set dates for the prohibition of underground injection of hazardous wastes in Class I
injection wells. Wastes otherwise prohibited from injection may continue to be injected under
the following circumstances.
• An extension from the effective prohibition date is granted. The extension may be in the form
of a capacity variance or a case-by-case extension.
• An exemption from a prohibition is granted in response to demonstrating no migration of the
injected restricted waste.
• The restricted waste is generated by a conditionally exempted small quantity generator.
• Wastes that are hazardous only because they exhibit a hazardous characteristic, if
decharacterized, are not prohibited from injection in either a Class I hazardous or
nonhazardous well. (This exemption was authorized by the Land Disposal Program
Flexibility Act).
The circumstances in which treatment of Phase IV wastes is not required prior to injection in
a Class I well are discussed in detail below.
Land Disposal Program Flexibility Act (LDPFA) Exemptions. The LDPFA provided an
exemption from treatment of UHCs to UTS for wastes that are hazardous only because they
exhibit a hazardous characteristic (D001-D043), if the wastes are decharacterized and managed
by Class I underground injection. The waste may be diluted to remove the characteristic prior to
10/9/97
Page 11
-------
injection. We identified three facilities that inject hazardous characteristic (D001-D043) wastes
only that could be exempt from the LDR requirements, if the wastes are decharacterized before
injection.
• Kaiser Aluminum & Chemical Co., FL -D002 waste
• Parke-Davis, MI - D004-D011, DO 18, D035
• Hoechst - Bay City, TX - D001 and D002 wastes
The remaining facilities, however, also may be injecting wastes that are characteristic only at the
point of generation (rather than characteristic and listed). These wastes also would be exempt
under the LDPFA.
No-Migration Petitions. Disposal of hazardous waste by underground injection is banned unless
the operator demonstrates that the waste will not migrate from the injection zone for as long as
the waste remains hazardous. EPA promulgated standards in July 1988 describing how no
migration could be successfully demonstrated. EPA requires operators to show that wastes will
remain totally confined in the injection zone for at least 10,000 years. Alternatively, operators
may demonstrate that the waste will decompose or otherwise be attenuated in the injection zone
so that it is no longer hazardous. The information demonstrating no migration is submitted to
EPA in a petition. An approved no-migration petition is waste and unit specific, and becomes
the basis for granting an LDR exemption. Thus, to modify a petition to grant a LDR exemption
for additional wastes not included in the petition, the operator must demonstrate that the new
wastes will neither migrate from the injection zone nor affect the containment of wastes
previously granted an LDR exemption.
Operators who have either submitted timely no-migration petitions or modifications to no-
migration petitions for exemption from the Phase IV LDRs might not have their petitions
approved in time to avoid the effective prohibition date due to the lengthy procedures required to
process petitions. To provide relief from the need to shut down or curtail their operations, EPA
may grant a case-by-case capacity extension. To be granted a case-by-case extension, the
operator must demonstrate that a binding contractual commitment has been made to construct or
otherwise provide alternative treatment, recovery, or disposal capacity that protects human health
and the environment. EPA has interpreted disposal capacity to include a no-migration unit. Any
extension applies only to waste generated at an individual facility and precludes granting a case-
by-case extension to commercial injectors. Scenarios involving Phase IV rule wastes managed
by underground injection where a case-by-case extension might be requested include the
following.
• Some non-commercial facilities with an approved no-migration petition for hazardous wastes
other than Phase IV wastes may currently inject Phase IV wastes. Once the land ban goes
into effect, these facilities would have to submit a petition to modify their no-migration
petitions to include Phase IV wastes. A case-by-case extension might be requested if the
petition modification could not be granted in time to avoid the Phase IV land ban. However,
the number of facilities that might fall within this category is likely to be small, because many
of the facilities that have approved no-migration petitions are likely to have already included
10/9/97
Page 12
-------
EXHIBIT 2-1
CLASS I UNDERGROUND INJECTION WELLS
Facility ID #:
Facility Name
Number
of Wells
Type
No-Mlgratlon
Petition Status
Potentially
InJectB Phase
IV Wastes
Explanation/Comment
Prohibited
From Injection
(see notes 1,2)
AKD991281221
ARCO Alaska Inc. Prudhoe Bay Operations
3
c
None
no
AR10-U
Great Lakes Chemical Corp. (South Plant)
4
NC
None
no
AR2-U
Great Lakes Chemical Corporation
4
NC
None •
no
AR4-UR1
Albemarle Corporation
4
NC
None
no
AR5-U
Great Lakes Chemical Corp. Newell Plant
2
NC
None
no
AR8-U
Red River Aluminum, Inc.
1
NC
None
no
AR9-U
Great Lakes Chemical Corp. (West Plant)
2
NC
None
no
AR?-U
Ethyl Corporation (Magnolia)
UNK
NC
Approved
yes
Organic solvents,
organoarsenlc
compounds, likely K
waste w/ metal UHCs
no
CA191000001
Zonal Holding Corporation(Envrwlls)
1
C
None
no
CA192000001
SMS Briner
1
c
None
no
CA194000001
Sacramento Ethanol Partners (SEPCO)
3
c
None
no
CA194000002
Northern California Power Agency
1
c
None
no
CA594000001
San Joaquin CoGen Limited
1
c
None
no
CO-1
U.S. Corps of Engineers
1
NC
None
no
C01042-0053
Shell Western E&P, Inc. (Hovenweep)
1
NC
None
no
C01043-0054
Shell Western E&P, Inc, (Yellow Jacket)
1
NC
None
no
C01044-0055
ARCO Permian (Garola)
1
NC
None
no
C01104-0420
Shell Western E&P, Inc. (Woods #3 MWD #1)
1
NC
None
no
COI516-02115
Wright's Disposal, Inc. (Sukla Farms)
1
C
None
no
FL101705471
Monsanto Chemical Co.
3
NC
None
no
FLS105001
Kaiser Aluminum & Chemical Company
1
NC
Approved
yes
D002 with metal UHC,
Na/K silicofluoride
production
no
FLS105705474
Cytec Industries
2
NC
None
no
FLS300506415
Harris Corporation
2
NC
None
no
FLS303108055
Indian River County Utility Services
1
NC
None
no
FLS400807931
Zemel Road Landfill
1
NC
None
no
FLS405801738
Sarasota County EDR- Sar. Cty Utilities Dept.
1
NC
None
no
FLS405805520
Plantation - Sarasota County Utilities Dept.
1
NC
None
no
FLS405806573
Englewood
1
NC
None
no
FLS405806588
Venice Gardens Utility
1
NC
None
no
FLS500606577
City of Plantation Water Treatment Plant
2
NC
None
no
FLS505005556
QO Chemical, Inc.
2
NC
None
no
FLS5050P05378
Acme Improvement District
1
NC
None
no
FLS505006578
United Technologies - Pratt and Whitney
1
NC
None
no
FLS505007543
Palm Beach County Solid Waste Authority
2
NC
None
no
-------
EXHIBIT 2-1
CLASS I UNDERGROUND INJECTION WELLS
Potentially
Prohibited
Number
No-Mlgratlon
Injects Phase
From Injection
Facility 10 #:
Facility Name
of Wells
Type
Petition Status
IV Wastes
Explanation/Comment
(see notes 1,2)
FLS505007547
Jupiter
1
NC
None
no
FLS505007891
City of Boynton Beach W Water Treatment Plant
1
NC
None
no
FLS513105560
Hercules, Inc.
1
NC
None
no
FLS514306722
North Martin County Utilities
1
NC
None .
no
FLS521102483
Marco Island Utilities-SSU Services
1
NC
None
no
FLS521108024
North Collier County Collier County Utilities
1
NC
None
no
FLS523607770
Gulf Utility
1
NC
None
no
ILD000781591
LTV Steel Company (Hennepin Works)
1
NC
Approved
yes
K062 w/ metal UHC,
neutralized waste pickle
llauor
no
ILD005078126
Quantum, USI Division
1
NC
None
no
ILD00S463344
Allied-Signal, Inc.
1
NC
Approved
yes
D004
no
ILD042075333
Cabot Corporation
2
NC
Approved
yes
D002, F038 potentially w/
metal UHCs.
no
IN-039-11-0001
Hoskins Manufacturina ComDanv
1
NC
None
no
IN-089-1W-0011
USX Corporation
1
NC
Withdrawn
no
IN-089-1W-0012
Inland Steel Corporation (Indiana Harbor)
2
NC
Withdrawn
no
IN-091 -11-0001
Criterion Catalyst Company
2
NC
None
no
IN-127-11-0007
ISK Magnetics, Inc.
2
NC
None
no
IN-127-1W-0001
Bethlehem Steel Corporation (Burns Harbor)
3
NC
Approved
yes
D010, D018, D038, K062
w/ metal UHCs
no
IN-127-IW-0006
Midwest Steel Division ot National Steel Corp
1
NC
Approved
yes
K062 w/ metal UHCs,
spent acid from steel
Dicklina process
no
IN-163-11-0001
Turris Coal Company
1
NC
None
no
KS-01-051-001
Exide
1
NC
None
no
KS-01 -053-001
Enron Gas Processing Co.
6
NC
None
no
KS-01-055-001
Val Agri, Inc. d/b/a Monfort
1
NC
None
no
KS-01-055-002
Iowa Beef Processors Inc. (Finnay.Lyon sites)
2
NC
None
no
KS-01-057-001
Farmland Industries, Inc.
3
NC
None
no
KS-01-067-001
AMOCO Production Company
5
NC
None
no
KS-01-077-001
Trident NGL, Inc.
2
NC
None
no
KS-01-091-001
Johnson County Landfill
1
NC
None
no
KS-01-093-001
Colorado Interstate Gas Co.
2
NC
None
no
KS-01-095-001
Phillips Petroleum Company
1
NC
None
no
KS-01-097-001
Northern Natural Gas Company (Kiowa)
1
NC
None
no
KS-01-113-002
National Cooperative Refinery Corporation
1
NC
None
no
KS-01-113-003
Koch Underground Storage Co (Conway/Riddell)
5
NC
None
no
KS-01-113-006
Texaco Trading and Transportation, Inc.
2
NC
None
no
-------
EXHIBIT 2-1
CLASS I UNDERGROUND INJECTION WELLS
Potentially
Prohibited
Number
No-Mlgratlon
ln|ects Phase
From Injection
Facility ID #:
Facility Name
of Wells
Type
Petition Status
IV Wastes
Explanation/Comment
(see notes 1,2)
KS-01-125-001
Sherwin-Williams Company
3
NC
None
no
KS-01-155-002
Koch Hydrocarbon Company (Fractionation)
4
NC
None
no
KS-01-155-004
Morton Salt, Inc.
1
NC
None
no
KS-01-155-005
Western Resources, Inc.
2
NC
None
no
KS-01-155-007
Koch Hydrocarbon Company (Hillside)
2
NC
None
no
KS-01-155-008
Ferrellgas
1
NC
None
no
KS-01-159-001
North American Salt Company
5
NC
None
no
KS-01-159-002
MAPCO/Mitchell, MAPCO/Conway (KS-01-113-001)
3
NC
None
no
KS-01-159-003
Northern Natural Gas Company (Rice)
1
NC
None
no
KS-01-165-001
Kansas Ref. Helium Company
1
NC
None
no
KS-01-173-001
Abbott Laboratories
1
NC
Approved
no
KS-01-173-002
Air Products Corporation
1
NC
Approved
no
KS-01-173-003
High Plains Corp.
1
NC
None
no
KS-01-173-004
Vulcan Chemicals
8
NC
Approved
yes
D007
no
KS-01-175-001
Northern Natural Gas Company (Seward)
2
NC
None
no
KS-ARCO
ARCO Oil & Gas Corporation
1
NC
None
no
KS-EMPIRE
Empire Gas Corp.
1
NC
None
no
KS6599
Winfield State Training School
1
NC
None
no
KS8238
Sentry
1
NC
None
no
Abondoned well
KYS0310117
Imco Recycling, Inc.
1
NC
None
no
KYS1110001
E.I. duPont, Louisville Works
2
NC
Approved
no
LA2330
Hallar Enterprises, Inc.
1
C
None
no
LA6581
Witco Chemical Corporation
1
NC
None
no
LAD000618256
Cecos International (Willow Springs)
1
C
Approved
yes
D002, D003-D010, D021-
D043
no
LAD000778514
Rollins Environmental Services of LA, inc.
1
C
Approved
yes
D004-D011, D012-D043
no
LAD001700756
Monsanto Co.
2
NC
None
no
LAD001890367
E.I. duPont (Pontchartrain Works)
6
NC
Approved
yes
Well 3 - D002, Well 4 -
D001, D003-D011, D012-
D017
no
LAD003913449
Borden Chemical & Plastics
3
NC
None
no
LAD008175390
Cytec Industries, Inc.
5
NC
Approved
yes
D002.D003 potentially w/
metal UHCs.
no
LAD008194060
Uniroyal Chemical Company
3
NC
None
no
LAD008213191
Rubicon, Inc.
4
NC
Approved
no
LAD020597597
Angus Chemical Company
2
NC
Approved
yes
D002 potentially w/ metal
UHCs.
no
LA D034199802
Chevron Chemical Company
2
NC
None
no
LAD040776809
BASF Corporation
1
NC
Approved
no
LAD057109449
UOP, Inc.
3
NC
None
no
LAD065470916
Witco Chemical Corporation
2
NC
None
no
-------
EXHIBIT 2-1
CLASS I UNDERGROUND INJECTION WELLS
Facility 10 #:
Facility Name
Number
of Wells
Type
No-Migration
Petition Status
Potentially
Injects Phase
IV Wastes
Explanation/Comment
Prohibited
From Injection
(see notes 1,2)
LAD980627061
ZENECA, Inc.
2
NC
None
no
LAD985200930
Calumet Lubricants Company
2
NC
None
no
LAG041
Gold Line Refining Ltd.
1
NC
None
no
MI-017-11-0003
Tidemark Exploration, Inc.
1
NC
None
no
MI-057-11-0002
Total Petroleum
1
NC
Withdrawn
no
MI-057-1 W-0001
Velsicol Chemical Corporation
1
NC
Unknown???
no
MI-077-1W-0001
The Uplohn Company
2
NC
Approved
yes
D001, D007, D035, D038
no
MI-091-11-0001
Great Lakes Chemical Corporation
1
NC
None
no
MI-133-11-0001
Kalium Chemicals
3
NC
None
no
MI-135-11-0001
Hoskins Manufacturing Company
1
NC
None
no
MI-137-11-0001
Standard Products
1
NC
None
no
MI-139-11-0001
H.J. Heinz Company
3
NC
None
no
MI-139-1 W-0001
BASF Chemicals Division
2
NC
Withdrawn
no
MI-139-1W-0003
Parke-Davis Division of Warner Lambert
3
NC
Submitted,
pending
determination
yes
D004-D011, D018, D035,
D038
no, LDPFA
MI-143-11-C001
Beckman Production Services, Inc.
1
C
None
no
MI-161-11-0001
Gelman Sciences, Inc.
1
NC
None
no
MI-163-1W-0003
Detroit Coke Company
3
NC
Withdrawn
no
MI-163-1W-0006
Environmental Disposal Systems
1
C
Planned
no
MI-165-11-0001
Pillsbury Company
1
NC
None
no
MSI1001
duPont DeLisle Plant-White Pigment & Mineral
4
NC
Submitted,
pending
determination
yes
Mineral process waste -
TI02 waste acid with
metal UHCs
yes
MS11004
Englehard Corporation
1
NC
None
no
MSS059001
Morton International, Inc.
2
NC
Approved
yes
D003 potentially w/ metal
UHCs
no
ND-UIC-101
Dakota Gasification Company
2
NC
None
no
ND-UIC-104
International Salt Company
1
NC
None
no
|NM990753931 | Climax Chemical Company I 1|NC |None |no | I |
OH-02-18-017
Akzo Nobel Salt, Inc.
1
NC
None
no
OH-02-43-006
Zeneca Ag. Products
2
NC
None
no
OH-03-02-003
BP Chemicals
4
NC
Approved
yes
D004-D011, D018, D019,
D038
no
OH-05-09-001
AK Steel Co.
2
NC
Approved
yes
K062 w/ metal UHCs,
D007, D002 spent nickel
liauid
no
OH-CWM
Chemical Waste Management, Inc.
7
C
Approved
yes
K062 w/ metal UHCs
no
-------
EXHIBIT 2-1
CLASS I UNDERGROUND INJECTION WELLS
Facility ID #:
Facility Name
Number
of Wells
Type
No-Mlgratlon
Petition Status
Potentially
Injects Phase
IV Wastes
Explanation/Comment
Prohibited
From Injection
(see notes 1,2)
OHD005108477
Aristech Chemical Corporation (Haverhill PI)
3
NC
Withdrawn
no
OHD980793384
Reserve Environmental Services, Inc.
1
C
None
no
OKD-SW-3519019
IMCO Recycling, Inc.
1
NC
None
no
OKD000402396
Perma Fix Treatment Services, Inc.
2
C
None
yes
D001, D002 potentially w/
metal UHCs
no, LDPFA
OKD000829440
Zinc Corporation of America
2
NC
None
no
OKD001824564
American Airlines
2
NC
None
no
OKD007188063
Macklanburg - Duncan
1
NC
None
no
OKD00722026
Rockwell International
1
NC
None
no
OKD078661279
Wil-Gro Fertilizer
1
NC
None
no
OKD098466568
Kaiser Chemical (Plant Shut Down)
2
NC
None
no
TNS0850004
DuPont Chemicals
3
NC
None
yes
Min. process waste -
TI02 prod., waste acid w/
metal UHCs
yes
TNS1190002
Zeneca Specialties
3
NC
None
no
TXD WDW-002
Monsanto Company (Chocolate Bayou Plant)
5
NC
Approved
ves
D004-D011, DO30
no
TXD WDW-004
E.I. duPont de Nemours and Company (Victoria)
11
NC
Approved
yes
D001-D011, D012-D043
no
TXD WDW-014
Hoechst Celanese Chemical Company (Bay City)
5
NC
Approved
yes
D001,D002 potentially w/
metal UHCs
no
TXD WDW-016
Rexene Products Co. (Odessa Petrochemical)
5
NC
None
yes
D007,
no, LDPFA
TXD WDW-020
Diamond Shamrock Corporation (McKee Plant)
5
NC
None
no
TXD WDW-033
Hoechst Celanese Chemical Co. (Clear Lake)
3
NC
Approved
yes
D004-D011
no
TXD WDW-034
ISP Technologies, Inc. (Texas City)
4
NC
None
yes
D001 potentially w/metal
UHCs
no, LDPFA
TXD WDW-036
Lyondell Petrochemical Co. (Channelview)
1
NC
Approved
no
TXD WDW-051
BASF Corporation (Freeport Road)
2
NC
Approved
yes
D018 potentially w/ metal
UHCs
no
TXD WDW-054
E.I. duPont de Nemours and Company (Sabine)
6
NC
Approved
yes
D002,D003,D005,D007-
D009, D018, D021-D028
no
TXD WDW-067
Phillips 66 Co. (Borger Refinery)
4
NC
None
no
TXD WDW-070
Disposal Systems of Corpus Christl, GNR Group
1
C
Approved
yes
D004-D011, D012-D043
no
TXD WDW-080
Amoco Oil Company (Texas City Plant)
5
NC
Approved
yes
D002, D003 potentially w/
metal UHCs
no
TXD WDW-082
E.I. duPont deNemours and Company (Houston)
3
NC
None
no
TXD WDW-091
Sterling Chemicals (Texas City)
3
NC
Approved
yes
D002, D003 potentially w/
metal UHCs
no
TXD WDW-100
E.I. duPont de Nemours Co. (Beaumont Plant)
3
NC
Approved
yes
D & K wastes potentially
w/ metal UHCs
no
TXD WDW-111
Witco Chemical Corporation (Retzloff)
2
NC
None
no
TXD WDW-115
Cominco Fertilizers (US), Inc. (Borger Plant)
2
NC
None
no
-------
EXHIBIT 2-1
CLASS I UNDERGROUND INJECTION WEIXS
Facility ID #:
Facility Name
Number
of Well9
Type
No-Mlgration
Petition Status
Potentially
Injects Phase
IV Wastes
Explanation/Comment
Prohibited
From Injection
(see notes 1,2)
TXD WDW-117
Jetco Chemicals, Inc. (Amine Plant)
1
NC
None
no
TXD WDW-120
Iowa Beef Processors, Inc.
2
NC
None
no
TXD WDW-122
Atochem North America, Inc. (Crosby Plant)
2
NC
Unknown ???
no
TXD WDW-123
U.S.X.-Texas Uranium Operations (Clay)
3
NC
None
no
TXD WDW-125
Sandoz Crop Protection Corp. (Beaumont Plant)
5
NC
None
no
TXD WDW-129
Asarco, Inc. (Amarlllo Copper Refinery)
2
NC
Approved
yes
D002, D004, D006-D008,
D010, D011, Se, Te plant
wastes
no
TXD WDW-130
U.S.X.-Texas Uranium Operations (Burns)
1
NC
None
no
TXD WDW-134
Chevron (Palangana Dome Site)
1
NC
None
no
TXD WDW-135
Texaco Refining and Marketing (Amarillo)
2
NC
None
no
TXD WDW-138
Malone Services Company
2
C
Approved
no
wells inactive
TXD WDW-140
U.S.X. Texas Uranium Operation (Boots)
2
NC
None
no
TXD WDW-146
CECOS International, Inc., (Odessa)
1
C
Denied
no
Abandoned wells
TXD WDW-147
Meridiem Company
2
C
Approved
yes
D wastes potentially w/
metal UHCs
no
TXD WDW-148
Arco Chemical Company (Channelvlew Plant)
2
NC
Approved
yes
0 wastes potentially w/
metal UHCs
no
TXD WDW-150
Coqema Mining, Inc.
3
NC
None
no
TXD WDW-152
Occidental Petroleum Corp.
2
NC
Approved
yes
D009
no
TXD WDW-156
Intercontinental Energy Corp. (Lamprecht)
1
NC
None
no
TXD WDW-157
Empak, Inc.
1
C
Approved
yes
D004-D011, D012-D043
no
TXD WDW-159
Intercontinental Energy Corp. (Zamzow)
1
NC
None
TXD WDW-160
Chemical Waste Manaqement (Port Arthur)
1
C
Approved
yes
D004-D011, D012-D043
no
TXD WDW-163
BP Chemicals America Co. (Vlstron)
3
NC
Approved
yes
D004-D011, D018, D019,
D038
no
TXD WDW-167
Wastewater, Inc.
1
C
Approved
yes
D004-D011, D012-D017
no
TXD WDW-168
Everest Exploration, Inc. (Hobson)
3
NC
None
no
TXD WDW-169
Disposal Systems, Inc. (Deer Park)
2
C
Approved
yes
D004-D011, D012-D017
no
TXD WDW-170
Westinghouse Electric Corp. (Brown Mine)
1
NC
None
no
TXD WDW-172
Shell Chemical Company (Deer Park)
2
NC
None
no
TXD WDW-180
Witco Chemical Company (Marshall Plant)
2
NC
Approved
no
TXD WDW-185
Everest Exploration, Inc.
1
NC
None
no
TXD WDW-186
American Ecology Corp. (Gibraltar)
2
C
Approved
yes
D004-D011
no
TXD WDW-187
Everest Mineral Corp. (Las Palmas Mining)
1
NC
None
no
TXD WDW-190
IEC Corporation (Pawnee Mine)
1
NC
None
no
TXD WDW-194
Everest Mineral Corporation (Mt. Lucas)
1
NC
None
no
TXD WDW-195
Cogema Mining, Inc (West Cole Facility)
1
NC
None
no
TXD WDW-210
Hoechst Celanese Chemical Co. (Bishop)
3
NC
Approved
yes
D004-D011, D018, D035
no
TXD WDW-222
Hampshire Chemical Corporation
2
NC
None
no
TXD WDW-231
Velsicol Chemical Corp.
2
NC
None
no
TXD WDW-244
Celanese Chemical Company
3
NC
None
no
-------
EXHIBIT 2-1
CLASS I UNDERGROUND INJECTION WELLS
Facility ID #:
Facility Name
Number
of Wells
Type
No-Mlgratlon
Petition Status
Potentially
Injects Phase
IV Wastes
Explanation/Comment
Prohibited
From Injection
(see notes 1,2)
TXD WDW-247
Uranium Resources, Inc. (URI)
2
NC
None
no
TXD WDW-250
Uranium Resources, Inc. (Rosita Project)
1
NC
None
no
TXD WDW-275
Loving Co. Disposal, Inc.
2
C
Pending
no
Wells not yet drilled
TXD WDW-278
Texas Ecoloqlst. Inc.
2
NC
Approved
yes
D004-D011, D012-D043
no
TXD WDW-280
Power Resources, Inc.
2
NC
None
no
TXD WDW-308
Uranium Resources, Inc. (Vasquez Project)
2
NC
None
no
TXD WDW-310
Crossroads Environmental Corporation
2
C
None
no
TXD WDW-311
Thomas Disposal Co.
1
C
None
no
TXD WDW-313
Triple P Disposal Company
1
C
None
no
TXD WDW-316
Environmental Processing Systems
2
C
None
no
WY87-339
Oedekoven Water & Hot Oil Svc. (Olsen)
1
C
Unknown ??
no
WY87-457
Oedekoven Water & Hot Oil Svc. (Morse Ranch)
1
C
None
no
WY88-545
Cogema Mining, Inc. (Christensen Ranch)
2
C
Unknown??
no
WY89-030
Power Resources (Morton)
1
C
None
no
WY89-192
Coastal Chemical
4
NC
None
no
WY89-198
Prima Exploration (C-H Minnelusa)
1
C
None
no
WY89-275
Cogema Mining, Inc. (North Butte)
2
NC
Unknown ??
no
WY89-285
Amoco Oil Company (Beaver Creek)
2
NC
None
no
WY89-379
H&M Disposal (C.G. Nicolaysen) (Cole Creek)
1
C
None
no
WY89-449
Chevron (Carter Creek)
2
NC
None
no
WY89-520
Amoco Oil Company (Whitney Canyon)
2
NC
None
no
WY90-223
Kissack Water & Oil Service (Shell Fox)
1
C
Unknown??
no
WY91-046
Kissack Water & Oil Service
1
C
Unknown??
no
WY91-166
Kissack Water & Oil Service (Federal)
2
C
Unknown??
no
WY91-247
Cogema Mining, Inc. (Irigaray)
2
NC
Unknown ??
no
WY91-264
Kissack Water & Oil Service (Keuhne)
1
C
None
no
WY93-294
WY Waste Water Disposal Co.(Laramie Facility)
1
C
Unknown??
no
WY95-030
Cortez Energy Company
1
C
Unknown??
no
WY95-277
KFx/Thermo - Ecotek Corporation
3
NC
Unknown ??
no
NOTES:
1. NO - Facility identified as potentially injecting Phase IV wastes that are not prohibited from injection because:
a) The facility has an approved no-migration petition,
b) The waste is decharacterized and meets the requirements of the Land Disposal Program Flexibility Act (LDPFA), or
c) The waste is listed with UHC exceeding UTS, and the facility can adjust an exisiting treatment system to
achieve the new treatment standard.
2. YES - Facility identified as potentially injecting Phase IV wastes that are prohibited from injection because.
a) The facility does not have an approved no-migration petition and,
b) The facility cannot treat its waste to meet either the new treatment standards or the LDPFA requirements.
3. An additional 45 non-commercial municipal facilities with 86 wells that do not manage Phase IV wastes in Florida are not listed.
Type: Commercial (C) or Non-Commercial (NC)
-------
characteristic and listed wastes may not have UHCs above the UTS; and (2) aggregate waste
volumes may include wastes not subject to the Phase TV rule. Appendix B describes the
methodology used to estimate these volumes and presents the results of the analysis in greater
detail.
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3.0 LDR EXEMPTIONS
Hazardous waste underground injection restrictions are codified in 40 CFR Part 148.
These regulations set dates for the prohibition of underground injection of hazardous wastes in
Class I injection wells. Wastes otherwise prohibited from injection may continue to be injected
under the following circumstances/
• An extension from the effective prohibition date is granted. The extension
may be in the form of a capacity variance or a case-by-case extension (40
CFR 148.1(c)(1)).
• The restricted waste is generated by a conditionally exempted small
quantity generator (40 CFR 148.1 (c)(3)).
• Wastes that are hazardous only because they exhibit a hazardous
characteristic, if decharacterized, are not prohibited from injection in
either a Class I hazardous or nonhazardous well (40 CFR 148.1(d)). (This
exemption was authorized by the Land Disposal Program Flexibility Act.)
• An exemption from a prohibition is granted in response to demonstrating
no migration of the injected restricted waste (40 CFR 148.1(c)(2)).
The circumstances under which treatment of Phase IV wastes in the long term is not
required prior to injection in a Class I well (i.e., the last two items above) are discussed in detail
in the following sections.
3.1 Land Disposal Program Flexibility Act (LDPFA) Exemptions
The LDPFA provides an exemption from treatment of UHCs to UTS for wastes that are
hazardous only because they exhibit a hazardous characteristic (D001-D043), if the wastes are
decharacterized and managed by (1) Class I underground injection or (2) in Clean Water Act or
equivalent systems with land disposal units. The wastes may be diluted to remove the
characteristic prior to management.
The LDPFA provides an exemption from treatment of UHCs for a number of waste
categories that otherwise would require additional treatment under the Phase IV rule because of
revisions making five of the non-wastewater metal UTS more stringent. Corrosive, ignitable,
reactive and TC organic wastes are currently subject to LDRs and are restricted from injection
without treatment. Current treatment decharacterizes these wastes, thereby meeting the LDPFA
requirements for an exemption from further treatment of UHCs. TC metal wastes that fail both
''These are the main circumstances under which prohibited wastes may be injected. Less common
circumstances include variances due to analytical limitations and exemptions for de minimis solvent concentrations.
Page 21
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the EP and TCLP are currently subject to LDRs, which prior to today's rule required treatment to
TC levels only. By meeting the current LDRs, these wastes also meet the LDPFA requirements
for an exemption from further treatment of UHCs. Therefore, these characteristic wastes will not
require additional treatment to meet the Phase IV rule.
Newly identified characteristic mineral processing wastes and newly identified TC metal
wastes (i.e., pass the EP but fail the TCLP) currently do not have LDR treatment requirements.
The Phase IV rule would restrict these wastes from injection without treatment of all UHCs to
UTS. However, the LDPFA provides an exemption from treatment of all UHCs, if these wastes
are decharacterized. Thus, LDPFA provides partial relief, while some treatment will be required
for these newly identified wastes to meet the Phase IV rule.
For capacity analysis purposes, EPA assumes that characteristic hazardous wastes are
exempted by the LDPFA from further treatment to meet the Phase IV rule because current
treatment requirements decharacterize the wastes. The exceptions to this assumption are newly
identified TC metal wastes (those TC metal wastes that pass the EP, but fail the TCLP) and
mineral processing wastes. Because these waste do not currently have to be treated, the wastes
must be examined individually to determine if treatment to decharacterize the waste is currently
performed before injection.
3.2 No-Migration Petitions
Disposal of prohibited, untreated hazardous waste by underground injection is banned
unless the operator demonstrates that the waste will not migrate from the injection zone for as
long as the waste remains hazardous. EPA promulgated standards in July 1988 describing how
no migration could be successfully demonstrated. EPA requires operators to show that wastes
will remain totally confined in the injection zone for at least 10,000 years. Alternatively,
operators may demonstrate that the waste will decompose or otherwise be attenuated in the
injection zone so that it is no longer hazardous. The information demonstrating no migration is
submitted to EPA in a petition. An approved no-migration petition is waste and unit specific,
and becomes the basis for granting an LDR exemption. Thus, to modify a petition to grant an
LDR exemption for additional wastes not included in the petition, the operator must demonstrate
that the new wastes will neither migrate from the injection zone nor affect the containment of
wastes previously granted an LDR exemption.
Operators who have either submitted timely no-migration petitions or modifications to
no-migration petitions for exemption from the Phase IV LDRs might not have their petitions
approved in time to avoid the effective prohibition date due to the lengthy procedures required to
process petitions. To provide relief from the need to shut down or curtail their operations. EPA
may grant a case-by-case capacity extension. To be granted a case-by-case extension, the
operator must demonstrate that a binding contractual commitment has been made to construct or
otherwise provide alternative treatment, recovery, or disposal capacity that protects human health
and the environment. EPA has interpreted disposal capacity to include a no-migration unit. Any
extension applies only to waste generated at an individual facility and precludes granting a case-
Page 22
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by-case extension to commercial injectors. Two scenarios involving Phase IV wastes managed
by underground injection where a case-by-case extension might be requested are described
below.
Some non-commercial facilities with an approved no-migration petition for hazardous
wastes other than Phase IV wastes may currently inject Phase IV wastes. If these wastes do not
meet the requirements for a LDR exemption, once the land ban goes into effect, these facilities
would have to submit a petition to modify their no-migration petitions to include the Phase IV
wastes. A case-by-case extension might be requested if the petition modification could not be
granted in time to avoid the Phase IV land ban. However, the number of facilities that might fall
within this category is likely to be small, because many of the facilities that have approved no-
migration petitions are likely to have already included in their petitions wastes and constituents
that will be affected by the Phase IV LDRs. Moreover, a typical strategy used to demonstrate no
migration by many petitioners is to model the fate and transport of the most mobile waste or
constituent and demonstrate how other wastes and constituents are less mobile. This strategy is
likely to be adopted by some facilities for new constituents, thus potentially streamlining the
approval of the petition modifications. For capacity analysis purposes, EPA assumes that
facilities with approved no-migration petitions that may require modification to their petitions are
likely to be few. Some will be able to obtain approval of a petition modification before the land
ban effective date, while others will be granted an extension, and will continue to manage their
Phase IV wastes by underground injection.
Some non-commercial facilities that currently inject Phase IV wastes have submitted no-
migration petition applications, but likely will not receive approval in time to avoid the Phase IV
land ban. These facilities might request a case-by-case extension using their no-migration
petition submittal to demonstrate a good faith effort to meet the requirements of the Phase IV
LDRs. Without reviewing each case individually, it would be difficult to predict which facilities
would likely receive an extension.
Exhibit 2-1 lists Class I underground injection facilities with an approved no-migration
petition. Of the 227 Class I facilities identified in the database, 48 have approved no-migration
petitions. Of these Class I facilities with approved no-migration petitions, 40 potentially manage
Phase IV wastes. Appendix A describes the methods used to identify facilities with no-migration
petitions.
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Page 24
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4.0
PHASE IV WASTES PROHIBITED FROM INJECTION
To determine which facilities injecting Phase IV wastes would be subject to the
prohibition from disposal without treatment, EPA eliminated the facilities that will continue to
inject Phase IV wastes without significant change. Facilities that are exempted from the LDRs as
discussed in Section 3.0 were first eliminated. These include facilities that have an approved no-
migration petition and/or inject decharacterized characteristic hazardous wastes. In addition,
listed wastes that contain UHCs for which the UTS have been revised to be more stringent were
also eliminated. Because these wastes are already meeting current treatment standards, the
Agency believes that to achieve the new UTS, these wastes are expected to only require
optimization of existing treatment formulations and systems. The facilities that remain after this
process of elimination are those injecting newly identified mineral processing wastes and newly
identified TC metals wastes that are unable to decharacterize their wastes.
4.1 Newly Identified TC Metals Wastes
Identifying the facilities injecting newly identified TC metal wastes is problematic.
Because RCRA waste codes do not distinguish newly identified TC metal wastes from those
identified before enactment of HSWA in November 1984, the BRS and other data sources do not
provide a means of identifying such wastes. Promulgation of the TC Rule (55 FR 11798)
broadened the type of waste that became subject to Subtitle C of RCRA. Most newly identified
TC wastes are wastes that fail the TCLP because of the inclusion of new organic TC constituents.
However, in the original proposal of the TC rule (60 FR 43654), EPA noted that, for lead wastes,
the TCLP might be more aggressive in extracting lead than the EP, and therefore assumed that
the additional quantities of newly identified D008 wastes will be approximately 20 percent of the
quantity of D008 wastes that were hazardous by the old EP leaching procedure. In addition,
representatives of the metals manufacturing industry commented that slag piles could fail the TC
as proposed and would therefore require Subtitle C management.3 Furthermore, because no
wastewaters pass the EP and fail the TCLP, any newly identified TC metal wastes are non-
wastewaters.
EPA conducted two studies to compare the results of the TCLP with those of the EP.6 In
the first study, a synthetic heavy metal waste was chemically stabilized with and without a
variety of interfering compounds, and was subjected to TCLP and EP extractions. The extracts
were analyzed for metals. In the second study, two solidified/stabilized heavy metal wastes and
an untreated perchloroethylene still-bottom waste were subjected to TCLP and EP extractions.
Results indicate that generally the TCLP is a more aggressive leaching procedure than the EP.
One significant procedural difference between the EP and the TCLP that may account for some
of the different results is the extraction fluid used. In the EP, distilled deionized water is used as
3EPA, "Background Document, Response to Comments Toxicity Characteristic Rule. Proposed Rule." May
1989.
6EPA, "A Comparative Evaluation of Two Extraction Procedures: the TCLP and the EP," EPA/600/52-
91/049, March 1992.
Page 25
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the extractant. In the TCLP, the type of extractant is based on the waste's alkalinity. Either an
acetate buffer (Fluid 1) or an acetic acid buffer (Fluid 2) is used. In these studies, when Fluid 1
was used to extract metal contaminants, the EP and the TCLP produced statistically different
results, with the TCLP generally being the more aggressive extraction. The metals that were
more aggressively extracted were arsenic, lead, cadmium and mercury.
EPA identified 25 facilities that inject 27.6 million metric tons per year of TC metal
wastes. Of these facilities, eight appear to inject wastewaters, and two are also newly identified
mineral processing wastes facilities. Thus, the remaining 15 facilities appear to inject TC metal
non-wastewaters, excluding newly identified mineral processing wastes, and thus could be
injecting wastewaters. EPA is unable at this time to distinguish with any certainty the newly
identified TC metal wastes from the EP metal wastes at these 15 facilities. Moreover, there were
no comments to the proposed rule regarding newly identified TC metal wastes or commenters
who identified themselves as generators of newly identified TC metal wastes. However, of these
15 facilities, 13 inject D004 (arsenic), D006 (cadmium), D008 (lead) or D009 (mercury) wastes
(see Exhibit 4-1). These TC metal non-wastewaters (D004, D006, D008, D009) in total amount
to about 5.5 million metric tons per year of injected waste.7 As discussed above, these metals are
more aggressively extracted by the TCLP. Therefore, any newly identified TC metal wastes
would likely be a subset of the wastes from these 15 facilities. However, the Agency believes
that the wastes at these facilities are more likely to be TC metal wastes identified before HSWA,
and thus the quantity of newly identified TC metal waste currently being injected is likely to be
very small, if any is being injected at all.
4.2 Newly Identified Mineral Processing Wastes
EPA has identified two facilities injecting newly identified mineral processing
characteristic wastes without an LDR exemption. They are the Dupont titanium dioxide
processing facilities located in New Johnsonville, Tennessee and DeLisle, Mississippi. Both of
these facilities are injecting titanium chloride process waste acids that are characteristic for
corrosivity and TC metals (lead, chromium). Based on comments to the proposed Phase IV rule,
and communications between EPA and Dupont, Dupont does not treat the waste acids before
injection at these two facilities. Dupont reportedly injects a total of 289 million gallons per year
of Phase IV waste at its DeLisle facility and 361 million gallons per year of Phase IV waste at its
New Johnsonville facility. Appendix C presents documentation of the volumes and other
characteristics of the wastes generated by Dupont annually.
7From Appendix B. 27.6 Mtons TC metal wastes - (18.8 Mtons TC metal wastewaters + 2.9 Mtons newly
identified mineral processing TC metal wastes) = 5.9 Mtons TC metal non-wastewater - 0.4 Mtons TC metal non-
wastewater (D005, D007 ,D010, D011) =5.5 Mtons TC metal non-wastewater (D004, D006, D008, D009)
Page 26
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EXHIBIT 4-1
FACILITIES INJECTING TC METAL NON-WASTEWATER
Facility ID
Facility Name
Injects D004,
D006, D008
or D009
DLD005463344
Allied-Signal. Inc.
yes
IN-127-1W-0001
Bethlehem Steel Corp Burns Harbor
no
LAD000618256
Cecos International (Willow Springs)
yes
LAD000778514
Rollins Environmental Services of LA, Inc.
yes
MI-077-1W-0001
The Upjohn Company
no
TXD WDW-033
Hoechst Celanese Chemical Co. (Clear Lake)
yes
TXD WDW-070
Disposal Systems of Corpus Christi, GNR Group
yes
TXD WDW-156
Occidental Chemical Corporation
yes
TXD WDW-157
Empak, Inc.
yes
TXD WDW-160
Chemical Waste Management (Port Arthur)
yes
TXD WDW-163
BP Chemicals America Co.
yes
TXD WDW-167
Wastewater, Inc.
yes
TXD WDW-169
Disposal Systems, Inc. (Deerpark)
yes
TXD WDW-210
Hoechst Celanese Chemical Co. (Bishop)
yes
TXD WDW-278
Texas Ecologist, Inc.
yes
Facilities Injecting D004. D006. D008 or D009 Non-wastewaters
13
Note: Waste identified as non-wastewater based on waste source description in UICWELLS.
Page 27
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Page 28
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5.0
CAPACITY DATA AND ISSUES
This section presents information on the ability of the facilities identified as injecting
prohibited Phase IV wastes to treat their wastes on-site or off-site. The section is organized as
follows. Section 5.1 evaluates the ability of theses facilities to treat on-site to meet the land ban
by constructing an on-site treatment system. Section 5.2 evaluates the ability of these facilities to
transport the prohibited Phase IV waste for off-site commercial treatment or injection and the
available commercial treatment and injection capacity.
5.1 On-site Management
Currently, neither of the Dupont facilities injecting newly identified mineral processing
characteristic wastes has an operating treatment system to manage the volume of waste
generated.
5.1.1 Dupont - New Johnsonville
The New Johnsonville facility is under a consent order to cease operations of its injection
wells by July 1, 1998, and is currently constructing a treatment system to manage Phase IV
wastes.
5.1.2 Dupont - DeLisle
In the Regulatory Impact Analysis of the application of Phase IV LDR to newly identified
mineral processing wastes8, EPA presented costs associated with construction of an on-site
treatment system for management of corrosive liquid wastes. In the RIA, EPA assumes that
acidic wastes would be treated by neutralization , precipitation, dewatering and stabilization of
the sludge before land disposal. Using the assumptions developed for the RIA, EPA estimates
that the minimum time to construct a treatment system for acid wastes at the DeLisle facility is
approximately one year. Appendix D describes the assumptions used in this estimate.
5.2 Off-site Management
As discussed above, on-site treatment is currently unavailable at the two Dupont facilities
injecting newly identified mineral processing wastes. The Dupont DeLisle facility cannot
obtained on-site treatment by the land ban date, and although a treatment system is under
construction at the Dupont New Johnsonville facility, it may not be completed by the land ban
date. This section evaluates the feasibility of off-site transport of wastes from both of these
8EPA, "Regulatory Impact Analysis, Application of Phase IV Land Disposal Restriction to Newly
Identified Mineral Processing Wastes," Office of Solid Waste, draft dated January 28, 1998.
Page 29
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facilities and assesses the availability of commercial treatment or injection to meet required
capacity.
5.2.1 Transport to Off-Site Management
Dupont claims it would be impractical to ship their wastes off-site because they would
need 200 tanker trucks per day at each site to transport the waste to an off-site treatment or
injection facility. EPA independently assessed these claims, using Dupont's reported injection
rates and production schedule, and agrees that such a shipment is not feasible. (See Appendix
C.)
5.2.2 Availability of Commercial Injection Capacity
EPA reviewed the all commercial injection facilities to identify facilities in the vicinity of
the two Dupont facilities. Appendix E presents the available injection capacity at all of the
commercial facilities that have an approved no-migration petition. There are no commercial
underground injection facilities in the vicinity of the New Johnsonville facility. Whereas, there
are two commercial underground injection facilities in the vicinity of the DeLisle facility. The
facilities and the available injection capacity are presented below.
• Cecos Willow Springs, LA has an approved no-migration petition
(approximately 200 miles away) and an available injection capacity of
61,261,200 gallons per year.
• Rollins, LA has an approved no migration petition (approximately 200
miles away) and an available injection capacity of 69,666,000 gallons per
year.
The total available injection capacity in the vicinity of the DeLisle facility is 130,927,200
gallons per year. This volume is less than the required capacity at DeLisle.
5.2.3 Availability of Commercial Treatment Capacity
EPA identified commercial treatment facilities to located commercial treatment in the
vicinity of the Dupont facilities.9 Appendix E presents the available treatment capacity for these
commercial treatment facilities. There are no commercial treatment facilities in the vicinity of
the DeLisle facility. Whereas, there are two commercial treatment facilities in the vicinity of the
'Commercial treatment facilities identified in EPA's "Background Document for Capacity Analysis for
Land Disposal Restrictions - Phase IV (Second Supplemental): Toxicity Characteristic Metals Wastes and Newly
Identified Mineral Processing Wastes (Proposed Rule), April 1997."
Page 30
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New Johnsonville facility. The facilities and the available treatment capacity are presented
below.
• Tricil Environmental Services Inc., Nashville. Tennessee
(approximately 75 miles away) has an available treatment capacity of
81 million gallons per year.
• Osco Inc., Columbia, Tennessee (approximately 70 miles away) has no
available treatment capacity.
Both treatment facilities have insufficient available capacity to handle waste volume estimates
for the New Johnsonville facility.
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Page 32
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6.0 SUMMARY
Presented below is a summary of the major findings of the effects of the Phase IV rule on
underground injection.
• The Phase IV rule would prohibit the injection of the following untreated
wastes unless otherwise exempted.
~ Newly identified mineral processing wastes
~ Newly identified TC metal wastes
~ TC metal wastes identified before HSWA
~ Other characteristic wastes containing UHCs exceeding the revised
UTS for metals
~ Listed wastes containing UHCs exceeding the revised UTS for metals.
• If alternative commercial treatment or injection capacity is unavailable for
wastes prohibited from injection, only the newly identified mineral processing
and newly identified TC metal wastes are eligible for a capacity variance.
• As of 1995, there are a total of 227 Class I underground injection facilities
operating 537 Class I wells.
~ EPA estimates that 46 Class I facilities potentially inject wastes that
would be prohibited from injection without treatment by the Phase IV
rule or an LDR exemption.
~ These facilities inject a combined high-end estimated volume of 45
million metric tons.
~ The actual volume of Phase IV waste is likely to be substantially less
because (1) some of the characteristic and listed wastes may not have
UHCs above the revised UTS for metals, and (2) aggregate waste
volumes used in the estimate may contain wastes not subject to the
Phase IV rule.
• Wastes otherwise prohibited from injection by the Phase IV rule, may
continue to be injected under the following circumstances.
~ An extension from the effective prohibition date is granted in the form
of a capacity variance.
~ Phase IV wastes is generated by a conditionally exempted small
quantity generator.
~ The facility demonstrates no migration of the injected waste and is
granted an approved no-migration petition.
Page 33
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The waste meet the requirements of the LDPFA which allows
injection of wastes that are hazardous only because they exhibit a
hazardous characteristic, if the waste is decharacterized.
Forty-eight facilities have approved no-migration petitions. Forty of these
facilities potentially inject Phase IV wastes.
»• Facilities with approved no-migration petitions covering Phase IV
UHCs will not be prohibited from injecting untreated Phase IV wastes.
*¦ Facilities with approved no-migration petitions that do not include
Phase IV UHCs will have to submit a modification to their no-
migration petition and obtain approval of the modification before the
prohibition date to continue injecting Phase IV wastes. If they are
unable to obtain approval for the modification in time to meet the
prohibition, EPA may grant a case-by-case capacity extension. For
capacity purposes, EPA assumes that either the petition modification
will be approved in time to meet the prohibition or these facilities will
be granted a case-by-case extension.
~ If a facility has submitted a no-migration petition but will not obtain
approval by the prohibition date, EPA may grant a case-by-case
capacity extension, if the operator demonstrates that a binding
contractual commitment has been made to construct or otherwise
provide alternative treatment, recovery, or disposal capacity that
protects human health and the environment.
The LDPFA provides an exemption to characteristic wastes that are
decharacterized from further treatment of UHCs to UTS as required by the
Phase IV rule.
~ TC metal wastes identified before HSWA, corrosive, reactive,
ignitable and TC organic wastes currently are required to treat before
injection. Thus, by meeting current treatment standards, these wastes
are decharacterized and are exempted by the LDPFA from further
treatment of UHCs to meet the Phase IV rule. Four facilities injecting
characteristic wastes that do not have an approved no-migration
petition decharacterize their wastes before injection and are exempted
by the LDPFA from treating UHCs in their wastes. These facilities
will continue to inject their wastes as currently managed under the
Phase IV rule.
*¦ The newly identified characteristic mineral processing wastes and
newly identified TC metal wastes currently do not require treatment
before injection. If these wastes can be decharacterized, the LDPFA
exempts the wastes from further treatment of UHCs as required by the
Phase IV rule. Two facilities injecting newly identified wastes that do
Page 34
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not have approved no-migration petitions could receive partial relief
from further treatment by the LDPFA. However, these facilities
currently do not treat to decharacterize their wastes and will be
prohibited from injecting under the Phase IV rule.
Listed wastes containing UHCs above the revised UTS are meeting current
treatment standards. EPA believes that to achieve the revised UTS, these
wastes are expected to only require optimization of existing treatment
formulations and systems. EPA believes that optimization can be
accomplished in time to meet the prohibition date.
Because of various exemptions and/or optimization of existing treatment, EPA
eliminated facilities that will continue to inject Phase IV wastes without
significant change in current management. Facilities that would be prohibited
from injecting Phase IV wastes are those injecting newly identified mineral
processing wastes and newly identified TC metal wastes.
EPA was unable to distinguish newly identified TC metal wastes from
TC metal wastes identified before HSWA. Based on EPA studies of
the EP and TCLP, the TCLP more aggressively extracts lead, cadmium
arsenic and mercury. Non-wastewater TC metal wastes containing
these metals as UHCs amount to about 5.5 million metric tons per year
of waste injected at 13 facilities. Most of these facilities are likely to
be TC metal wastes identified before HSWA, and the volume of newly
identified TC metal wastes is likely to be small, if any at all.
EPA identified two Dupont facilities injecting newly identified mineral
processing characteristic wastes. These facilities combined are
injecting 2.9 million metric tons of Phase IV waste per year.
Currently neither of the Dupont facilities injecting newly identified mineral
processing wastes has an operating treatment system to manage the prohibited
wastes.
The Dupont facility in New Johnsonville, Tennessee is currently
constructing a treatment system to manage the prohibited waste.
Information is unavailable to determine whether the treatment system
can be completed before the prohibition date. However, the facility
signed a consent order with EPA agreeing to cease injecting by July 1,
1998.
Using assumptions developed for the Mineral Processing RIA, EPA
estimates that the minimum time to construct a treatment system for
the prohibited wastes at the Dupont DeLisle facility is approximately
one year.
Page 35
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Dupont claims that it is impracticable to ship the wastes from the DeLisle and
New Johnsonville facilities off-site for treatment or injection. EPA
independently assessed this claim and agrees that such a shipment is
infeasible.
Regardless of Dupont's ability to transport waste off-site, there is insufficient
commercial injection or treatment capacity in the vicinities of Dupont's
DeLisle and New Johnsonville facilities to meet their required capacity.
Page 36
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Appendix A - Methodology for Identification of Facilities that Potentially
Inject Phase IV Wastes
-------
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-------
RCRA also allows generators to apply for extensions to the LDRs on a case-by-case basis
for specific wastes generated at a specific facility for which there is not adequate capacity
(RCRA section 3004(h)(3)). EPA may grant case-by-case capacity variances to applicants who
can demonstrate that: (1) no capacity currently exists anywhere in the U.S. to treat a specific
waste, and (2) a binding contractual commitment is in place to construct or otherwise provide
alternative capacity, but due to circumstances beyond the applicant's control, such alternative
capacity cannot reasonably be made available by the effective date (40 CFR 268.5).
HSWA's schedule divided hazardous wastes into three broad categories: solvent and
dioxin wastes; California listed wastes; and "scheduled" wastes. EPA completed LDR
rulemakings for these three broad categories by May 1990. For hazardous wastes that are
identified or listed after November 8, 1984 ("newly identified wastes"), rulemaking has
proceeded in phases based on the requirement to promulgate land disposal prohibitions within six
months of the date of identification or listing. However, the statute does not provide an
automatic prohibition of land disposal of such wastes if EPA fails to meet this deadline. Exhibit
1-1 summarizes the previous LDR rulemakings and their respective promulgation dates.
1.2.2 Toxicity Characteristic Metal Wastes
In May 1980 (45 FR 33084), the Agency promulgated the final rule on the use of the
Extraction Procedure (EP) toxicity test to identify a waste that poses a significant hazard due to
its potential to leach significant concentrations of hazardous constituents. Metal and organic
constituents were identified that, if present in the EP waste extract in excess of a specified
concentration, cause the waste to be identified as hazardous (EP Toxic). After several revisions
to the existing hazardous waste identification regulations, EPA finalized the Toxicity
Characteristic (TC) rule in March 1990 (55 FR 11798). This rule replaced the EP leaching test
with the Toxicity Characteristic Leaching Procedure (TCLP). Since promulgation of the TC rule,
the TCLP has been used to determine the toxicity of a characteristic metal waste. A waste that is
characteristic by the TCLP, but not by the EP, is considered a newly identified waste and
currently is not subject to LDRs. In August 1995 (60 FR 43654), the Agency proposed revised
treatment standards, under the LDR program, for all characteristic metal wastes (D004-D011),
including those previously regulated by the EP. These revised standards, for both wastewater
and non-wastewater forms of D004-D011 wastes, are numerically equivalent to the universal
treatment standards (UTS) for the TC constituents. (A universal treatment standard is a single
treatment standard established for a specific constituent regardless of the waste matrix in which it
is present.) Furthermore, any underlying hazardous constituent associated with a UTS must meet
the UTS level.
EPA received numerous comments on the treatability of TC metal wastes to the UTS
levels. Upon additional review of the comments and data submitted by commenters, the Agency
re-proposed the UTS levels for 12 metal constituents in the Phase IV LDR second supplemental
proposed rule (62 FR 26041, May 12, 1997). In final Phase IV rule, EPA is promulgating the
final UTS for those 12 metal constituents in TC metal wastes, and requiring the UTS to be met
for all UHCs. Exhibit 1-2 presents the TC levels, existing UTS levels, and final UTS levels.
Page 3
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EXHIBIT 1-1
SUMMARY OF PREVIOUS LAND DISPOSAL RESTRICTIONS RULEMAKINGS
Rulemaking
Federal Register Notice
Promulgation Date
Solvents and Dioxins (surface disposed)
51 FR 40572
November 7, 1986
Solvents and Dioxins (deep well injected)
53 FR 28188
July 26, 1988
California List (surface disposed)
52 FR 25760
July 8, 1987
California List (deep well injected)
53 FR 30908
July 26, 1988
First Third Rule
53 FR 31138
August 8, 1988
First Third Rule (deep well injected)
54 FR 25416
June 7,1989
Second Third Rule
54 FR 26594
June 8,1989
Third Third Rule
55 FR 22520
May 8, 1990
Newly Listed and Identified Wastes
(Phase I)
57 FR 37194
June 30, 1992
Interim Final Rule for Vacated Treatment
Standards
58 FR 29860
Mav 24, 1993
Organic TC Wastes and Newly Listed
Wastes (Phase II)
59 FR 47982
September 19, 1994
Decharacterized Wastewaters, Carbamate
Wastes, and Spent Potliners (Phase m)a
61 FR 15565
April 8, 1996
Wood Preserving Wastes Final Rule
62 FR 25998
May 12, 1997
a On August 26, 1996, the Agency revised the carbamate waste treatment standards for one year from the date of
publication ("Emergency Revision of the Land Disposal Restrictions (LDR) Phase III Treatment Standards for Listed
Hazardous Wastes from Carbamate Production," 61 FR 43923). On January 14, 1997, the Agency extended the
national capacity variance for spent potliners (K088) for six months ("Land Disposal Restrictions Phase III -
Emergency Extension of the K088 Capacity Variance; Final Rule," 62 FR 1991). On July 14, 1997, the Agency
extended the national capacity variance for K088 wastes for three additional months (62 FR 37693). Thus, K088
wastes became subject to LDR treatment standards on October 8, 1997.
Page 4
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EXHIBIT 1-2
EXISTING AND FINAL UTS LEVELS
(NON-WASTEWATER METALS)
Waste
Code
Constituent
TC
Level
(mg/1)
Existing
UTS
level
(mg/1 TCLP)
Final
UTS
Level
(mg/1 TCLP)
D004
Arsenic
5.0
5.0
5.0
D005
Barium
100
7.6
21
D006
Cadmium
1.0
0.19
0.11
D007
Chromium
5.0
0.86
0.60
D008
Lead
5.0
0.37
0.75
D009
Mercury
0.2
0.025
0.025
D010
Selenium
1.0
0.16
5.7
D011
Silver
5.0
0.30
0.14
Antimony
2.1
1.15
Beryllium
0.014
1.22
Nickel
5.0
11
Thallium
0.078
0.20
Vanadium
0.23
1.6
Zinc
5.3
4.3
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1.2.3 Mineral Processing Wastes
Under Section 8002 of RCRA, commonly referred to as the Bevill Amendment, wastes
from extraction, beneficiation, and mineral processing operations are exempt from regulation as
hazardous waste under Subtitle C of RCRA, as amended. The Mining Waste Exclusion was
established in response to the so-called "Bevill Amendment," which was added in the 1980 Solid
Waste Disposal Act Amendments. The Bevill Amendment precluded EPA from regulating these
wastes until the Agency performed a study and submitted a Report to Congress. The Agency
completed its study of extraction and beneficiation wastes in 1985, and issued a regulatory
determination in 1986 that removed these wastes from Subtitle C regulation. The Agency
established criteria for what constitutes a special waste in September 1989, and these special
wastes were excluded from Subtitle C requirements. The Agency's study of mineral processing
wastes was completed in June 1990, and it focused on high-volume, low-hazard wastes referred
to as special wastes. The Agency promulgated final rules in September 1989 (54 FR 36592) and
January 1990 (55 FR 2322) establishing that only 20 specific mineral processing wastes fulfilled
the newly promulgated special wastes criteria; all other mineral processing wastes were removed
from the Mining Waste Exclusion.
These newly identified non-exempt ("de-Bevilled") wastes have the same regulatory
status as any other industrial solid waste. Thus, if they exhibit characteristics of hazardous waste
or are listed as hazardous wastes, they must be managed in accordance with RCRA Subtitle C.
Existing waste characterization data suggest that many of these wastes exhibit the characteristic
of toxicity for metals (D004-D011), corrosivity (D002), and/or reactivity (D003). EPA considers
these wastes to be "newly identified" because they were brought in the RCRA Subtitle C system
after the date of enactment of the HSWA in November 1984. All wastes removed from the
Bevill exclusion and found to exhibit any of the RCRA hazardous characteristics became newly
identified wastes subject to RCRA Subtitle C requirements.
1.2.4 Phase IV Rulemaking
On December 6, 1990, wastewaters, process residuals, preservative drippage, and spent
formulations from wood preserving processes generated at plants that currently use or have
previously used chlorophenolic, creosote, or inorganic arsenic-containing or chromium-
containing preservatives became listed hazardous wastes subject to Subtitle C regulation. LDR
rulemakings for these newly listed wastes were grouped with TC metals and mineral processing
wastes initially. However, EPA finalized treatment standards for wood preserving wastes
separately on May 12, 1997 (62 FR 25998), and these wastes currently are subject to LDRs.
The final Phase IV rule is part of a collection of rules to establish treatment standards for
newly listed and identified wastes that were proposed in five previous Federal Register notices.
These notices are listed below, and cover LDRs and associated issues for metals wastes and
newly identified mineral processing wastes ("de-Bevilled" mineral processing wastes).
Page 6
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• Phase IV Proposal - August 22. 1995 (60 FR 43654). Issues Associated
With Clean Water Act Treatment Equivalency, and Treatment Standards
for Wood Preserving Waste and Toxicity Characteristic Metal Wastes
• Phase IV First Supplemental Proposal - January 25. 1996 (61 FR 2338).
Clarification of Bevill Exclusion for Mining Wastes, Changes to the
Definition of Solid Waste For Mineral Processing Wastes, Treatment
Standards for Characteristic Mineral Processing Wastes, and Associated
Issues
• Phase IV Notice of Data Availability - May 10. 1996 (61 FR 21417).
Issues Associated With Clean Water Act Treatment Equivalency, and
Treatment Standards for Wood Preserving Wastes and Toxicity
Characteristic Metal Wastes
• Phase IV Second Supplemental Proposal - May 12. 1997 (62 FR 26041).
Second Supplemental Proposal on Treatment Standards for Metal Wastes
and Mineral Processing Wastes, Mineral Processing and Bevill Exclusion
Issues, and the Use of Hazardous Waste as Fill
• Phase IV Notice of Data Availability - November 10. 1997 (62 FR 60465).
Second Supplemental Proposal on Treatment Standards for Metal Wastes
and Mineral Processing Wastes, Mineral Processing and Bevill Exclusion
Issues, and the Use of Hazardous Waste as Fill
1.2.5 Types of Wastes Covered by the Phase IV LDRs
The complex history of proposal, withdrawal, reproposal, and finalization of certain
aspects of the Phase IV LDRs has led to inclusion and exclusion of certain wastes in this rule.
For example, previous analyses of the impact of the rule included wastes not part of the latest
proposed rule. Thus, for clarity, the types of wastes regulated by the Final Phase IV rule are
described below.
Newly Identified Mineral Processing Wastes Containing Characteristic Hazardous Wastes
EPA established definitions and techniques for determining which operations and waste
streams might be subject to LDRs. The decisions concerning whether individual wastes are
outside the scope of the RCRA Mining Waste Exclusion are based on a number of different
factors discussed in detail in the Agency's background document that describes and characterizes
Page 7
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mineral processing wastes.2 Determining which mineral processing wastes are de-Bevilled newly
identified hazardous wastes is not a straightforward process. However, in general, a de-Bevilled
newly identified hazardous mineral processing waste has the following characteristics:
• The waste must originate from primary mineral production operations only
defined as those using at least 50 percent ores, minerals, or beneficiated
ores or minerals as the feedstock providing mineral value. (Thus,
secondary production of mineral commodities such as wastes from scrap
recycling, metals recovery from flue dust, and similar activities have
always been subject to Subtitle C regulation.)
• The waste must not be one of the 20 special wastes established in 55 FR
2322.
• The waste must not originate from beneficiation and/or extraction as
defined by 40 CFR 261.4(b)(7).
• The waste must meet the criteria for characteristic hazardous waste as
defined by 40 CFR 261.20.
The Phase IV rule requires these wastes to meet LDR requirements for the first time. If
EPA determines that there is insufficient alternative commercial treatment capacity, these wastes
are eligible for a national capacity variance.
Toxicity Characteristic (TC) Metals Hazardous Wastes (D004 - DPI 1)
Wastes that were previously identified as TC metal by the EP and remained TC metal
after testing with the TCLP currently are subject to less stringent LDR treatment requirements
(i.e., treatment to TC levels), and will be required under Phase IV to meet the more stringent
UTS for all UHCs including the revised non-wastewater metals UTS. These wastes are not
eligible for a national capacity variance if alternative commercial treatment capacity is
insufficient (unless the waste is a newly identified mineral processing waste). A newly identified
group of TC metal wastes, those that were not identified as hazardous by the EP, but were
identified as hazardous by the TCLP, are subject to LDRs for the first time. (The distinguishing
differences between these groups of TC Metal wastes are discussed in Section 4.1.) The newly
identified TC metal wastes are eligible for a national capacity variance if EPA determines that
there is insufficient alternative commercial treatment capacity.
2EPA, Background Document, Identification and Description of Mineral Processing Sectors and Waste
Streams, December 1995.
Page 8
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Listed Hazardous Wastes with UHCs Exceeding the Revised UTS for Metals
These wastes currently are subject to LDRs. The Phase IV rule revises the UTS for non-
wastewaters downward for five metal UHCs (cadmium, chromium, silver, antimony, and zinc),
and thus listed wastes containing these metal UHCs would be required to treat to more stringent
levels. Examples of listed wastes that might be affected by the Phase IV rule are spent pickle
liquor from steel finishing (K062) or spent cyanide plating bath solutions (F006) containing
UHCs such as cadmium or chromium above the revised UTS. Listed wastes are not eligible for
a national capacity variance if there is insufficient alternative commercial treatment capacity.
Other Characteristic Wastes (Toxic Organic. Ignitable. Corrosive, or Reactive) with
UHCs Exceeding the Revised UTS for Metals
Wastes identified as hazardous based on the characteristics of ignitability (D001),
corrosivity (D002), reactivity (D003), or organic toxicity (D012-D043) currently are subject to
LDRs (unless the waste is a newly identified mineral processing waste). Phase IV would require
more stringent treatment if these wastes contain metals above the revised UTS for non-
wastewaters. These wastes are not eligible for a national capacity variance if there is
insufficient alternative commercial treatment capacity.
Page 9
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Page 10
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2.0 UNIVERSE OF INJECTED PHASE IV WASTES
This section identifies the facilities injecting wastes affected by the Phase IV rule, and
quantifies the volume of waste potentially prohibited from injection. The following sources were
used to define the universe of injected wastes and facilities potentially affected by the Phase IV
rule.
• UICWELLS - Class I Injection Wells Database Version 6 (updated through
1995) developed by EPA;
• The 1993 Biennial Reporting System (BRS) for the Hazardous Waste
Report required by sections 3002 and 3004 of RCRA;
• Public Comments to the proposed Phase IV rule;
• EPA, Background Document - Identification and Description of Mineral
Processing Sectors and Waste Streams, December 1995;
• Federal Register Notices 60 FR 43654, 61 FR 2338, 61 FT? 21417, 62 FR
25998, and 62 FR 26041 establishing treatment standards for newly listed
and identified wastes; and
• Personal communications with injection well operators, and EPA Regional
and State UIC program personnel.
2.1 Affected Class I Universe
Hazardous waste injection began in the 1950s. In response to the Safe Drinking Water
Act, EPA promulgated regulations in 1980 governing all injection wells including those injecting
hazardous waste. In 1984, Congress banned most forms of land disposal of untreated waste,
including injection wells, unless EPA determined that a prohibition was not required to protect
human health and the environment. In 1988, EPA passed additional regulations requiring Class I
operators to prove protectiveness by submitting a "no-migration" petition demonstrating that
waste would not migrate from the injection zone for as long as it remained hazardous. Well
operators who do not submit petitions must either treat or remove the banned substances or cease
injection of the waste. For characteristic wastes, treatment can include dilution of the waste. For
listed wastes, treatment does not include dilution, except for a limited number of listed wastes
(i.e., wastes listed based solely on a characteristic).
Page 11
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Class I wells, by definition, inject municipal or industrial waste beneath the lowermost
underground source of drinking water (USDW). A USDW is an aquifer or portion of an aquifer
that supplies a public water system (PWS), does not presently supply a PWS but contains enough
water to supply a PWS, or which contains less than 10,000 milligrams/liter of total dissolved
solids (TDS). According to 1995 Agency data3, there are a total of 227 Class I underground
injection facilities operating 537 Class I wells. Exhibit 2-1 presents a list of all Class I
underground injection facilities including identification numbers and commercial/noncommercial
status. The table does not include 45 Class I municipal wells recently constructed and located in
Florida that do not inject RCRA hazardous wastes. Presented below is a summary of selected
characteristics of Class I wells and facilities.
Type of Well
Hazardous
Nonhazardous
Commercial
Hazardous
Nonhazardous
Noncommercial
Total Wells
165
372
60
21
39
477
Type of Facility
Commercial
Noncommercial
Total
Total Facilities
41
186
227
2.2 Facilities Injecting Phase IV Wastes
Using available injectate data for each of these facilities and additional available process
description data, EPA identified the Class I facilities currently disposing Phase IV restricted
wastes in underground injection wells. For most of the sites, well injectate data was available for
aggregate injectate only, which may include other wastes not covered by the Phase IV rule. In
addition, there are data gaps for other facilities that require a number of assumptions to be made
in characterizing the injectate (i.e., lack of UHC data). Because of uncertainties, the facilities
identified are described as potentially injecting restricted Phase IV waste. Exhibit 2-1 presents
the Class I universe of facilities and highlights the those facilities that are potentially injecting
Phase IV restricted wastes. Appendix A describes the detailed methodology used to identify
these facilities.
Using additional well-specific data (i.e., well flow rates and operating status) and injected
waste volumes as reported in the BRS, EPA estimated the amount of restricted waste disposed of
at each facility. EPA estimates that 46 Class I facilities potentially inject a combined total
volume of approximately 45 million metric tons per year of Phase IV waste at the high-end. The
actual volume of Phase IV waste is likely to be substantially less because: (1) some of the
3UICWELLS, Class I Injection Wells Database, Version 6.
Page 12
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in their petitions wastes and constituents that will be affected by the Phase IV LDRs. In
addition, the strategy used to demonstrate no migration by many petitioners is to model the
fate and transport of the most mobile waste or constituent and demonstrate how other wastes
and constituents are less mobile. This strategy might be adopted by some facilities for new
constituents, thus possibly streamlining the approval of the petition modifications. For
capacity analysis purposes, we will assume that facilities with approved no-migration
petitions that may require modification to their petitions are likely to be few, will be granted
an extension, and will continue to manage their Phase IV wastes by underground injection.
• Some non-commercial facilities that currently inject Phase IV wastes have submitted no-
migration petition applications but likely will not receive approval in time to avoid the Phase
IV land ban. These facilities might request a case-by-case extension using their no-migration
petition submittal to demonstrate a good faith effort to meet the requirements of the Phase IV
LDRs. Without reviewing each case individually, it would be difficult to predict which
facilities would likely receive an extension. For capacity analysis purposes, we will assume a
worst- and best-case scenario, where all these facilities will either cease managing their Phase
IV wastes by underground injection or receive exemptions, respectively.
Facilities with approved no-migration petitions were identified from the UIC database and
internet searches of the Federal Register database (electronic searchable versions of the Notices
are available from January 1, 1994, forward covering the time since the UICWELLS database
was last updated). Table 2 lists Class I underground injection facilities with an approved no-
migration petition and a notation indicating whether the facility is identified as potentially
managing Phase IV waste. Of the 227 Class I facilities identified in the database, 46 have
approved no-migration petitions. Of these Class I facilities with approved no-migration
petitions, 28 potentially manage Phase IV wastes.
Facilities Without LDR Exemptions
Facilities identified as potentially managing Phase IV wastes in a Class I underground
injection well without an approved no-migration petition or LDPFA exemption are listed on
Table 3 with a notation indicating whether the facility has submitted a no-migration petition for
approval. Thirteen facilities that potentially manage Phase IV wastes do not have approved no-
migration petitions. . Two facilities, CECOS, TX and Loving Co., TX are commercial facilities
and the remaining 12 facilities are noncommercial. Only four of these facilities have submitted a
petition to EPA for approval. The status of the petition review is not known at this time. EPA
denied a no-migration petition for one facility, CECOS in Texas.
10/9/97
Page 13
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NEXT STEPS
The next steps to completing the Class I injection well study, based on the preliminary
findings summarized in this memorandum, include: (1) finalize the identification of facilities
managing Phase IV wastes by Class I underground injection that will not be granted an extension
or exemption from the LDRs prior to the effective date of the treatment standards; and (2)
analyze the availability of alternative treatment or injection capacity for those facilities or wastes
that will not be granted an extension or exemption from the LDRs. Discussed below are the
outstanding issues that need to be resolved to complete both stages of the study. We note that the
final results of the first stage may show that further analysis of alternative treatment and injection
capacity may not be warranted. For example, if the first stage results indicate that a large
majority of facilities and generators will be exempt from the land ban, and that the universe of
facilities and generators that will have to modify management of their wastes as a result of the
land ban is small, the Agency may decide not to provide a national capacity variance and to
regulate the facilities and generators subject to the land ban on a case-by-case basis.
Outstanding Issues Near Resolution for the First Stage
• Validate our assumptions and interpretations regarding the rules and regulations affecting the
Phase IV Class I injection well study. Specifically: the case-by-case extension process, the
use of a no-migration petition and LDPFA exemption to avoid the LDRs, and the assumption
that the Agency will grant modifications to approved petitions to cover Phase IV wastes prior
to the land ban.
• Verify that certain facilities actually manage Phase IV wastes by underground injection.
Summarized below are the outstanding issues for these facilities.
1) For the DuPont, TN, Zinc Corporation of America, OK, and Dakota Gasification Co., ND
facilities, identified as mineral processing operations, there is no constituent data in
UICWELLS to verify that the wastes injected are characteristic hazardous wastes. Waste
descriptions and volumes must be researched for these facilities.
2) UICWELLS does not list waste codes for Koch, KS, Rockwell, OK and Loving Co., TX
facilities, and more information is needed to verify that TC wastes are injected at theses
facilities.
3) UICWELLS does not list waste codes for the Hoskins, IN and MI facilities, and
Macklanburg-Duncan, OK facility. More information is needed to verify that listed
wastes with UHCs above UTS are injected at these facilities.
• Obtain additional information to verify that the 13 facilities identified as potentially
managing Phase IV wastes without LDR exemptions are not exempt small quantity
generators. The BRS and the new National Constituents Survey results from the Office of
Solid Waste (OSW) should provide data on waste quantities and waste type to validate our
characterization of the wastes.
10/9/97
Page 14
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• Identify other Class I facilities managing Phase I wastes not yet identified and generators
managing Phase IV waste in commercial Class I wells. The BRS should provide data on
waste streams received at both noncommercial and commercial Class I wells that will be
useful in identifying these facilities.
Second Stage Next Steps
• For facilities that will be affected by the Phase IV land ban, review the affected waste streams
to determine the type of treatment that would be appropriate to meet UTS. Research the
industry to determine whether process changes can recover or recycle wastes or readily
incorporate treatment into the process.
• For facilities that will not be able to treat, recycle, or recover the affected waste streams,
locate, if available, commercial facilities that can accept and treat the waste stream. We will
rely on the information on commercial treatment facilities developed for the Background
Document for the surface disposed wastes capacity analysis ,5
• For facilities that will not be able to treat, recycle, or recover the affected waste streams,
locate, if available, commercial Class I facilities that have unused capacity and can inject
Phase IV wastes. The commercial Class I facilities with approved no-migration permits have
been identified. We will use the injection rates and volumes found in the UICWELLS,
supplemented with additional data from EPA and state UIC Program regional offices to
calculate the remaining capacity of commercial Class I wells that can accept Phase IV wastes.
• Prepare a draft report that summarizes our findings regarding Class I injection of Phase IV
wastes.
5EPA, Background Document for Capacity Analysis for Land Disposal Restrictions - Phase IV (Second
Supplemental): Toxicity Characteristic Metals Wastes and Newly Identified Mineral Processing Wastes (Proposed
Rule) April 1997.
Page 15
10/9/97
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TABLE 1. CLASS I UNDERGROUND INJECTION WELLS
Facility 11) #:
Facility Name
CI II
CI Ml
Type
No-Migration
Petition Status
Kxceeds UTS
(nietal-mg/l)
Potentially
Injects Phase
IV Wastes
Fxplanation/Cominent
AKD991281221
ARCO Alaska Inc. Prudhoe Hay Operations
0
3
C
None
110
ALASKA TOTALS:
0
3
0
ARIO-IJ
Circal Lakes Chemical Corp. (South Plant)
0
4
NC
None
no
AR2-U
Great Lakes Chemical Corporation
0
4
NC
None
no
AR4-URI
Albemarle Corporation
0
4
NC
None
no
AR5-U
Great Lakes Chemical Corp. Newell Plant
0
2
NC
None
no
AR8-IJ
AR8-U
AR8-U
Red River Aluminum, Inc.
0
1
NC
None
Barium-25
Lead-1.25
Silver-1.36
no
Below TC, nonhazardous
AR9-IJ
Great Lakes Chemical Corp. (West Plant)
0
2
NC
None
110
AR?-U
Kthyl Corporation (Magnolia)
2
0
NC
Approved
yes
No code, various organic
solvents, organoarsenie
compound, likely listed wastes
with metal UHCs (see Notel)
ARKANSAS TOTALS:
2
17
1
CA191000001
Zonal Molding Corporation(Envrwlls)
0
1
C
None
110
CA192000001
SMS Brincr
0
1
C
None
no
CA 194000001
Sacramento Ethanol Partners (SEPCO)
0
1
C
None
no
CA 194000002
Northern California Power Agency
0
1
c
None
no
CA59400000I
San Joaquin CoGcn Limited
0
1
c
None
110
CALIFORNIA TOTALS:
0
5
0
CO-1
U.S. Corps of Engineers
0
0
NC
None
no
C01042-0053
Shell Western E&P, Inc. (Movenweep)
0
1
NC
None
no
CO 1043-0054
Shell Western E&P, Inc. (Yellow Jacket)
0
1
NC
None
no
CO 1044-0055
ARCO Permian (Garola)
0
1
NC
None
no
CO 1104-0420
Shell Western E&P, Inc. (Woods #3 MWD #1)
0
1
NC
None
110
CO 1516-021 15
Wright's Disposal, Inc. (Sukla Farms)
0
0
C
None
no
COLORADO TOTALS:
0
4
0
FLS101705471
Monsanto Chemical Co.
0
3
NC
None
110
11. SI 05001
FLS10500I
Kaiser Aluminum & Chemical Company
1
0
NC
Approved
Arsenic-12
Cadmium-0.23
yes
1)002 with UIKMJTS, Na/K
silicofluoridc production (see
Note 1)
M.S 105705474
Cytcc Industries
0
1
NC
None
no
I'l.S 300506415
Man is Corporation
0
2
NC
None
no
1-1 -S 303108055
Indian River County Utility Services
0
1
LINK
None
no
I'l .S400807931
Zcmcl Road Landfill
0
1
NC
None
no
-------
TABLE 1. CLASS I UNDERGROUND INJECTION WELLS
facility ID #:
Facility Name
CI 11
CI Nil
Type
No-Migration
Petition Status
Kxceeds UTS
(metal-mg/1)
Potentially
Injects Phase
IV Wastes
Kxplanation/Comment
FLS405801738
Sarasota County FDR- Sar. Cty Utilities Dept.
0
1
NC
None
110
FLS405805520
Plantation • Sarasota County Utilities Dept
0
1
NC
None
no
FLS405806573
Fnglewood
0
1
NC
None
110
l;LS405 806588
Venice Gardens Utility
0
1
NC
None
110
FLS500606577
City of Plantation Water Treatment Plant
0
2
NC
None
110
FLS505005556
QO Chemical, Inc.
0
2
NC
None
no
IUS5050P05378
Acme Improvement District
0
0
NC
None
110
FLS505006578
United Technologies - Pratt and Whitney
0
1
NC
None
no
FLS505007543
Palm Beach County Solid Waste Authority
0
2
NC
None
no
FLS505007547
Jupiter
0
1
UNK
None
no
FLS50500789I
City of Boynton Beach W Water Treatment Plant
0
1
NC
None
no
FI.S513105560
Hercules, Inc.
0
1
NC
None
no
FLS514306722
North Martin County Utilities
0
1
NC
None
no
FLS521102483
Marco Island Utilitics-SSU Services
0
1
NC
None
no
FI.S521108024
North Collier County Collier County Utilities
0
1
NC
None
no
FLS523607770
Gulf Utility
0
1
NC
None
no
FLORIDA TOTALS:
1
112
1
45 addtl facilities w/ 86 Nil wells
that do not manage Phase IV
wastes, adjusted total 112 NH
11,1)000781591
LTV Steel Company (llennepin Works)
1
0
UNK
Approved
Silver-0.16
yes
K062 w/UIIC>UTS,
neutralized waste pickle liquor
I1.D005078126
Quantum, USI Division
0
1
UNK
None
no
11,1)005463344
Allied-Signal, Inc.
1
0
UNK
Approved
yes
1)004 (see Note 1)
IL.D042075333
Cabot Corporation
2
0
NC
Approved
yes
ILLINOIS TOTALS:
4
1
3
IN-039-11-0001
Hosldns Manufacturing Company
0
1
NC
None
Chromium-
yes
No code, neutralized waste
pickle liquor (likely K062 w/
UHOUTS) (see Note 2)
IN-089-IW 00! 1
IN-08'J-1W-0011
USX Corporation
0
1
UNK
Withdrawn
Lcad-23
Chroiniuni-39
yes
K062 w/ U11C>U I S, abondoncd
wells no longer accepting waste.
IN-O89-IW-00I2
Inlaml Steel Corporation (Indiana Harbor)
2
0
UNK
Withdrawn
no
iN-oy i-1 i-oooi
Criterion Catalyst Company
0
2
NC
None
110
IN-127-11-0007
ISK Magnetics, Inc.
0
2
NC
None
110
IN-127-1W-0001
1N-127-1W-0001
Bethlehem Steel Corporation (Burns Harbor)
3
0
NC
Approved
Chroniiuiii-65.8
Nickel-18
yes
1)010, 1)018, K062 spent NII4
liquor from coke product (see
Note 1)
-------
TABLE 1. CLASS I UNDERGROUND INJECTION WELLS
Facility ID #:
Facility Name
CI II
CI Nil
Type
No-Migration
Petition Status
Kxceeds UTS
(metal-mg/l)
Potentially
Injects Phase
IV Wastes
Kxplanation/Comment
IN-I27-IW-0006
IN-127-1W-0006
lN-127r|W-0006
IN-127-1W-0006
IN-I27-IW-0006
Midwest Steel Division of National Steel Corp
1
0
NC
Approved
Cadmium-21
Chromium-65.2
Silver-0.72
Nickel-18
Zinc-7.56
yes
K0G2 \v/ UIICMJTS, spent acid
from steel pickling process
IN-163-11-0001
Turns Coal Company
0
1
NC
None
no
INDIANA TOTALS:
6
7
4
KS-01 -051-001
Hxidc
0
1
NC
None
no
KS-01-053-001
F.nron Gas Processing Co.
0
6
NC
None
no
KS-01-055-001
Val Agri, Inc. d/b/a Monfort
0
1
NC
None
no
KS-01-055-002
Iowa Beef Processors Inc. (Finnay.Lyon sites)
0
2
NC
None
no
KS-01-057-001
Farmland Industries, Inc.
0
3
NC
None
no
KS-01-067-001
AMOCO Production Company
0
4
NC
None
no
KS-01-077-001
Trident NGL, Inc.
0
2
NC
None
no
KS-01-091-001
Johnson County Landfill
0
1
NC
None
110
KS-0I-093-00I
Colorado Interstate Gas Co.
0
2
NC
None
110
KS-01-095-001
Phillips Petroleum Company
0
1
NC
None
no
KS-01-097-001
Northern Natural Gas Company (Kiowa)
0
1
NC
None
no
KS-01-113-002
National Cooperative Refinery Corporation
0
1
NC
None
no
KS-01-113-003
KS-01-113-003
KS-01-113-003
KS-01-113-003
KS-01-113-003
Koch Underground Storage Co. (Conway/Rlddell)
0
5
NC
None
Arsenlc-10
Chromium-1.0
Cadntluni-1.0
Lead-2
Silver-1.0
yes
No codes, hydrocarbon waste
brine vr/ As>TC, (see Note 2)
KS-01-113-006
Texaco Trading and Transportation, Inc.
0
2
NC
None
no
KS-01 -125-001
Sherwin-Williams Company
0
3
NC
None
Zinc-83
110
KS-01-155-002
Koch Hydrocarbon Company (Fractionation)
0
4
NC
None
110
KS-01 -155-004
Morton Salt, Inc.
0
1
NC
None
no
KS-01 -155-005
Western Resources, Inc.
0
2
NC
None
Silver 0.12
110
Waste brine and surfactant,
nonhazunlous waste
KS-01 -155-007
Koch Hydrocarbon Company (Hillside)
0
2
NC
None
110
KS-01-155-008
Ferrellgas
0
1
NC
None
no
KS-01-159-001
North American Salt Company
0
5
NC
None
no
KS-01-159-002
MAPCO/Mitchell, MAPCO/Conway (KS-01-113-001)
0
3
NC
None
no
KS-01-159-003
Northern Natural Gas Company (Rice)
0
1
NC
None
no
KS-01-165-001
Kansas Rel. Helium Company
0
1
NC
None
no
KS-01 -173-001
Abbott Laboratories
1
0
NC
Approved
no
KS-01-173-002
Air Products Corporation
1
0
NC
Approved
no
KS-01-173-003
High Plains Corp.
0
0
IJNK
None
no
-------
TABLE 1. CLASS I UNDERGROUND INJECTION WELLS
Facility 11) #:
Facility Name
CI II
CI NH
Type
No-Migration
Petition Status
ICxceeds UTS
(metal-mg/1)
Potentially
Injects I'hase
IV Wastes
Fxplanation/Comment
KS-01-173-004
Vulcan Chemicals
8
0
NC
Approved
Antimony-1.4
yes
No waste code, organic chem.
prod, likely listed waste w/
IJIIC>UTS (possibly K071 or
K106) (see Note 1)
KS-01-175-001
Northern Natural Gas Company (Seward)
0
1
NC
None
no
KS-ARCO
ARCO Oil & Gas Corporation
0
1
NC
None
110
KS-EMP1RE
Empire Gas Corp.
0
1
NC
None
110
KS6599
Winficld State Training School
0
1
NC
None
no
KS8238
Sentry
0
1
110
KANSAS TOTALS:
10
60
2
KVS0310117
Imco Recycling, Inc.
0
1
NC
None
110
KVS1110001
E.l. duPont, Louisville Works
2
0
UNK
Approved
110
KENTUCKY TOTALS:
2
1
0
LA2330
Hallar Enterprises, Inc.
0
1
C
None
110
I.A6581
Witco Chemical Corporation
0
1
NC
None
no
LAD000618256
Cecos International (Willow Springs)
1
0
C
Approved
An
-------
TABLE 1. CLASS I UNDERGROUND INJECTION WELLS
Facility II) U:
Futility Naine
CI 11
c:i nii
Type
No-Migration
Petition Status-
Kxcecds UTS
(metal-nig/l)
Potentially
Injects Phase
IV Wastes
ICxplanation/Coimnent
M1-077-1VV-0(101
M1-077-1W-0001
The IJpjohn Company
2
0
NC
Approved
Chromium-261
Zinc-564
yes
1)001,1)007,1)035, L>038 (see
Note 1)
Ml-()y 1-11-0001
Great Lakes Cliemieal Corporation
0
1
NC
None
no
Ml-133-11-0001
Kalitim Chemicals
0
2
NC
None
110
M1-135-11-0001
Hoskins Manufacturing Company
0
i
NC
None
Chromium-1.4
yes
No code, neutralized waste
pickle liquor, (likely K062 w/
UHC>UTS) (see Note 2)
Ml-137-11-0001
Standard Products
0
l
NC
None
110
Ml-139-11-0001
H.J. Heinz. Company
0
3
NC
None
110
Ml-139-1W-0001
BASF Chemicals Division
0
2
NC
Withdrawn
no
MI-139-1W-0003
Parke-Davis Division of Warner Lambert
0
3
NC
Pending
yes
D004-D011, D018, D035, D038
(see Note 2)
MI-I43-1I-C00I
Beckman Production Services, Inc.
0
1
C
None
Barium-21
no
M1-161 -11 -0001
Gelman Sciences, Inc.
0
1
NC
None
no
Ml-163-1W-0003
Detroit Coke Company
0
3
NC
Withdrawn
110
Ml-163-1W-0006
Environmental Disposal Systems
0
1
C
Planned
110
Ml-165-11-0001
Pillsbury Company
0
1
NC
None
no
MICHIGAN TOTALS:
2
23
3
MSI1001
MSUOOI
MSI1001
duPont DeLlsle Plant-White Pigment & Mineral
0
4
NC
Planned-Phase 4
Chromium-604
Lead-151
Vanadium-458
yes
Mineral process waste -TI02
pigment, air emiss abatemnt
process waste (see Note 2)
MSI 1004
F.nglehard Corporation
0
1
NC
None
no
MSS05900I
Morton International, Inc.
2
1
NC
Approved
yes
MISSISSIPPI TOTALS:
2
6
2
ND-UIC-101
Dakota Gasification Company
0
2
NC
None
yes
No codes, no constituent
information (see Note 2)
ND-UIC-104
International Salt Company
0
1
NC
None
no
NORTH DAKOTA TOTALS:
0
3
1
NM990753931
Climax Chemical Company
0
1
NC
None
no
NHW MRXICO TOTALS:
0
1
0
OH-02-18-017
Ak/.o Nobel Salt, Inc.
0
1
NC
None
110
011-02-43-006
Zeneca Ag. Products
0
2
NC
None
IK)
()11-03-02-003
HI* Chemicals
4
0
NC
Approved
yes
1)004-1)011,1)018, 1)019, 1)038
(see Note 1)
-------
TABLE 1. CLASS I UNDERGROUND INJECTION WELLS
Facility ID H:
Facility Name
CI H
CI NH
Type
No-Migration
Petition Status
Exceeds UTS
(metal-nig/l)
Potentially
Injects Phase
IV Wastes
Explanation/Comment
Ol 1-05-09-001
011-05-09-001
011-05-09-001
011-05-09-001
AK Steel Co.
2
0
NC
Approved
Cadmium-0.25
Chromium-15
Lead-4.9
Silver-0.27
yes
K062 w/ IJI1C>IJTS (see Note 1)
OII-CWM
OII-CWM
OII-CWM
Chemical Waste Management, Inc.
5
0
C
Approved
Chromium-1442
l.ead-31
Nickcl-368
yes
K062 w/ IJIIOUTS (see Note 1)
OHD005108477
Arislech Chemical Corporation (Haverhill PI)
0
3
NC
Withdrawn
no
OHD980793384
Reserve Environmental Services, Ine
0
1
C
None
no
OHIO TOTALS:
11
7
3
OKD-SW-35I90I'
1MCO Recycling, Inc.
0
1
NC
None
110
OKD000402396
Perma Fix Treatment Services, Inc.
0
2
C
None
yes
OKD000829440
Zinc Corporation or America
0
2
NC
None
yes
Mineral processing waste, zinc
wastewater, no constituent data
(see Note 2)
OKD()OI8245(. 1
OKD001824561
OKD00182456-4
American Airlines
0
2
NC
None
Antimony-0.35
Chromium-1.1
Thallium-0.2
no
No codes, nonha/.ardous ground
surface wash water
OKD007188063
OKD007188063
Macklanburg • Duncan
0
1
NC
None
Antlmony-0.35
Thallium-0.2
yes
No code, Al anodizing
wastewaters, zinc plating
wastewaters (likely F006-F009)
(see Note 2)
OKD00722026
OKD00722026
Rockwell International
0
1
NC
None
Antimony-0.35
Thalliuro-0.2
yes
No codes, likely TC waste,
metal
finishing rlnsewater w/
UHC>UTS (see Note 2)
OKD07866I279
Wil-Gro Fertilizer
0
1
NC
None
no
OKD098466568
Kaiser Chemical (Plant Shut Down)
0
2
NC
None
no
OKLAHOMA TOTALS:
0
12
4
TNS0850004
DuPont Chemicals
0
3
NC
Planned-Phase 4
yes
Mineral processing waste •
titanium dioxide prod., no
constituent data (see Note 2)
TNS1190002
Zcncca Specialties
0
3
IJNK
Planned-Phase 3
no
TliNNIiSSlili TOTALS:
0
6
l
rxi) winv-002
Monsanto Company (Chocolate Bayou Plant)
5
0
NC
Approved
yes
D004-D011, D038 (see Note 1)
TX1) WDW-004
TX1) WDW-004
K.I. duPont de Nemours and Company (Victoria)
II
0
NC
Approved
Nickel-86.5
Vanadium-8.8
yes
D001-D01I, D0I2-D043 (see
Note 1)
-------
TABLE 1. CLASS I UNDERGROUND INJECTION WELLS
Potentially
No-Migration
Exceeds UTS
Injects Phase
Facility ID #:
Facility Name
CI II
CI Nil
Type
Petition Status
(metal-mg/1)
IV Wastes
Explanation/Comment
TXl) VVDW-014
Hoechst Celanese Chemical Company (Bay City)
5
0
NC
Approved
Nickel-1500
yes
Wells 49, 110,277 - D001.D002
(see Note 1)
TXD WDW-016
Rexene Products Co. (Odessa Petrochemical)
5
0
NC
Unknown??
yes
D007, D018, and other U&P
waste codes (see Note 2)
TXD WDW-020
Diamond Shamrock Corporation (McKec Plant)
0
5
NC
Planned
no
TXl) WDW-033
lloechst Celanese Chemical Co. (Clear Lake)
3
0
NC
Approved
yes
D004-D011 (see Note 1)
TXD WDW-034
ISP Technologies, Inc. (Texas City)
0
4
NC
Pending
yes
TXD WDW-036
Lyondell Petrochemical Co. (Channclview)
1
0
NC
Approved
110
TXD WDW-051
BASF Corporation (I-reeport Road)
0
2
NC
95propsd apprl
yes
TXI) WDW-054
E.l. dul'ont de Nemours and Company (Sabine)
6
0
NC
Approved
Chroinium-2.5
yes
D002,D003,1)005,1)007-1)009,
1)018,1)021-1)028 (see Note 1)
TXD WDW-067
Phillips 66 Co. (Borgcr Refinery)
0
4
NC
None
Lead-1.7
yes
Decharacteri/.ed D001, high TOC
(16800)
TXD WDW-070
Disposal Systems of Corpus Christi, GNR Croup
1
0
C
Approved
yes
D004-D011,1)012-1)043 (see
Note 1)
TXD WDW-080
Amoco Oil Company (Texas City Plant)
5
0
NC
Approved
no
TXD WDW-082
F..I. duPont dcNemours and Company (Houston)
0
3
NC
None
110
TXD WDW 091
Sterling Chemicals (Texas City)
3
0
NC
Approved
no
TXD WDW-100
Is.I. duPont dc Neinours Co. (Beaumont Plant)
3
0
NC
Approved
no
TXD WDW-111
Witeo Chemical Corporation (Rctzlol'f)
0
2
NC
None
no
TXD WDW-115
Cominco Fertilizers (US), Inc. (Borger Plant)
0
2
NC
None
no
TXD WDW-117
Jetco Chemicals, Inc. (Amine Plant)
0
1
NC
None
no
TXD WDW-120
Iowa Beef Processors, Inc.
0
2
NC
None
Chromium-1 0
IK)
nonha/.ardous waste
TXD WDW-122
Atochem North America, Inc. (Crosby Plant)
0
2
NC
Unknown '?'!?
no
TXD WDW-123
U.S.X.-Texas Uranium Operations (Clay)
0
3
NC
None
110
TXD WDW-125
Sandoz Crop Protection Corp. (Beaumont Plant)
0
5
NC
None
no
TXD WDW-129
Asarco, Inc. (Amarlllo Copper Reflnery)
0
2
NC
Pending
Antimony-2.7
yes
D002, D004, D006-D008,
TXD WDW-129
Cadmiura-OJ
D010, D011,Se,Te plant
TXD WDW-129
Chromium-21.4
mineral processing wastes
TXD WDW-129
Lead-1.3
(see Note 2)
TXD WDW-129
Selenium-6.1
TXD WDW-129
Silver-0.2
TXD WDW-130
U.S.X - Texas Uranium Operations (Burns)
0
1
NC
None
110
TXD WDW-134
Chevron (Palangana Dome Site)
0
1
NC
None
no
TXD WDW-135
Texaco Refining and Marketing (Amarillo)
0
2
NC
None
no
TXD WDVV-138
Malone Services Company
2
0
C
Approved
TC
1)004-1)01 l(see Note 1)
TXD WDW-140
U.S.X. Texas Uranium Operation (Boots)
0
2
NC
None
no
TXD WDW-146
CECOS International, Inc., (Odessa)
0
1
C
Denied
TC
D006-D009, other F, K, P, U
waste codes (see Note 2)
TXD WDW-147
Meridiem Company
2
0
c
Approved
yes
TXD WDW-148
Arco Chemical Company (Channclview Plant)
2
0
NC
Approved
no
TXD WDW-150
Cogcma Mining, Inc.
0
3
NC
None
no
-------
TABLE 1. CLASS I UNDERGROUND INJECTION WELLS
Facility ID#:
Facility Name
CI II
CI NH
Type
No-Migration
Petition Status
Exceeds UTS
(nietal-mg/1)
Potentially
Injects Phase
IV Wastes
ICxplanat ion/Comment
TXD WDW-I.S2
Occidental Petroleum Corp
2
0
NC
Approved
no
TXD WDW-156
Intercontinental Energy Corp. (Lamprccht)
0
1
NC
None
Chromitmi-609
110
Uranium Mine - Bevill exclusion
(extraction)
TXD WDW-157
Kmpak, Inc.
1
0
C
Approved
yes
D004-D011, D012-D043 (see
Note 1)
I XD WDW-IW
Intcrcominental Energy Corp. (Zamzow)
0
1
NC
None
Chromium-495
no
Uranium Mine, Bevill exclusion
(extraction)
1X1) VVDVV-160
Chemical Waste Management (Port Arthur)
'
0
C
Approved
yes
D004-D011, D012-D043 (see
Note 1)
TXD WDW-163
BP Chemicals America Co.
3
0
NC
Approved
yes
1)004-1)011, DO 18, D019, D038
(see Note 1)
TXD WDYV-167
Wastewater, Inc.
'
0
C
Approved
yes
D004-D011, 1)012-1)017 (see
Note 1)
TXD WDW-168
Everest Exploration, Inc. (Hobson)
0
3
NC
None
110
TXD WDW-169
Disposal Systems, Inc.
2
0
C
Approved
yes
D004-D011, D012-D017 (sec
Note 1)
TXD WDW-170
Westinghouse Electric Corp (Brown Mine)
0
1
NC
None
110
TXD WDW-172
Shell Chemical Company (Deer Park)
0
2
NC
None
110
TXD WDW-180
Witco Chemical Company (Marshall Plant)
2
0
NC
Approved
110
TXD WDW-185
Everest Exploration, Inc.
0
1
NC
None
110
TXD WDW-186
American Ecology Corp.
2
0
C
Approved
yes
TXD WDW-187
Everest Mineral Corp (Las Palmas Mining)
0
1
NC
None
no
TXD WDW-190
IEC Corporation (Pawnee Mine)
0
1
NC
None
110
TXD WDW-194
Everest Mineral Corporation (Mt. Lucas)
0
1
NC
None
no
TXD WDW-195
Cogema Mining,Inc (West Cole Facility)
0
1
NC
None
no
TXD WDW-210
Hoechst Celanese Chemical Co.
3
0
NC
Approved
yes
1)004-1)011,1)018,1)035 (sec
Note 1)
TXD WDW-222
Hampshire Chemical Corporation
0
2
NC
None
Chromium-1.1
no
Below TC
TXD WDW-231
Vclsicol Chemical Corp.
2
0
NC
None
no
TXD WDW-244
Celanese Chemical Company
2
0
NC
None
110
TXD WDW-247
Uranium Resources, Inc. (URI)
0
2
NC
None
110
TXD WDW-250
Uranium Resources, Inc. (Rosita Project)
0
1
NC
None
no
TXD WDW-275
Loving Co. Disposal, Inc.
0
2
C
Pending
yes
No codes, spent metallic
solutions, alkaline wastes, no
constituent data (see Note 2)
1X1) WDW-278
Texas Ideologist, Inc.
2
0
NC
Approved
yes
1)004-1)011, 1)012-1)043 (sec
Note 1)
TXD WDW-280
Power Resources, Inc
0
2
NC
None
110
TXD WDW-308
Uranium Resources, Inc (Vasquez Project)
()
2
NC
None
110
TXD WDW 310
Crossroads Environmental Corporation
0
2
C
None
no
TXD WDW-311
Thomas Disposal Co.
0
1
C
None
110
TXD WDW-313
Triple P Disposal Company
0
1
C
None
no
-------
TABLE 1. CLASS 1 UNDERGROUND INJECTION WELLS
Facility ID#:
Facility Name
CI II
CI Nil
Type
No-Migration
Petition Status
Kxcceds UTS
(metal-mg/l)
Potentially
Injects Phase
IV Wastes
Kxplanation/Comment
I XD WDW-316
Environmental Processing Systems
0
2
C
None
no
TEXAS TOTALS:
77
77
21
WY87-339
Oedckovcn Water & Hot Oil Svc. (Olsen)
0
1
C
Unknown ??
no
WY87-457
Oedekoven Water & Hot Oil Svc. (Morse Ranch)
0
1
c
None
no
WY88-545
Cogema Mining, Inc. (Christensen Ranch)
0
1
c
Unknown??
110
WY89-030
Power Resources (Morton)
0
1
c
None
110
WY89-192
Coastal Chemical
0
4
NC
None
no
WY89-198
Prima Exploration (C-H Minnelusa)
0
1
c
None
no
WY89-275
Cogema Mining, Inc. (North Butte)
0
2
NC
Unknown ??
no
WY89-285
Amoco Oil Company (Beaver Creek)
0
2
NC
None
no
WY89-379
H&M Disposal (C.G. Nicolaysen) (Cole Creek)
0
1
C
None
110
WY 89-449
Chevron (Carter Creek)
0
' 2
NC
None
Vanadium-110
no
No code, non-hazardous
washwater waste
W Y89-520
Amoco Oil Company (Whitney Canyon)
0
2
NC
None
no
WY90-223
Kissack Water & Oil Service (Shell Fox)
0
1
C
Unknown??
110
WY91-046
Kissack Water & Oil Service
0
1
C
Unknown??
no
WY9I-I66
Kissack Water & Oil Service (Federal)
0
2
c
Unknown??
110
WY9I-247
Cogema Mining, Inc. (Irigaray)
0
1
NC
Unknown ??
no
WY91-264
Kissack Water & Oil Service (Keuhne)
0
1
C
None
110
WY93-294
WY Waste Water Disposal Co.(Laramie Facility)
0
1
C
Unknown??
110
WY95-030
Cortcz Energy Company
0
1
C
Unknown??
110
WY95-277
KFx/Thermo - F.cotek Corporation
0
1
NC
Unknown ??
no
WYOMING TOTALS:
()
27
0
NATIONAL TOTALS
135
394
FACILITIES -W/ APPROVED NO-MIGRATION PETITIONS
46
FACILITIES POTENTIALLY INJECTING PHASE IV WASTES
50
FACILITY TYPE
COMMERCIAL
41
NONCOMMERCIAL
177
UNKNOWN
9
NOTKS:
1. Facilities highlighted in bold text are identified as potentially managing Phase IV wastes.
2 I-acillics highlighted in bold text and shading are identified as potentially managing Phase IV wastes but without an approved no-migration petition.
CM II = Class I hazardous underground injection well.
CI Nil = Class I nonha/.ardous underground injection well.
Type = Commercial (C), Noncommercial (NO, Unknown (IJNK)
-------
TABLE 2. CLASS I UNDERGROUND INJECTION WELLS WITH APPROVED NO
MIGRATION PETITIONS
Potentially Injects Potentially Injects
Name Phase IV Waste Name Phase IV Waste
Ethyl Corp., AR
No
Monsanto, TX
Yes
Kaiser Aluminum, FL
Yes
DuPont-Victoria, TX
Yes
LTV Steel, IL
Yes
Hoechst-Bay City, TX
Yes
Allied-Signal, IL
Yes
Hoechst-Clear Lake, TX
Yes
Cabot Corp., IL
No
DuPont-Sabine, TX
Yes
Bethlehem Steel, IN
Yes
Disposal Systems-Corpus,TX
Yes
Midwest Steel, IN
Yes
Amoco-Texas City, TX
No
Abbott Labs, KS
No
Sterling. TX
No
Air Products, KS
No
DuPont-Beaumont, TX
No
Vulcan Chemicals, KS
Yes
Malone Services, TX
Yes
DuPont, KY
No
Merichem, TX
No
CECOS, LA
Yes
Arco-Channelview, TX
No
Rollins, LA
Yes
Occidental Pet., TX
No
DuPont, LA.
Yes
Empak, TX
Yes
Cytec, LA
No
Chemical Waste Mgmt, TX
Yes
Rubicon, LA
No
BP Chemical, TX
Yes
Angus, LA
No
Wastwaster, TX
Yes
BASF, LA
No
Disposal Systems, TX
Yes
The Upjohn Co., MI
Yes
Witco, TX
No
Morton, MS
No
American Ecology, TX
No
BP Chemical, OH
Yes
Hoechst-Bishop, TX
Yes
AK Steel, OH
Yes
Texas Ecologist, TX
Yes
Chemical Waste Mgmt, OH Yes
Asarco-Amarillo, TX
Yes
10/9/97
-------
TABLE 3. FACILITIES POTENTIALLY INJECTING PHASE IV WASTES WITHOUT NO
MIGRATION PETITIONS OR LDPFA EXEMPTION
Name
Hoskins Manufacturing, IN
Koch Underground, KS
Hoskins Manufacturing, MI
DuPont, MS
Dakota Gasification Co., ND
Zinc Corp. of America, OK
Macklanburg-Duncan, OK
Rockwell, OK
DuPont, TN
Rexene, TX
CECOS,TX
Loving Co., TX
Petition Submited?*
No
No
No
Yes
No
No
No
No
No
No
Denied
Yes
*Yes indicates that according to UICWELLS, the facility petition status is "planned" or
"pending".
10/9/97
-------
^ICF
CONSULTING GROUP
ICF Incorporated
9300 Lee Highway
Fairfax, VA 22031-1207
703/934-3000 Fax 703/934-9740
MEMORANDUM January 29. 1998
TO: Robert Smith
FROM: Debra Favre and Jim Laurenson
SUBJECT: Progress Update - Additional Information Gathering for UIC Facilities
Potentially Affected by Phase IV Rulemaking
At your request, we have contacted the Regions to gather additional information on the types of
wastes generated and injected, and the availability of treatment capacity at 15 facilities initially
identified as potentially affected by the Phase IV rulemaking. Summarized below are the
responses gathered to date from the contact effort for each of the facilities of concern. We are
also continuing our research on the newly identified TC metal wastes (wastes that passed the
Extraction Procedure (EP) Toxicity test but failed the Total Concentration Leaching Procedure
(TCLP) test) to assess the likelihood of these wastes being disposed by underground injection.
Region 4
Dupont, MS facility - The Region confirms our initial description of the waste as being a
characteristic hazardous mineral processing waste (corrosive and TC metal). However, the exact
volume currently injected is not yet known. The Region indicates that they are processing
Dupont's no migration petition, and a decision should be made on approval by the latter part of
1998. They are unwilling to state whether it appears likely that it will be approved or not.
Dupont. TN facility - The Region indicates that the Class I underground injection wells at this
facility have been shutdown and that the facility is not disposing hazardous waste through
underground injection. Because the wells are inactive, they see no need to process Dupont's no
migration petition.
Region 5
Parke-Davis, MI facility - The Region indicates that the waste injected is a process wastewater
from pharmaceutical production processes including TC metals wastes. Thus, this waste was
covered under the Phase III LDRs and is required to treated to TC levels thereby decharacterizing
the waste. Further treatment of other underlying hazardous constituents would be exempted by
the Land Disposal Flexibility Program Act. This facility has submitted a no migration petition,
and the Region indicates that a decision on the petition is likely to be made by or near the Phase
IV rule finalization date.
-------
Hoskins, IN and MI facilities - The Region indicates that these facilities generate a wastewater
that is neither a characteristic nor listed hazardous waste. Region understands that the wastes
injected by these facilities are non-hazardous, and consequently, the facilities do not need no
migration petitions.
Region 6
Zinc Corporation of America, Macklenburg Duncan, Rockwell International, OK facilities - The
Region indicates that these facilities generate wastewaters that are neither characteristic nor listed
hazardous wastes. Region understands that the wastes injected by these facilities are non-
hazardous, and consequently, the facilities do not need no migration petitions.
Perma-Fix, OK facility - The Region indicates that this facility injects non-hazardous wastes and
that any hazardous wastes received by this facility are treated to non-hazardous before injection.
Region understands that all wastes injected by this facility are non-hazardous at the point of
injection, and consequently, the facility does not need a no migration petition.
Rexene, TX facility - The Region indicates that this facility's no migration petition was denied,
and they are no longer injecting hazardous wastes. They are treating their waste on-site before
discharging to a POTW with the wells being used as backup.
BASF, TX facility - A no migration petition was approved for this facility in August 1995. The
approved waste codes are D002, DO 18 and F039.
WITCO, TX facility - The Region indicates that this facility injects a waste that is neither a
characteristic or listed hazardous waste. Consequently, they do not need a no migration petition.
ISP, TX - This facility submitted a petition application, however in December 1996, they
contacted the Region and indicated that they no longer needed a petition and would no longer
pursue one at that time. During a call from the Region on January 27, 1998, the facility
representative reiterated that the wells were only used for the disposal of nonhazardous waste.
Region 7
Dakota Gasification, SD facility - The Regional contact for UIC recently left the Agency. The
new contact is not familiar with this site and is currently researching files to provide adequate
information.
New information: Dakota Gasification is primarily a lignite coal gasification facility. The
facility also produces ammonia and other chemicas as by-products of the gasification process.
Process wastewater (non-hazardous) is injected in underground injection wells. "No migration"
petition status is not applicable.
In summary based on the Regions' responses to our inquiries, only the Dupont, MS and Dakota
Gasification, SD facilities remain as potentially affected by the Phase IV rulemaking.
-------
All of the Regions have been contacted by telephone at least twice and a detailed questionnaire
was faxed to them over a week ago. We are continuing to follow up the Dakota Gasification
facility to accurately assess the impact of Phase IV on this facility. We will provide more
information as soon as it becomes available. If you have any questions, please feel free to
contact us.
-------
Methodology for Collecting Information on UIC Facilities
The following officials were used as initial points of contact for gathering information on operations of underground
injection facilities in their Region:
• Larry Meyer (404) 562-9449, Region IV;
-Dupont Chemicals. TNS0850004
-Dupont DeLisle Plant, MSI1001
• Nathan Wiser (312) 353-9569, Region V;
-Hoskins Manufacturing Co. IN-039-11-0001
-Hoskins Manufacturing Co. MI-135-11-0001
-Parke-Davis MI-139-1W-0003
• Brian Graves (214) 665-7193; Region VI;
-Zinc Corporation of America OKD000402396
-Macklanburg-Duncan OKD007188063
-Rockwell International OKD00722026
-Perma-Fix Treatment Services OKD000402396
• Ken Deason (913) 551-7585, Region VII; and
-Koch Underground Storage Co KS-01-113-003
• Paul Osborne (303) 312-6125, Region VIII
-Dakota Gasification Co. ND-UIC-101
On January 20, 1998, a cover memo, indicating the relevant facilities for each Region, and a two page
questionnaire (see Attachment A) were sent via facsimile to the above contacts. Prior to sending the questionnaires,
telephone calls to each contact were made explaining the purpose of the questionnaire and to give a "heads-up" for
the incoming fax. On January 21, 1998, phone calls were made to ensure the receipt of the questionnaire and to
answer any questions officials may have had.
Responses to the questionnaire, which are provided in Attachment B, were received over the next ten days.
The contacts for Region VII and Region VIII forwarded the questionnaire to state officials who were more
knowledgeable about the facilities in Kansas and North Dakota. Each official replied by facsimile, except for Larry
Meyer of Region IV. Mr. Meyer preferred to answer the questions during a telephone interview on January 21.
1998. The following table summarizes who responded and the date of correspondence.
Contact
Date Response was Received
Larry Meyer
January 21 (telephone)
Nathan Wiser
January 23 (fax)
Brian Graves
January 27 (fax)
Mike Cochran, Kansas Department of
Health and Environment
January 26 (fax)
Scott Radig, North Dakota Division of
Water Quality
January 30 (fax)
Follow-up telephone calls were made to Larry Meyer and Nathan Wiser to obtain more detailed information
on facilities in their respective regions. These officials had indicated that "no migration" petitions were submitted by
relevant facilities. Further information was needed on whether these petitions were expected to be approved and
when decisions were expected to be made. Telephone logs detailing these correspondences are provided in
Attachment C.
-------
SENT BY: 1-23-98 :11:21AM : EPA- 703 934 9740:s 3/12
lJI .... -- - — • uj i-iZl tcoo i J
Ho^|n3^i "XaJDiAaJ/V
4. If the facility does not have a "no migration" petition and the facility injects a
characteristic waste (waste code beginning with D or would begin with a D code if
regulated under RCRA) does that facility decharacterize# its waste before injection?
ko.Qg. ( ka h U7-uK.1V
^ "V <- dec k o..— 'hv i ^
1 g% i ^
tV-o f j" vx-j fi^v. of c* - ti ]m. l
i ^ /V\ os, /> -e x
f
O >vl
5. If the answer is no to #4, does the facility have the additional injection capacity to
inject diluted wastes? (i.e., Can the well accept a the larger waste volume after dillution
sufficient to decharactcrize the waste?)
TTTTT
6. If the answer is no to #5, does the facility have the capability to treat its injected
waste before injection? How much time would be needed belfore this treatment couid
take place (e g , before the wastes could be diverted and/or the treatemnt system
optimized)?
73TP"
7. If the answer is no to #5, can the waste be transported to an off-site treatment
facility (e.g., a centralized wastewater treatment plant)? If yes to #7, how much time
would this take?
A>
m
x* TOTAL F-fiGt. S3 **
-------
SENT BY: 1-23-98 ; 11:10AM : EPA- 703 930 3740:# 2/12
OLJil ui ^ xtj.£« rn Ji.r fu.i *xa ^toa iu ^l_ji^cooa^-JS-bvs r.
l-Vo ^ K / /0 S y ^"p°- ~P £ ^ < 0 . ftV i *-• ' *ia>-j
$= M\-i^5 - I X- -<-£- CA. A-Wt kt- - (jg- 4rx-^) 1d /f ^ i f K*av. .
2. What type of waste is being injected in underground injection wells at the facility?
S&J 4-u)t> \t*s r/iu. -fro "H* n*n4v»-/A Ia. 1^6^ ^>roccn
&£ 41*. coi»p»^'i acVd O uaj 4-p c IpV»
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-------
SENT BY: 1-23-98 =11:HAM ; EPA- 7^ 93^ 3740:# 3/12
|4o <;\e y t kp yfr-c.-Vrv 1 < K I U&76 ~ U)asJ<-
¦k IP -tWi Li >\o 4-1 fig -J-tv i u_
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p P K -K'a » \ I TK-fl o
5. If the answer is no to #4, does the facility have the additional injection capacity to
inject diluted wastes? (i.e., Can (be well accept a the larger waste volume alter dillution
sufficient to decharacterizc the waste?)
6. If the answer is do to #5, does the facility have the capability to ticat its injected
waste before injection? How much lime would be needed before this treatment could
take place (e.g., before the wastes could be diverted and/or the treaiemnt system
optimized)?
7. If the answer is no to #5, can the waste be transported to an off-site treatment
facility (e.g., a centralized wastewater treatment plant)? If yes to #7. how much time
would this take?
-Kfft
** TOTAL PAGE.03 **
-------
01/26/98 15:31 ©785 296 5509
KDHE-BUR WATER
001/004
KANSAS DEPARTMENT OF HEALTH AND ENVIRONMENT
FAX COVER SHEET
DATE: January 26, 1998
time: imp,m. - *z,j yo/ ,
PAGES: 1 including cover page.
TO: Joe
ICF
FAX: 703-934-3740 PHONE: 703-934-3687
FROM: Mike Cochran
Kansas Department of Health and Environment
Building 283, Forbes Field
Topeka, KS 66620-0001
FAX: 785/296-5509 PHONE: 785/296-5560
RE: Questionmre Regarding Class I UIC Facility
Koch Underground Storage Company
Permit Number KS-01-113-003
Message:
Please find attached the completed questionaire you sent to Ken Deason, EPA Region VII,
concerning this facility and Phase IV implications. Ken requested we complete the form and
send it to you since the Kansas Department of Health and Environment administers the Class
I part of the UIC Program in Kansas.
If you have any questions, please contact me at the above referenced telephone number.
-------
01/26/98 15:32 ©785 296 5509 KDHE-BUR WATER
FROfl '< EPf) REGION UII FAX NO.: 11355LZ?65
q —
002/004
& J -20-93 1 2 ¦ 5 ±v K . VJ1
. u i a f . 4JJ. ' CJL3
C 7 VgJ-off.
ICF Incorporated
9300 Lee Highway
Fairfax, VA 22031-1207
FAX: (703)934-3083
FAX COVER SHEET
¦Date: | /Zfc/fg
To: KtN O£lio J
Number of Pages: .s5
(including cover sheet)
Fax Number S~s~l- 7~?£r
Phone Number: ^ ^
Fax Number ")e>i
Phone Number -^3
From:
: 'Soe
Message:
\J\Je. &•»"£ U^o^k-iv^ ophSu I4en-t5 £-^^9 c o-v. |/*lv«cs<£ JjJ
k^s4^i«47«ss. a fcjardt^
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OENERAU SEflVlCCS AGMlNiSTAATlOw
J
If there is a problem with this transmission, of all pages have not been received.
please call the sender. Than* you.
-------
01/26/98 15:32 ©785 296 5509
KDHE-BUR WATER
$003/004
The purpose of this phone survey is to obtain information on the listed underground injection
facilities to evaluate the impact of the Phase IV Land Disposal Restrictions to their operations.
(Koch Underground Storage Company, KS-01-113-003).
Ask the following questions of the EPA Regional contacts regarding the listed facilities.
1. What type of operations are conducted at this facility? For example, is it a manufacturing
plant, chemical processing plant, commercial storage facility? Obtain as specific a description
of operations as you can.
The facility is a hydrocarbon storage well facility. Products such as propane, butane,
isobutane and gasoline are stored under pressure in caverns solutioned in the salt section
located hundreds of feet below the groundsurface. Saturated brine is pumped into the
cavern access wells to remove the stored product for transport by pipeline or truck.
2. What type of waste is being injected in underground injection wells at the facility?
Waste brine resulting from the storage operation. When product is pumped into the
caverns for storage, brine is displaced to the surface. At times there is not sufficient
surface storage for the displaced brine and the brine must then be injected into an
underground injection well for disposal.
* Is the waste a process wastewater or nonwastewater? (RCRA wastewater defined
as wastes that contain < 1 % by weight TOC or < 1 % by with total suspended
solids.)
The waste is a wastewater.
* What waste category or waste code is the waste classified? For example is it a
listed waste or characteristic hazardous waste and if so what hazardous waste
code (i.e., D001, K062 or others)?
The waste is not a listed or characteristic hazardous waste.
3. What is the facility's "no migration" petition status? If the facility has submitted a "no-
migration" petition, when do you expect the petition to be approved?
The facility has not submitted a "no-migration" petition. A "no-migration" petition is not
required since there is no injection of listed or characteristic hazardous waste.
4. If the facility does not have a "no-migration" petition and the facility injects a
characteristic waste (waste code beginning with D or would begin with a D code if regulated
under RCRA) does that facility decharacterized its waste before injection?
KDHE's review of this facility found no information indicating listed or characteristic
hazardous waste is injected and the facility has provided no information that it injects listed
-------
01/26/98 15:33 0785 296 5509
KDHE-Btt* WATER
[<£004/004
or characteristic hazardous waste.
5. If the answer is no to #4, does the facility have the additional injection capacity to inject
diluted wastes? (i.e., Can the well accept the large waste volume after dilution sufficient to
decharacterize the waste?)
The well can accept considerably more waste volume than what is currently directed to the
injection well.
6. If the answer is no to #5, does the facility have the capability to treat its injected waste
before injection? How much time would be needed before this treatment could take place (e.g.,
before the wastes could be diverted and/or the treatment system optimized)?
Not applicable.
7. If the answer is no to #5, can the waste be transported to an off-site treatment facility
(e.g., a centralized wastewater treatment plant)? If yes to #7,how much time would it take?
Not applicable.
-------
SENT BY:
1-27-98 ; 17:45 ; Reg 6 Water SuPPLY -
703 930 3740;# 1/ 3
EPA REGION 6 FAX TRANSMITTAL
# OF PAGES 3 (INCLUDING COVER PAGE)
TO: Joe Schock
PHONE:
(703) 934-3687
FROM: BRIAN GRAVES
GROUND WATER/UIC SECTION
EPA REGION 6
MAIL CODE: (6WQ-SG)
DEPT/AGENCY/BUSINESS
ICF Inc.
PHONE #:
(214) 665-7193
FAX#:
(703) 934-3740
FAX#:
(214) 665-2191 |
-------
SENT BY: 1-27-98 ; 17:4-5 ; Reg 6 Water SuPPLY - 703 930 3740:# 2/ 3
1/27/98
INFO FOR ZCF - PHASE XV
/'
1. Zinc Corporation of America - non hazardous permit
no petition
Wells dispose of nonhazardous
stormvater at an abandoned
zinc refinery
2. Macklanbura-Duncan non hazardous permit
no petition
Facility manufactures caulk and storm
windows
wells haven't been used in over one
year. The waste stream is currently
belong treated and sent to a POTW.
3. Rockwell International (now Boeing) - non hazardous permit
no petition
Facility
manufactures
airplane parts and
wells dispose of non
hazardous wash
waters
4. Perma-Fix -^ion hazardous permit
no petition
Commercial non hazardous disposal facility
5. Reyene Products Conow Huntsman)- non hazardous permits
no petition
Wastewaters are being
treated and going to a
POTW with the wells being
used as backup.
Chemical manufacturing
\
6. ISP Technologies - non hazardous permits
no petition
Operator submitted a petition
application but indicated in 12/96 that
they no longer needed a petition and
would not pursue one at that time.
During a follow-up call 1/27/98 the
facility representative reiterated that
the wells were only disposing of
nonhazardous waste. They indicated that
the reason they did not pursue the
petition was their analysis of EPA's
NODs indicated that they did not feel
1
-------
SENT BY: 1-27-98 ; 17:45 ; Reg 6 Water SuPPLY - 703 930 3740;# 3/ 3
they could make the demonstration.
Pharmaceutical manufacturing
7. BASF Corp. Freeoort TX - petition approved 8/95
Approved waste codes: D002, D018
and F039.
Wells TX WDW-51,99
Chemical manufacturing
8. Witno Chemical Corp. Houston TX - non hazardous permits
no petition
Wells TX WDW-111,139
Chemical manufacturing
d
W
\i
W
fjfi
st
2
-------
01/30/98 10:41 ©701 328 5200
NORTH DAKOTA
DEPARTMENT OF HEALTH
ND ENV HEALTH
1^1 001/003
no it*
a?
ENVIRONMENTAL HEALTH SECTION
TO: CToe^ -S^Wook: , Xr^c.
1200 Missouri Avenue
P.O. Box 5520
Bismarck, North Dakota 58506-5520
Fax #701-326-5200
Fax #: 1Q3-?3t/-57VgO
Phone: 0 3 - *7 3<~j - y 7
FROM: , U.IC pro^r^M j Dlv/. tTp uChtfyzS
Fax #: (701) 328-5200
Phone: (701) 328-5150
DATE: -95 Number of pages following:_ Z
Remarks ~3~c>€- ( c Do^ f
-------
01/30/98 10:42 O701 328 5200 ND ENV HEALTH
JAN-26—1998 10=39 FROM UfiTER QLHL'ITY TO ffrauaasaao ,Jgl 002/003
Tbe pispose of This phone survey is to obtain information an the listed underground
injection facilities io evaluate tbe >«npapr of die Phase IV LABd Disposal Resorkzions their
cpeza&oos»
Ask the fallowing questions of the EPA Regional contacts regarding the listed facilities-
1. W}ihi type of operations arc conducted ai this facility? For example, is it a
mmmfecmring piarrt, chemical proccssi4gpiait,commetciaZ storage fecflity? Obtain as
specific a description cf operations as ycu can.
—fry - ^W7
s<*,^AA«*ry - J7 a'rt^r
jrf Gc&Xnen Am /-^cr - __
2. What type of waste is being injected io underground injection wells at the facility?
fjcoc&st <~*hrF - aOA hr c
Is [be waste a ptocess wastewater arnocwasiewatw wasie? (RCRA
wastewater Heff ryeri as wastes that contain < 1% by weight TOC or <1 % by
weight total suspended solids J
pr-orjfjtj uJ-r^Tg u*rzXrz.f~
• What waste category or waste co •
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01/30/98 10: 42 ©701 328 5200 \T) ENV HEALTH
JPN-26-1996 10=40 FROM UflTER QUALITY ' T0 87013285200 R
4. If the facility docs eot have a. "110 migration" petition and the facility injccc a
characteristic waste (waste cade beginning with D t* would begin whfa z D code if
regulated under RCRA) does that fkdlity decharacteiized its waste before injection?
^v^,5/e
5. If the aas*w is mj to #4, dkxs the fatilhybavctbe additional injection capacity to
inject diluted wawes? (Lc^ Can the wcQ accept a the larger waste ¦oohinK after dflhition
sufficient to decbaiaaetxae the -waste?)
wf
6. If the answer is no 10 #5, does the facility have the capability to treat its injected
waste before injection? How moch lime wouli be needad. bdfaje this treatment could
take plats (e.g., before the wastes could be diverted and/or the rrealemnt syitan
oponrized)? , /
nrf gfflYofblt
7. If the ansaer is no to #5. caa the wasc be transported to oBoff-sne treatment
facility (e^g^ a ctsnrallzed wastewater treatment plant)? If yes to #7, how much, rime
would tbis take?
jtof"
** TOTRL PfiGE.03 *=*
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ATTACHMENT C
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Appendix C - Phase IV Wastes Prohibited from Injection
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STATUS REPORT ON THE PHASE IV LDR UIC ANALYSIS
We are continuing to research the impact of the Phase IV LDR rulemaking on the
Dupont. New Johnsonville. TN and DeLisle, MS facilities. We have reviewed Dupont's
February 5, 1998 letter to independently verify their claims regarding their inability to
meet the ban on injecting their hazardous mineral processing wastes without treatment.
Summarized below are our current findings.
Dupont claims that each of their subject facilities injects about 1,000.000 gallons
of waste per day. Unless they receive a capacity variance, they will have to shut down
these facilities, because they do not have on-site treatment capability and alternative off-
site treatment or injection capacity is unavailable. They claim it would be impractical to
ship their wastes off-site because it would take at least 200 tanker trucks per day at each
site to transport the waste to an off-site treatment or injection facility. In addition, they
claim that there is no commercial treatment or injection capacity available for their waste
within a reasonable distance for safe transport.
To assess these claims, we used Dupont's reported injection rates and production
schedule from their letter. Based on their information, Dupont operates year round (365
days/year) around the clock (assuming 22 hours/day) and injects at a rate of 750
gallons/minute at the New Johnsonville and 600 gallons/minute at the DeLisle facilities.
Using these assumptions, Dupont generates the following volumes of wastes annually at
each of the subject facilities.
New Johnsonville
750 gal x 60 min x 22 hr x 365 days = 361,350,000 gal/yr or 361 million gal/yr
min hr day year
DeLisle
600 gal x 60 min x 22 hr x 365 days = 289.080,000 gal/yr or 289 million gal/yr
min hr day year
In 1989 EPA sent a questionnaire to Dupont titled the "National Survey of Solid
Wastes form Mineral Processing Facilities." The purpose of this survey was to obtain
information on the generation and management of selected solid wastes from mineral
processing facilities. These wastes were later de-Bevilled and became subject to Subtitle
C of RCRA. They are the newly identified hazardous mineral processing wastes that are
covered by the Phase IV LDR rulemaking.
We reviewed the survey completed by Dupont for the DeLisle facility. In the
survey completed in 1989. Dupont reported injecting a total of 128 million gallons of
special waste in three underground injection wells in 1988. This volume is less than half
of the 289 million gallons Dupont reported injecting in its recent letter. Although they
Page 1
-------
are currently using four wells, the difference is not made up by adding in the volume from
the newer 4th well (see calculations below).
Special Waste Injected at DeLisle in 1988
Well 1 123,083,000
Well 2 574,000
Well 3 3.892.000
127,549.000 gal in 1988 or 128 million gal in 1988
DeLisle 4th Well
Monthly injection rate from UICWELLS database:
180.000 gal x 12 mon = 2,160,000 gal/yr
mon year
127,549,000 gal special waste in 1988 from Wells 1-3
+ 2.160.000 gal/yr waste for Well 4
129,709,000 gal/yr or 130 million gal/yr
Possible explanations for these differences in the volume of waste could be:
• Dupont's production has increased substantially over the last ten years resulting in a
more than doubling of the waste volume generated.
• Dupont may be currently reporting the volume of all their wastes including non-
hazardous and other hazardous wastes generated by the facilities that were never
included in the Bevill exemption but have been subject to previous LDR rulemakings.
Only the newly identified hazardous mineral processing waste portion of the injected
volume that is subject to the Phase IV rulemaking.
0 If the newly identified hazardous mineral processing waste portion is
segregated from other wastes, the volume of waste subject to Phase IV is
much smaller.
0 If the aggregation of wastes at the plant occurs in such a way that the portion
subject to Phase IV cannot be separated, then the total volume is subject to
Phase IV.
Thus, a high-end estimate of the affected volume for the DeLisle facility would be 289
million gallons/year and a low-end estimate would be 130 million gal/year. We do not
have the New Johnsonville facility's survey response. However, if the facilities operate
similarly, we could assume a similar portion of the waste stream is newly identified
mineral processing waste subject to Phase IV. Assuming 44 % of the waste stream
Page 2
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ATTACHMENT A
The purpose of this phone survey is to obtain information on the listed underground injection
facilities to evaluate the impact of the Phase IV Land Disposal Restrictions their operations.
Ask the following questions of the EPA Regional contacts regarding the listed facilities.
1. What type of operations are conducted at this facility? For example, is it a manufacturing
plant, chemical processing plant, commercial storage facility? Obtain as specific a description of
operations as you can.
2. What type of waste is being injected in underground injection wells at the facility?
• Is the waste a process wastewater or nonwastewater waste? (RCRA wastewater
defined as wastes that contain < 1% by weight TOC or <1% by weight total
suspended solids.)
• What waste category or waste code is the waste classified? For example is it a listed
waste or characteristic hazardous waste and if so what hazardous waste code (i.e.,
DOOI, K062 or others)?
3. What is the facility's "no migration" petition status? If the facility has submitted a "no
migration" petition, when do you expect the petition to be approved?
-------
4. If the facility does not have a "no migration" petition and the facility injects a
characteristic waste (waste code beginning with D or would begin with a D code if regulated
under RCRA) does that facility decharacterized its waste before injection?
5. If the answer is no to #4, does the facility have the additional injection capacity to inject
diluted wastes? (i.e., Can the well accept a the larger waste volume after dillution sufficient to
decharacterize the waste?)
6. If the answer is no to #5, does the facility have the capability to treat its injected waste
before injection? How much time would be needed belfore this treatment could take place (e.g..
before the wastes could be diverted and/or the treatemnt system optimized)?
7. If the answer is no to #5, can the waste be transported to an off-site treatment facility
(e.g., a centralized wastewater treatment plant)? If yes to #7, how much time would this take?
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ATTACHMENT B
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i
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La<,y #
The purpose of this phone survey is to obtain information on the listed underground
injection facilities to evaluate the impact of the Phase IV Land Disposal Restrictions their
operations.
Ask the following questions of the EPA Regional contacts regarding the listed facilities.
1. What type of operations are conducted at this facility? For example, is it a
manufacturing plant, chemical processing plant, commercial storage facility? Obtain as
specific a description of operations as you can.
Thi fac.'i.'iy i 5 osc 4o in-?, clo^j ct<-\ , jUJr.dnvz "Tu/j I,/ffi7
bgL\sfr. fqi.'li'-ty > Mlmm/ Process:*^ -&c!li'±Y vuL\cl^
as. eJ -X?. (_s>iO£f-r p(r io4r,
4-> i-//h )u n/> Q\lJ £ ( Ti' j^i - i/o/., cL )py,J-€y Lnov toA. ;
• Is the waste a process wastewater or nonwastewater waste? (RCRA
wastewater defined as wastes that contain < 1% by weight TOC or <1% by
weight total suspended solids.)
WZ-.Wv ~ pfoc-eZS \AJas4e\sJak'<
• What waste category or waste code is the waste classified? For example is it a
listed waste or characteristic hazardous waste and if so what hazardous waste
code (i.e., D001, K062 or others)?
^ <^-oc/W ? CjorfO^; CbOOTp) ') C\/iDmi {\&Cy~7\ , dnsj
Lrld C>oo:kov/r) he ^ \/Ae^ &
-------
4. If the facility does not have a "no migration" petition and the facility injects a
characteristic waste (waste code beginning with D or would begin with a D code if
regulated under RCRA) does that facility decharacterized its waste before injection?
UM
5. If the answer is no to #4, does the facility have the additional injection capacity to
inject diluted wastes? (i.e., Can the well accept a the larger waste volume after dillution
sufficient to decharacterize the waste?)
N/fi
6. If the answer is no to #5, does the facility have the capability to treat its injected
waste before injection? How much time would be needed belfore this treatment could
take place (e.g., before the wastes could be diverted and/or the treatemnt system
optimized)?
iOA
7. If the answer is no to #5, can the waste be transported to an off-site treatment
facility (e.g., a centralized wastewater treatment plant)? If yes to #7, how much time
would this take?
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TELEPHONE LOG
Date: 2/27/98
To: Larry Meyer, EPA Region IV. (404) 562-9449
From: Joe Schock, ICF Inc.
Contacted him to ask follow-up questions to responses he gave regarding the impact of the Phase
IV rulemaking on operations at two facilities in Region IV. He had indicated that the Dupont
DeLisle Plant in Mississippi had submitted a "no migration" petition and a decision would be
made in the latter part of 1998. The purpose of this call was to determine if the petition is on
approval/disapproval from EPA and whether the decision would be made prior to the ban date.
He stated during the call that he could not predict when the decision would be made, and
furthermore that no decision had been made regarding when the petition would be evaluated.
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TELEPHONE LOG
Date: 2/27/98
To: Nathan Wiser, EPA Region V, (312) 353-9569
From: Joe Schock, ICF Inc.
Contacted him to ask follow-up questions to responses he gave regarding the impact of the Phase
IV rulemaking on operations at three facilities in Region IV. He had indicated that the Parke-
Davis facility in Michigan submitted a "no migration" petition. The purpose of this call was to
determine if the petition is expected to be approved and whether the decision would be made
prior to the ban date. He stated during the call that the petition is "likely" to be approved. As for
when a decision will be made, he stated that the petition will probably be granted near the ban
date of April 8, 1998.
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Appendix B- Methodology for Estimation of the Volume of Phase IV Waste
Managed
by Underground Injection
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APPENDIX B -
Methodology for Estimating the Volume of Phase IV Waste Managed
by Underground Injection
For all facilities identified as potentially injecting Phase IV wastes, the volume of waste injected
annually was determined using the following steps.
Step 1
A search was conducted on the 1993 Biennial Reporting System (BRS) of the Hazardous Waste
Report to identify the type and quantity of hazardous waste injected in Class I wells by the facilities
identified as potentially injecting Phase IV wastes. For non-commercial facilities, the volume of waste
generated on-site, as reported on the Generator Managed (GM) forms, was used to quantity the volume of
Phase IV waste injected at a facility. Commercial facilities inject both on-site and off-site generated
hazardous waste. Therefore, for these facilities, the volume of waste generated on-site (from the GM form)
was added to the volume of waste received from off-site generators (from the Waste Received (WR) form)
to determine the total volume of waste injected at each facility.
Step 2
There were many facilities, however, for which no data were available from the BRS. These facilities
may not have injected RCRA hazardous waste in 1993, may have decharacterized their waste and did not
report the volumes, or the volumes were not identified properly in the BRS. The Class I injection wells
database. UICWELLS. was used to obtain waste injection volumes for these facilities. Facilities were
queried using the EPA ED number and the well permit numbers. The database supplied information such
as the monthly rate of injection given in million gallons per month, and the average and maximum rates of
injection given in gallons per minute for active wells at each facility. In order for the data to be consistent
with waste volumes obtained from the BRS, the waste volumes were converted from million gallons per
month to tons per year by factoring by 12 and applying a unit conversion factor. Although the mass of a
waste may vary depending on its constituents, the majority of injected wastes are wastewaters or liquid
non-wastewaters consisting mainly of water, with dissolved constituents. Thus, for simplification, the
conversion factor of 1 million gallons of water equals 4399.6 tons of water was used to convert million
gallons to metric tons. Finally, to compute the total waste injected at each facility it was necessary to sum
the tons per year for each active well.
Step 3
To estimate the total volume of Phase IV waste injected in underground wells (in tons per year), the
data for all facilities were summed. This estimate is considered to be high-end because some wastes
included may not contain underlying hazardous constituents that exceed the metal UTS. Addition, some of
the waste volumes are reported for aggregate waste streams, some of which may not be Phase IV wastes.
All facilities were queried in the UICWELLS database regardless of whether BRS data was obtained.
Because the BRS data when available represents reportable quantities of hazardous waste injected rather
than estimated volumes as is found in the UICWELLS database, the data obtained from the BRS was used
in the summation wherever possible. Otherwise, annual injection rate estimates using data from the
UICWELLS database were used.
Exhibits B-l through B-3 present the total volume of injected potential Phase IV waste, the total
volume of injected TC Metal wastes, and the total volume of injected TC Metal wastewaters, respectively.
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EXHIBIT B-1
TOTAL VOLUME OF POTENTIAL PHASE IV WASTE
Facility ID
Facility Name
BhS
Injected
from On-
site (tons)
BRS Injected
from Off-site
(ton9)
BRS Total
Injected
(tons)
UIC
Well 10
uiu Annual
Injection
Rate
(Mgal/year)
UIC Annual
Injection Rate
(tona/yr)*
UIC Max
Injection Rate
(gal/mln)
UIC Avg
Injection Rate
(gal/mln)
Data Used In
Summation"
AR?-U
Ethyl Corporation
(Magnolia)
Not Found
Not Applicable
Not Found
Not Found
Not Found
Unknown
0
FLS105001
Kaiser Aluminum &
Chemical Company
96,495
Not Applicable
96,495
Well 1
96
422,362
Unknown
187
96,495
ILD000781591
LTV Steel Company
(Hennepin Works)
34,984
Not Applicable
34,984
Well 1
1.128
4,963
Unknown
48.3
34,984
ILD005463344
Allied-Signal, Inc.
Not Found
Not Applicable
Well 1
18.65
82,053
Unknown
35.98
82,053
ILD042075333
Cabot Corporation
844,527
Not Applicable
844,527
Well 1
Unknown
Unknown
400
Unknown
844,527
IN-127-1 W-0001
Bethlehem Steel
Corporation (Burns
Harbor)
391,314
Not Applicable
391,314
WAL-1
WAL-2
WPL-1
76.2
7.92
17.28
335,250
34,845
76,025
Unknown
147.8
15.3
39
391,314
IN-127-IW-0006
Midwest Steel Division
of National Steel Corp
Not Found
Not Applicable
WPL-2
5.04
22,174
Unknown
20.6
22,174
KS-01 -173-004
Vulcan Chemicals
1,483,832
Not Applicable
1,483,832
003
004
007
008
009
163
110.63
111.89
91.83
80.96
717,135
486,728
492,271
404,015
356,192
350
350
350
350
350
Unknown
Unknown
Unknown
Unknown
Unknown
1,483,832
LAD000618256
Cecos International
(Willow Springs)
58,419
7,727.72
66,147
001
23.9
105,150
161.6
46.75
66,147
LAD000778514
Rollins Environmental
Services of LA, Inc.
20,511
4,073.60
24,585
Well 1
9.168
40,336
150
125
24,585
LAD001890367
E.I. duPont
(Pontchartrain
Works)
Not Found
Not Applicable
Well 1
Well 2
Well 4
Well 7
Well 8
2.95
30.70
61.76
41.64
11.88
12,961
135,061
271,700
183,199
52,267
130.08
87.5
240.42
318 6
161.7
83.35
62.75
134.6
132.6
78
12,961
135,061
271,700
183,199
52,267
LAD008175390
Cytec Industries, Inc.
1,487,553
Not Applicable
1,487,553
Well 1
Well 2
Well 3
Well 5
119.04
66.00
106.44
119.04
523,728
290,374
468,293
523,728
345.8
240.6
417.1
428.92
242 5
146.4
208.67
249.25
1,487,553
LAD020597597
Angus Chemical
Company
101,681
Not Applicable
101,681
Well 1
Well 2
28.25
25.26
124,289
111,134
Unknown
78.25
53.758
48.055
101,681
MI-077-1 W-0001
The Upjohn
Company
2,701
Not Applicable
2,701
3
4
6.96
3
30,621
13,199
13 2
5.8
2,701
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EXHIBIT B-1
TOTAL VOLUME OF POTENTIAL PHASE IV WASTE
"BHS
uic'AnnuBi
Injected
BRS Injected
BRS Total
Injection
UIC Annual
UIC Max
UIC Avg
from On-
from Off-site
Injected
UIC
Rate
Injection Rate
Injection Rate
Injection Rate
Data Used In
Facility ID
Facility Name
site (tons)
(tons)
(tons)
Well ID
(Mgal/year)
(tons/yr)*
(gal/mln)
(gal/min)
Summation"
MI-139-1W-0003
Parke-Davis
158,512
Not Applicable
158,512
3
17.64
77,609
Unknown
45
158,512
Division of
4
9.48
41,708
Unknown
46
Warner Lambert
5
15.12
66,522
Unknown
50
MSI1001
DuPont DeLisle Plant-
Not Found
Not Applicable
Wells
289
1,271,484
Unknown
750
1,271,484
White Pigment &
1,2,3,7
(aggregate,
(aggregate)
Mineral
based on
company
provided
data)
MSS059001
Morton
499,104
Not Applicable
499,104
1005
129.6
570,188
Unknown
250
499,104
International,
Inc.
1006
129.6
570,188
Unknown
250
OH-03-02-003
BP Chemicals
983,240
Not Applicable
983,240
WDW-1
46.63
205,153
184
115
983,240
WDW-2
56 46
248,401
256
135
WDW-3
48.61
213,865
662
135
WDW-4
79.51
349,812
244
127
OH-05-09-001
AK Steel Co.
83,645
Not Applicable
83,645
1
6.33
27,849
80
22
83,645
2
7.52
33,085
80
24
OH-CWM
Chemical Waste
9,166
117,265.00
126,431
2
12.102372
53,246
90
75
126,431
Management, Inc.
4
2.552988
11,232
90
39
5
13.78986
60,670
90
75
6
16.90236
74,364
90
85
OKD000402396
Perma Fix Treatment
4,224
4,224
1
5.4
23,758
42
Unknown
4,224
Services, Inc.
2
5.4
23,758
200
Unknown
TNS0850004
DuPont Chemicals
Not Found
Not Applicable
Wells 4,5,6
361
1,588,256
Unknown
600
1,588,256
(aggregate
based on
company
provided
data)
TXD WDW-002
Monsanto
2,512,275
Not Applicable
2,512,275
WDW-013
546.39
2,403,897
1020
880
2,512,275
Company
WDW-224
58.89
259,092
180
58.89
(Chocolate
WDW-318
0
0
1,000
Unknown
Bayou Plant)
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EXHIBIT B-1
TOTAL VOLUME OF POTENTIAL PHASE IV WASTE
BR5T"
uiu Annual
In|ected
BRS Injected
BRS Total
Injection
UIC Annual
UIC Max
UIC Avg
from On-
from Off-site
Injected
UIC
Rate
Injection Rate
Injection Rate
Infection Rate
Data Used In
Facility ID
Facility Name
site (tons)
(tons)
(tons)
Wall ID
(Mgal/year)
(tona/yr)'
(gal/mln)
(gal/mln)
Summation"
TXD WDW-004
E.I. duPont de
4,555,034
Not Applicable
4,555,034
WDW-004
259.2
1,140,376
2,220
85
4,555,034
Nemours and
WDW-029
259.2
1,140,376
2,220
270
Company
WDW-030
259.2
1,140,376
2,220
245.58
(Victoria)
WDW-142
259.2
1,140,376
2,220
89.5
WDW-143
259.2
1,140,376
2,220
27.58
WDW-144
259.2
1,140,376
2,220
41.75
WDW-145
259 2
1,140,376
2,220
300.92
WDW-271
259.2
1,140,376
2,220
300
WDW-028
259.2
1,140,376
2,220
250
WDW-105
259.2
1,140,376
2,220
122
WDW-106
259.2
1,140,376
2,220
107.67
TXD WDW-014
Hoechst
Not Found
Not Applicable
WDW-014
401.76
1,767,583
750
0
1,767,583
Celanese
WDW-032
401.76
1,767,583
750
Unknown
1,767,583
Chemical
WDW-049
401.76
1,767,583
750
Unknown
1,767,583
Company (Bay
WDW-110
214.27
942,702
800
109.45
942,702
City)
WDW-277
214.27
942,702
630
0
942,702
TXD WDW-016
Rexene
Not Found
Not Applicable
WDW-088
455.328
2,003,261
345
79.92
2,003,261
WDW-154
455.328
2,003,261
345
33.58
2,003,261
WDW-303
420.48
1,849,944
1000
800
1,849,944
WDW-126
455.328
2,003,261
345
42.08
2,003,261
TXD WDW-033
Hoechst Celanese
Not Found
Not Applicable
WDW-033
214.27
942,702
400
166.22
942,702
Chemical Co.
WDW-283
214.27
9.42,702
400
0
942,702
(Clear Lake)
WDW-045
211
928,316
400
74.56
928,316
TXD WDW-034
ISP Tech-
779
Not Applicable
779
WDW-034
120.528
530,275
275
130.83
779
nologies, Inc.
WDW-113
120.528
530,275
275
96.75
TXD WDW-051
BASF Corp.
281,555
Not Applicable
281,555
WDW-051
0
300
114
281,555
(Freeport Road)
WDW-113
0
300
155
TXD WDW-054
E.I. duPont de
Not Found
Not Applicable
WDW-054
51.17
225,128
700
51.17
225,128
Nemours and
WDW-055
25.83
113,642
300
25.83
113,642
Company
WDW-191
349.42
1,537,308
750
349.42
1,537,308
(Sabine)
WDW-057
29.33
129,040
300
29.33
129,040
WDW-207
29.33
129,040
550
29.33
129,040
WDW-282
0
0
600
0
0
TXD WDW-070
Disposal Systems of
4,765
25,372.52
30,138
WDW-070
80.35
353,508
150
Unknown
30,138
Corpus Christi, GNR
Group
-------
EXHIBIT B-1
TOTAL VOLUME OF POTENTIAL PHASE IV WASTE
Facility ID
Facility Name
BH5>"
Injected
from On-
site (tons)
BRS Injected
from Off-site
(tons)
BRS Total
Injected
(tons)
UIC
Well ID
'inu Annuar
Injection
Rate
(Mgal/year)
UIC Annual
Injection Rate
(tons/yr)*
UIC Max
Injection Rate
(gal/min)
UIC Avg
Injection Rate
(gal/mln)
Data Used In
Summation"
TXD WDW-080
Amoco Oil Company
(Texas City Plant)
2,059,482
Not Applicable
2,059,482
WDW-126
WDW-127
WDW-128
696.384
696.384
696.384
3,063,811
3,063,811
3,063,811
650
650
650
384.67
384.67
384.67
2,059,482
TXD WDW-091
Sterling Chemicals
(Texas City)
1,088,370
1,088,370
WDW-091
WDW-196
WDW-314
525.6
525.6
525.6
2,312,430
2,312,430
2,312,430
1200
1200
1200
179.83
256.3
Unknown
1,088,370
TXD WDW-100
Dupont Beaumont
WDW-100
WDW-101
WDW-188
26
26
26
114,390
114,390
114,390
Unknown
Unknown
Unknown
Unknown
Unknown
154.58
114,390
114,390
114,390
TXD WDW-129
Asarco, Inc.
(Amarillo Copper
Refinery)
292,869
Not Applicable
292,869
WDW-129
WDW-273
161
161
708,336
708,336
300
300
113.5
93.75
292,869
TXD WDW-147
Merichem Company
479,163
Not Applicable
479,163
WDW-147
161
708,336
300
Uknown
479,163
TXD WDW-148
Arco Chemical
Company
1,027,471
Not Applicable
1,027,471
WDW-148
WDW-162
187.488
187.488
824,872
824,872
350
350
206.25
206.25
1,027,471
TXD WDW-156
Occidental Chemical
Corporation
Not Found
Not Applicable
WDW-156
80.352
353,517
293.11
200
353,517
TXD WDW-157
Empak, Inc.
2,074
21,263.77
23,338
WDW-157
156
686,338
100
99.13
23,338
TXD WDW-160
Chemical Waste
Management (Port
Arthur)
107,541
23,100.67
130,641
WDW-160
103.68
456,151
200
154
130,641
TXD WDW-163
BP Chemicals
America Co.
1,746,961
Not Applicable
1,746,961
WDW-163
WDW-164
WDW-165
214.27
299.86
Unknown
942,702
1,319,264
200
500
500
129.67
151.78
116.89
1,746,961
0
TXD WDW-167
Wastewater, Inc.
Not Found
Not Applicable
WDW-167
50
0
0
TXD WDW-169
Disposal Sys.,
Inc. (Deerpark)
Not Found
56,488.84
56,489
WDW-169
WDW-249
80.352
80.352
353,517
353,517
260
260
64
61.58
56,489
TXD WDW-186
American Ecology
Corp.
7,821
15,380.63
23,202
WDW-186
107
470,757
300
39.42
23,202
TXD WDW-210
Hoechst/Celanese
Chemical
(Bishop)
22,255
Not Applicable
22,255
WDW-210
WDW-211
WDW-212
321
321
321
1,412,272
1,412,272
1,412,272
320
320
320
77.56
87.56
149.33
22,255
-------
EXHIBIT B-1
TOTAL VOLUME OF POTENTIAL PHASE IV WASTE
Facility 10
Facility Name
BHS
Injected
from On-
site (tons)
BRS Injected
from Off-site
(tons)
BRS Total
Injected
(tons)
UIC
Well 10
uiuAnnuai
Injection
Rate
(Mgal/year)
UIC Annual
Injection Rate
(tons/yr)*
UIC Max
Injection Rate
(gal/mln)
UIC Avg
Injection Rate
(gal/mln)
Data Used In
Summation"
TXD WDW-278
Texas Ecologist, Inc.
7,958
Not Applicable
7,958
WDW-278
Unknown
100
24.33
7,958
SUM
45,038,556
Source: 1993 Bienneal Reporting System (BRS) for the Hazardous Waste Report; UICWELLS Volume 6, Underground Injection Control (UIC) Program
Class I Well Database developed by EPA.
' Tons/year were estimated from million gallons/year by applying the conversion factor of 1 Mgal of water = 4399.6 tons of water.
" Where BRS data were unavailable to compute the total waste injected, data were used from the UIC database.
-------
EXHIBIT B-2
ANNUAL VOLUME OF TC METAL WASTES
Facility ID
Facility Name
BRS Injected
from On-site
(tons)
BRS Injected
from Off-site
(tons)
BRS Total
Injected (tons)
UIC
Well ID
UIC Annual
Injection
Rate
UIC Annual
Injection Rate
(tons/yr)*
UIC Max
Injection
Rate
UIC Avg
Injection Rate
(gal/mln)
Data Used
In Summation"
ILD005463344
Allied-Signal, Inc.
Not Found
Not Applicable
Not Found
Well 1
18.65
82,053
Unknown
35.98
82,053
IN-127-1W-0001
Bethlehem
Steel Corp
Burns Harbor
391,314
Not Applicable
391,314
WAL-1
WAL-2
WPL-1
76.2
7.92
17.28
335,250
34,845
76,025
Unknown
147.8
15.3
39
391,314
LAD000618256
Cecos International
(Willow Springs)
58,419
7,728
66,147
001
Unknown
105,150
400
Unknown
66,147
LAD000778514
Rollins
Environmental
Services of LA, Inc.
20,511
4,074
24,585
Well 1
9.168
40,336
150
125
24,585
LAD001890367
E.I. duPont
(Pontchartraln
Works)
Not Found
Not Applicable
Well 1
Well 2
Well 4
Well 7
Well 8
2.95
30.70
61.76
41.64
11.88
12,961
135,061
271,700
183,199
52,267
130.08
87.5
240.42
318.6
161.7
83.35
62.75
134.6
132.6
78
12,961
135,061
271,700
183,199
52,267
MI-077-1 W-0001
The Upjohn
Company
2,701
Not Applicable
2,701
3
4
6.96
5.04
30,621
30,621
Unknown
13.2
20.6
2,701
MSI1001
DuPont Del-isle
Plant-White
Pigment & Mineral
Not Found
Not Applicable
Wells
1,2,3,7
289
(aggregate,
based on
company
provided
data)
1,271,484
Unknown
750
(aggregate)
1,271,484
TNS0850004
DuPont Chemicals
Not Found
Not Applicable
Wells 4,5,6
361
(aggregate,
based on
company
provided
data)
1,588,256
Unknown
600
1,588,256
OH-03-02-003
BP Chemicals
983,240
Not Applicable
983,240
WDW-1
WDW-2
WDW-3
WDW-4
46.63
56.46
48.61
79.51
205,153
248,401
213,865
349,812
184
256
662
244
115
135
135
127
983,240
TXD WDW-002
Monsanto Co
(Chocolate Bayou
Plant)
2,512,275
Not Applicable
2,512,275
WDW-013
WDW-224
WDW-318
546.39
58.89
0
2,403,897
259,092
0
1020
180
1,000
880
58.89
Unknown
2,512,275
-------
EXHIBIT B-2
ANNUAL VOLUME OF TC METAL WASTES
BRS Injected
BRS ln|ected
UIC Annual
UIC Annual
UIC Max
UIC Avg
from On-site
from Off-site
BRS Total
UIC
Injection
Injection Rate
Injection
Injection Rate
Data Used
Facility ID
Facility Name
(tons)
(tons)
Injected (tons)
Well ID
Rate
(tons/yr)*
Rate
(gal/mln)
In Summation"
TXD WDW-004
E.I. duPont de
4,555,034
Not Applicable
4,555,034
WDW-004
259.2
1,140,376
2,220
85
4,555,034
Nemours and
WDW-029
259.2
1,140,376
2,220
270
Company (Victoria)
WDW-030
259.2
1,140,376
2,220
245.58
WDW-142
259.2
1,140,376
2,220
89.5
WDW-143
259.2
1,140,376
2,220
27.58
WDW-144
259.2
1,140,376
2,220
41.75
WDW-145
259.2
1,140,376
2,220
300.92
WDW-271
259.2
1,140,376
2,220
300
WDW-028
259.2
1,140,376
2,220
250
WDW-105
259.2
1,140,376
2,220
122
WDW-106
259.2
1,140,376
2,220
107.67
TXD WDW-016
Rexene
Not Found
Not Applicable
WDW-088
455.328
2,003,261
345
79.92
2,003,261
WDW-154
455.328
2,003,261
345
33.58
2,003,261
WDW-303
420.48
1,849,944
1000
800
1,849,944
WDW-126
455.328
2,003,261
345
42.08
2,003,261
TXD WDW-033
Hoechst Celanese
Not Found
Not Applicable
WDW-033
214.27
942,702
400
166 22
942,702
Chemical Co.
WDW-283
214.27
942,702
400
0
942,702
(Clear Lake)
WDW-045
211
928,316
400
74.56
928,316
TXD WDW-054
E.I. duPont de
Not Found
Not Applicable
WDW-054
51.17
225,128
700
51.17
225,128
Nemours and
WDW-055
25.83
113,642
300
25.83
113,642
Company (Sabine)
WDW-191
349.42
1,537,308
750
349.42
1,537,308
WDW-057
29.33
129,040
300
29.33
129,040
WDW-207
29.33
129,040
550
29.33
129,040
WDW-282
0
0
600
0
0
TXD WDW-070
Disposal Systems
4,765
25,373
30,138
WDW-070
80.35
353,508
150
Unknown
30,138
of Corpus Christi,
GNR Group
TXD WDW-129
Asarco (Amarlllo
292,869
Not Applicable
292,869
WDW-129
161
708,336
300
113.5
292,869
Copper Refinery)
WDW-273
161
708,336
300
93.75
TXD WDW-156
Occidental
Not Found
Not Applicable
WDW-156
80.352
353,517
293.11
200
353,517
Chemical
Corporation
TXD WDW-157
Empak, Inc.
2,074
21,264
23,338
WDW-157
156
686,338
100
99.13
23,338
TXD WDW-160
Chemical Waste
107,541
23,101
130,641
WDW-160
103.68
456,151
200
154
130,641
Management (Port
Arthur)
TXD WDW-163
BP Chemicals
1,746,961
Not Applicable
1,746,961
WDW-163
214.27
942,702
200
129.67
1,746,961
America Co.
WDW-164
299.86
1,319,264
500
151.78
WDW-165
Unknown
500
116.89
0
-------
EXHIBIT B-2
ANNUAL VOLUME OF TC METAL WASTES
Facility ID
Facility Name
BRS Injected
from On-site
(tons)
BRS Injected
from Off-site
(tons)
BRS Total
Injected (tons)
UIC
Well ID
UIC Annual
Injection
Rate
UIC Annual
Injection Rate
(tons/yr)*
UIC Max
Injection
Rate
UIC Avg
Injection Rate
(gal/mln)
Data Used
In Summation**
TXD WDW-167
Wastewater, Inc.
Not Found
Not Applicable
WDW-167
50
0
0
TXD WDW-169
Disposal Systems,
Inc. (Deerpark)
Not Found
56,489
56,489
WDW-169
WDW-249
80 352
80.352
353,517
353,517
260
260
64
61.58
56,489
TXD WDW-210
Hoechst Celanese
Chemical Co.
(Bishop)
22,255
Not Applicable
22,255
WDW-210
WDW-211
WDW-212
321
321
321
1,412,272
1,412,272
1,412,272
320
320
320
77.56
87.56
149.33
22,255
TXD WDW-278
Texas Ecologist,
Inc.
7,958
Not Applicable
7,958
WDW-278
Unknown
100
24.33
7,958
SUM
27,604,048
Source: 1993 Bienneal Reporting System (BRS) for the Hazardous Waste Report; UICWELLS Volume 6, Underground Injection Control (UIC) Program
Class I Well Database developed by EPA.
" Tons/year were estimated from million gallons/year by applying the conversion factor of 1 Mgal of water = 4399.6 tons of water.
" Where BRS data were unavailable to compute the total waste injected, data were used from the UIC database.
-------
EXHIBIT B-3
ANNUAL VOLUME OF TC METAL WASTEWATER
BRS Injected
BRS Injected
BRS Total
UIC Annual
UIC Annual
UIC Max
UIC Avg
Data Used
from On-site
from Off-site
Injected
UIC
Injection Rate
Injection Rate
Injection Rate
Injection Rate
In
Facility ID
Facility Name
(tons)
(tons)
(tons)
Well ID
(Mgal/year)
(tons/yr)*
(gai/mln)
(gai/min)
Summation"
LAD001890367
E.I. DuPont
Not Found
Not Found
Not Found
Well 1
2.95
12,961
130.08
83.35
12,961
(Pontchartrain
Well 2
30.70
135,061
87.5
62.75
135,061
Works)
Well 4
61.76
271,700
240.42
134.6
271,700
Well 7
41.64
183,199
318.6
132.6
183,199
Well 8
11.88
52,267
161.7
78
52,267
MI-139-1W-0003
Parke-Davis
158,512
Not Found
158,512
3
17.64
77,609
Unknown
45
158,512
Div. of Warner
4
9.48
41,708
Unknown
46
Lambert
5
15.12
66,522
Unknown
50
OH-03-02-003
BP Chemicals
983,240
Not Found
983,240
WDW-1
Unknown
205,153
400
Unknown
983,240
WDW-2
56.46
248,401
256
135
WDW-3
48.61
213,865
662
135
WDW-4
79.51
349,812
244
127
TXD WDW-002
Monsanto Co
2,512,275
Not Found
2,512,275
WDW-013
5.04
349,812
Unknown
20.6
2,512,275
(Chocolate
WDW-224
58.89
259,092
180
58.89
Bayou Plant)
WDW-318
0
0
1,000
Unknown
TXD WDW-004
E.I. duPont de
4,555,034
Not Found
4,555,034
WDW-004
259.2
1,140,376
2,220
85
4,555,034
Nemours and
WDW-029
259.2
1,140,376
2,220
270
Company
WDW-030
259.2
1,140,376
2,220
245.58
(Victoria)
WDW-142
259.2
1,140,376
2,220
89.5
WDW-143
259.2
1,140,376
2,220
27.58
WDW-144
259.2
1,140,376
2,220
41.75
WDW-145
259.2
1,140,376
2,220
300.92
WDW-271
259.2
1,140,376
2,220
300
WDW-028
259.2
1,140,376
2,220
250
WDW-105
259.2
1,140,376
2,220
122
WDW-106
259.2
1,140,376
2,220
107.67
TXD WDW-016
Rexene
Not Found
Not Found
Not Found
WDW-088
455.328
2,003,261
345
79.92
2,003,261
WDW-154
455.328
2,003,261
345
33.58
2,003,261
WDW-303
420.48
1,849,944
1000
800
1,849,944
WDW-126
455.328
2,003,261
345
42.08
2,003,261
TXD WDW-054
E.I. duPont de
Not Found
Not Found
Not Found
WDW-054
51.17
225,128
700
51.17
225,128
Nemours and
WDW-055
25.83
113,642
300
25.83
113,642
Company
WDW-191
349.42
1,537,308
750
349.42
1,537,308
(Sabine)
WDW-057
29.33
129,040
300
29.33
129,040
WDW-207
29.33
129,040
550
29.33
129,040
WDW-282
0
0
600
0
0
TXD WDW-157
Empak, Inc.
2,074
21,263.77
23,338
WDW-157
156
686,338
100
99.13
23,338
SUM
18,881,472
Source: 1993 Bienneal Reporting System (BRS) for the Hazardous Waste Report; UICWELLS Volume 6, Underground Injection Control (UIC) Program
Class I Well Database developed by EPA.
' Tons/year were estimated from million gallons/year by applying the conversion factor of 1 Mgal of water = 4399.6 tons of water.
" Where BRS data were unavailable to compute the total waste injected, data were used from the UIC database.
-------
SENT BY:
1-23-98 ;11:25AM
EPA-
703 934 9740;t 1/20
..tOSNv.
2E
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGIONS
77 WEST JACKSON BOULEVARD
CHICAGO.IL 60604-3590
FAX TRANSMITTAL
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FROM.
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FAX #: (312) 886-4235
EQUIPMENT: XEROX 7032
SUBJECT:
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-------
SENT BY: 1-23-98 :11:26AM : EPA- 703 934 9740:* 2/20
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The purpose of this phone survey is to obtain information on the listed underground
injection facilities to evaluate the impact of the Phase IV Land Disposal Restrictions their
operations.
Ask the following questions of the EPA Regional contacts regarding the listed facilities.
1. What type of operations are conducted at this facility? For example, is if a
manufacturing plant, chemical processing plant, commercial storage facility? Obtain as
specific a description of operations as you can.
qvVe > s C d ^ & i* <¦ i j fy\ i (_ K i q >->
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2. What type of waste is being injected in underground injection wells at the facility?
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3. What is the facility's "no migration" petition status? If the facility has submitted a
"no migration" petition, when do you expect the petition to be approved?
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-------
SFNT BY* 1-23-98 •11:26AM : EPA" /Oo 934 9/40-2 3/20
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4. If the fiacijity does not have a "no migration" petition and the facility injects a
characteristic waste (waste code beginning with D or would begin with a D code if
regulated under RCRA) does that facility decharacteiizcfits waste before injection?
•Ulj/ Aw t Auf 6j i Ka. va c -k*"u. , t~< u)t>ik p* n <
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5. If the answer is no to #4, does the facility have the additional injection capacity to
inject diluted wastes? (i.e., Can the well accept a the larger waste volume after diliution
sufficient to decharactcrize the waste?)
3/a-J- P*.i
6. If the answer is no to #5, does the facility have the capability co treat its injected
waste before injection? How much time would be needed before this treatment could
take place (e.g., before the wastes rould be diverted and/or the treatemnt system
optimized)?
A^-t j 4- MX -V'-* d ^>Y Co K. pt-u
7. If the answer is no to #5. can the waste be transported to an off-site treatment
facility (e.g.. a centralized wastewater treatment plant)? If yes to #7, how much time
would this take7
s
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-------
SENT BY'-
1-23-98 :11:20AM ; EPA- _, 703 934 9740:# 2/12
I4o£V^-/^5~; li/O^AA/A (" f0^
The purpose of this phone survey is to obtain information on the listed underground
injection facilities to evaluate the impact of the Phase IV Land Disposal Restrictions their
operations.
Ask the following questions of che EPA Regional contacts regarding the listed facilities.
1. What type of operations are conducted at this facility? For example, is it a
manufacturing plant, chemical processing plant, commercial storage facility? Obtain as
specific a description of operations as you can. ,
it i A S fl niA ^ ° 4ctj caJ f-f ( ia 14\ £rv 44\a. f\ cu ^kkJU ^
*U r*A^V ^>^0<^cAf fop«. ^v/ ff V - _
• Is the waste a process wastewater or nonwastewater waste? (RCRA
wastewater defined as wastes that contain < 1 % by weight TOC or <1% by
weight total suspended solids.) , ^ \
iCftc-ir ' S o^_ C^mcesJ t.J 4~g uJi> (. Ol Q-CV'^ /»J
• What waste category or waste code is the waste classified? For example is it a
listed waste or characteristic tiazardous waste and if so what hazardous waste
code (i.e., D001, K062 or others)?
U)asVc >5 K>4- a, CA^a.k-4-c- t 1 - ^ . rtM*^ U«
-------
STATUS REPORT ON THE PHASE IV LDR UIC ANALYSIS
We are continuing to research the impact of the Phase IV LDR rulemaking on the
Dupont, New Johnsonville, TN and DeLisle, MS facilities. We have reviewed Dupont's
February 5, 1998 letter to independently verify their claims regarding their inability to
meet the ban on injecting their hazardous mineral processing wastes without treatment.
Summarized below are our current findings.
Dupont claims that each of their subject facilities injects about 1,000,000 gallons
of waste per day. Unless they receive a capacity variance, they will have to shut down
these facilities, because they do not have on-site treatment capability and alternative off-
site treatment or injection capacity is unavailable. They claim it would be impractical to
ship their wastes off-site because it would take at least 200 tanker trucks per day at each
site to transport the waste to an off-site treatment or injection facility. In addition, they
claim that there is no commercial treatment or injection capacity available for their waste
within a reasonable distance for safe transport.
To assess these claims, we used Dupont's reported injection rates and production
schedule from their letter. Based on their information, Dupont operates year round (365
days/year) around the clock (assuming 22 hours/day) and injects at a rate of 750
gallons/minute at the New Johnsonville and 600 gallons/minute at the DeLisle facilities.
Using these assumptions, Dupont generates the following volumes of wastes annually at
each of the subject facilities.
New Johnsonville
750 gal x 60 min x 22 hr x 365 days = 361,350,000 gal/yr or 361 million gal/yr
min hr day year
DeLisle
600 gal x 60 min x 22 hr x 365 days = 289,080,000 gal/yr or 289 million gal/yr
min hr day year
In 1989 EPA sent a questionnaire to Dupont titled the "National Survey of Solid
Wastes form Mineral Processing Facilities." The purpose of this survey was to obtain
information on the generation and management of selected solid wastes from mineral
processing facilities. These wastes were later de-Bevilled and became subject to Subtitle
C of RCRA. They are the newly identified hazardous mineral processing wastes that are
covered by the Phase IV LDR rulemaking.
We reviewed the survey completed by Dupont for the DeLisle facility. In the
survey completed in 1989, Dupont reported injecting a total of 128 million gallons of
special waste in three underground injection wells in 1988. This volume is less than half
of the 289 million gallons Dupont reported injecting in its recent letter. Although they
Page 1
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are currently using four wells, the difference is not made up by adding in the volume from
the newer 4th well (see calculations below).
Special Waste Injected at DeLisle in 1988
Well 1 123,083,000
Well 2 574,000
Well 3 3.892.000
127,549,000 gal in 1988 or 128 million gal in 1988
DeLisle 4th Well
Monthly injection rate from UICWELLS database:
180.000 gal x 12 mon = 2,160,000 gal/yr
mon year
127,549,000 gal special waste in 1988 from Wells 1-3
+ 2,160,000 gal/yr waste for Well 4
129,709,000 gal/yr or 130 million gal/yr
Possible explanations for these differences in the volume of waste could be:
• Dupont's production has increased substantially over the last ten years resulting in a
more than doubling of the waste volume generated.
• Dupont may be currently reporting the volume of all their wastes including non-
hazardous and other hazardous wastes generated by the facilities that were never
included in the Bevill exemption but have been subject to previous LDR rulemakings.
Only the newly identified hazardous mineral processing waste portion of the injected
volume that is subject to the Phase IV rulemaking.
0 If the newly identified hazardous mineral processing waste portion is
segregated from other wastes, the volume of waste subject to Phase IV is
much smaller.
0 If the aggregation of wastes at the plant occurs in such a way that the portion
subject to Phase IV cannot be separated, then the total volume is subject to
Phase IV.
Thus, a high-end estimate of the affected volume for the DeLisle facility would be 289
million gallons/year and a low-end estimate would be 130 million gal/year. We do not
have the New Johnsonville facility's survey response. However, if the facilities operate
similarly, we could assume a similar portion of the waste stream is newly identified
mineral processing waste subject to Phase IV. Assuming 44 % of the waste stream
Page 2
-------
consists of newly identified wastes, then the high-end volume estimate would be 361
million gal/year and the low-end would be 159 million gal/year.
Based on the information presented in Dupont's letter, the subject facilities are
generating the following volume of waste daily.
New Johnsonville
High-end:
750 gal x 60 min x 22 hr = 990,000 gal/day
min hr day
Low-end:
159.000.000 gal x year = 436,000 gal/day
year 365 days
DeLisle
High-end:
600 gal x 60 min x 22 hr = 792,000 gal/day
min hr day
Low-end:
130.000,000 gal x year = 356,000 gal/day
year 365 days
A typical tanker truck for transport of hazardous liquids is limited to carrying 24
to 25 tons, which is about 7,000 gallons of water. The density of water is about 8 lb/gal.
Thus, it is reasonable to assume, as Dupont claims, that a tanker truck would only be able
to carry about 5,000 gallons of their waste given the waste's higher density (10 lb/gal).
Using these assumptions, the number of trucks required to transport Dupont's waste is
presented below.
New Johnsonville
High-end Low-end
990,000/5000 = 198-200 trucks 436,000/5000 = 87-90 trucks
Page 3
-------
De Lisle
High-end Low-end
792.000/5000 = 158-160 trucks 356.000/5000 = 71-73 trucks
Transporting the high-end volume estimates of waste from the New Johnsonville and
DeLisle facilities by truck would require that each truck be loaded within 7 to 9 minutes,
respectively, around the clock. Transporting the low-end volume estimates of waste from
the New Johnsonville and DeLisle facilities would require that each truck be loaded
within 16 to 20 minutes, respectively, around the clock.
We contacted Mr. Mitch Han, Environmental Health and Safety Manager of
Chemical Waste Management (CWM), regarding their available injection capacity at
their commercial injection well facilities located in OH and TX. Based on last years
estimates, CWM has 54,000.000 gallons of available capacity which is substantially less
than the low-end annual volume estimates for either the DeLisle or New Johnsonville
facilities. In addition, Mr. Han indicated that CWM has reduced its transportation fleet
and relies on subcontractors to transport waste. However it is his opinion, based on
experience working with transportation subcontractors, that mobilizing a minimum 160 to
200 trucks per day at each facility would be extremely difficult, if not impossible.
Next we identified commercial wastewater treatment facilities from the capacity-
analysis background document for surface disposed wastes' and commercial injection
facilities from UICWELLS Volume 6 to determine whether adequate treatment or
injection capacity exists to manage Dupont's waste if Dupont is able transport their
wastes. Described below, by Dupont facility, are the results this effort. We set a 200-
mile radius from each site as the limit for safe transport of the large volume of Phase IV
wastes from these sites. Mileage from the Dupont facilities to an off-site management
facility is based on rough estimates using road maps.
New Johnsonville
There are two commercial wastewater treatment facilities within approximately
200 miles of the site (based on 1989 BRS data).
• Tricil Environmental Services Inc., Nashville TN (approx. 75 miles away). Available
treatment capacity - 81 million gallons/year
• Osco Inc., Columbia, TN (approximately 70 miles away). No available treatment
capacity.
! Draft Background Document for Capacity Analysis for Land Disposal Restrictions - Phase IV: Toxicity
Characteristic Metal Wastes and Newly Identified Mineral Processing Wastes (Final Rule) prepared for
Office of Solid Waste by 1CF Inc.
Page 4
-------
Both treatment facilities have insufficient available capacity to handle either the low- or
high-end waste volume estimates for the New Johnsonville facility.
There are no commercial underground injection facilities within 200 miles of the
New Johnsonville facility.
DeLisle
There are no commercial wastewater treatment facilities within approximately 200
miles of the DeLisle facility (based on 1989 BRS data).
There are two commercial underground injection facilities and one Dupont facility
with injection wells within 200 miles of the DeLisle facility.
• Dupont Ponchatrain. LA has an approved no migration petition (approx. 150 miles
away). Available injection capacity is calculated below.
Annual injection rate:
245.500 gal x 12 months =2.946.000 gal/yr
month year
Maximum injection capacity:
130gal x 60 min x 24hr x 365 day = 68,328,000 gal/yr
min hr day year
Available injection capacity:
68,328,000
-2.946.000
65,382,000 gal/year
• Cecos Willow Springs, LA has an approved no migration petition (approximately 200
miles away)
Annual injection rate:
1.990.500 gal x 12 months =23,886,000 gal/yr
month year
Maximum injection capacity:
162gal x 60 min x 24hr x 365 dav = 85,147,200 gal/yr
min hr day year
Available injection capacity:
85.147.200
-23.886.000
61.261.200 gal/year
Page 5
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• Rollins, LA has an approved no migration petition (approximately 200 miles away)
Annual injection rate:
764.500 gal x 12 months =9,174,000 gal/yr
month year
Maximum injection capacity:
150 gal x 60 min x 24hr x 365 day = 78,840.000 gal/yr
min hr day year
Available injection capacity:
78,840,000
-9.174.000
69,666,000 gal/year
Total available injection capacity:
Dupont Ponchatrain: 65,382,000
Cecos 61,261,200
Rollins 69.666.000
196,309,200 gal/year
The available injection capacity at any one of the facilities identified is insufficient to
handle either the low-end or high-end volume estimates of waste generated at the Dupont
DeLisle facility. In addition, the combined total available injection capacity for the three
facilities is insufficient to handle the high-end volume estimate. However, the combined
total available capacity is sufficient to handle the low-end volume estimate.
Summary of Findings
High-end Volume Estimate
Assuming that all of Dupont's injected wastes are subject to Phase IV because: (1) they
are unable to segregate waste streams; or (2) all of their wastes are newly identified
mineral processing wastes:
• It would be impracticable to transport wastes off-site for treatment or injection from
either facility.
• There is either no treatment or insufficient treatment capacity within 200 miles of
either facility.
• There is either no available injection capacity or insufficient injection capacity within
200 miles of either facility.
Page 6
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Low-end Volume Estimate
Assuming that 44 % of Dupont's waste stream is newly identified mineral processing
wastes and can be segregated from other wastes that are injected at either facility:
• It would be difficult, but possible, to transport wastes from either facility for a limited
distance (say no more than 200 miles).
• There is insufficient treatment capacity and no available injection capacity within 200
miles of the New Johnsonville facility.
• There is no available treatment capacity and insufficient injection capacity at any of
the three injection facilities within 200 miles of the DeLisle facility.
• The combined available injection capacity at the three injection facilities within 200
miles of the DeLisle facility is sufficient to handle the low-end volume estimate of the
DeLisle waste.
Page 7
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TELEPHONE LOG
Date: 2/16/98
To: Mitch Han. Environmental Health & Safety Manager
Chemical Waste Management, (630) 218-1612
From: Debra Favre. ICF Inc.
Contacted him to discuss CWM's comment to the 1st supplemental to proposed Phase IV
rulemaking regarding a national capacity variance for UIC. He said that Pan Lee of EPA
had recently contacted him about available injection capacity. Based on last years volume
injected, he believes that CWM has a combined available annual capacity of about
54,000,000 gal at their two commercial injection facilities located in OH and TX. I asked
about the ability to mobilize 200 trucks/day to transport corrosive liquid to one of their
injection facilities. He says they have sold off most of their trucks and rely on subs or
generators to supply transportation. However he stated that based on his experience, it
would be extremely difficult, if not impossible, to mobilize that number of trucks for
daily transport to one of their facilities. Trucks would have to meet DOT requirements to
carry corrosives. Two biggest transporter are TRI-State and JB Hunt (their subs).
Page 8
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TELEPHONE LOG
Date: 2/18/98
To: Larry Meyer. EPA Region 4 (404) 562-9449
From: Debra Favre, ICF Inc.
I contacted Larry Meyer regarding the Dupont DeLisle and New Johnsonville facilities
and their ability to meet the prohibition on injecting without treatment in the Phase IV
rulemaking.
New Johnsonville
He is not as familiar with the enforcement issues as Scott Hoskins (404 562-9781) of
Enforcement. His understanding is that Dupont has signed a Consent Order agreeing to
ceasing injecting in their Class I wells by July 1, 1998, and after which they will begin
operating their treatment system to manage the wastes that previously were being
injected. Dupont's violation is based on the finding that their wells are injecting in a
drinking water source rather that in a zone below a drinking water source in violation of
the SWA. He thinks that Dupont's concern is that there will be a brief period between the
effective date of Phase IV and the start-up of their treatment process where they will not
be able to use their wells, and that is the basis for their need for a capacity variance.
DeLisle
Dupont's petition is deficient because it does not address alternatives to injection such as
Dupont's ability to construct and operate an aboveground treatment system. His
comments on the petition will include this deficiency. He says that Dupont has NPDES
permits for other treated discharge. He believes that the 1,000,000 gal/day claimed by
Dupont is not a combination of all facility wastewaters and that the whole volume is
subject to Phase IV. (That doesn't preclude the possibility of reducing the volume by
more careful waste segregation if wastes are mixed upstream.) He says their are no
injection facilities close enough to directly connect through a pipeline. He believes that
the volume is too large to truck over land to a commercial facility for treatment or
injection. He knows of no commercial treatment facilities in the area that could handle
the Dupont waste.
He indicated that the State of MS in evaluating Dupont's well permit raised the issue of
constructing a treatment system instead of continued injection. He says that Dupont's
response to the State of MS indicated that they are located in a wetland area and there are
environmental hazards to discharging that large a volume of treated waste into the
wetlands. State of MS did not require construction of a treatment process.
Page 9
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TELEPHONE LOG
Date: 2/18/98
To: Scott Hoskins, Enforcement, EPA Region 4 (404) 562-9781
From: Debra Favre, ICF Inc.
He confirmed that Dupont NewJohnsonville is under a consent order to cease injecting in
their wells by July 1, 1998. The order also requires that the wells be abondoned and
plugged by the end of 1998. If they violate the order to stop injecting, Mr. Hoskins says
Dupont will be referred to DOJ to file civil penalties. He understands that Dupont is
having difficulty getting their treatment process operating because they can't find a
market for their byproduct. However, the State of TN indicates that Dupont can landfill
the byproduct waste. EPA says Dupont's well are screened in a designated US Drinking
Water source, but Dupont disputes this. However, they signed the consent order to aviod
litigation. He thinks that Dupont is pursuing a capacity variance as a backup position if
the can't get there treatment system operating in time and would continue injecting in
violation of the Consent Order.
Page 10
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OuP:?nt Specially "hamicals
Cor? Resource Grocp
Mai? Aroo S3
DuPont Specialty Chemicals
February 5,1998,
Mr. Robert E. Smith
UIC Branch, Office of Ground Water and Drinking Water
US Eavirot jnental Protection Agency-Mail Stop 4606
401M Street, SW
Washington, DC 20460
RE: Land Disposal Restrictions • Phase IV • 2-Year National Capacity Variance
Dear Mr. Smith:
E. I. DuPcnt de Nemours and Company, Inc., operates 365 days a year, the two largest titanium dioxide
manufacturing plants in the world. Their continuous operation will be in serious jeopardy without the
Agency g:anting the proposed 2-year National Capacity Variance. Our Johnsonville Plant located
remotely ia Tennessee has a production capability of 25% of the U.S. titanium dioxide market and 10%
of the woild market The titanium dioxide production at this facility is in excess of 300,000 tons/year.
Our DeLisle site is located in Mississippi near Bay St Louis. The titanium dioxide production at this
facility is in excess of 250,000 tons/year, representing 21% of the U.S. market and 8% of the world
production.
The DeLisle and Johnsonville sites currently operate underground injection wells for disposal of low-pH
fluids consisting of high TDS in excess of 200,000 mg/1. The average flow rate to t e underground
injection wells is 750 gpm for the Johnsonville and 600 gpm for the DeLisle site. Due to the corrosive
nature of the waste stream all surface piping that comes into contact with the waste stream is constructed
of fiberglass. All well components are composed of fiberglass piping, titanium casing and packers,
epoxy and compatible cement The estimated cost of an injection well due to the nature of exotic well
components, exceeds $10,000,000. In addition, millions of dollars arc spent to maintain well integrity.
The Johnsonville site has three wells and the DeLisle site has four wells. We are not aware of any
commercial facility with wells that are constructed to handle our waste stream. In acdition, injection
volumes are approximately 1,000,000 gallons per day per site. The waste stream has a high density and
weighs o^er 10 lbs/gal. Due to the high density nature of the fluid, a transport truck could only cany
5,000 gallons and it would take 200 transport vehicles moving out daily at each facility to move the
volume of fluids. These trucks would have to be constructed of fiberglass or titanium to cany the
material because of compatibility requirements. Therefore, moving fluids from the sites to treatment
facilities is an impractical task and an unnecessary environmental risk which would involve the potential
exposure of hazardous waste Qow-pH, Pb and Cr) to the public because transporting would involve
public highways.
Based on EPA's own study, underground injection wells are safer than other disposal methods, even
safer than storing waste in tanks. DuPont continues to evaluate alternatives to underground injection
wells based on environmental concerns, technical feasibility and economics. Our Johnsonville site has
been constructing and integrating a neutralization project based on current production for the last four
years. The expenditures for this alternative have exceeded $70,000,000. The project is moving into the
final stagrs and will produce a NaCl product and a FeC03 that currently has no market outlet However,
due to the nature of our titanium dioxide stream, over 300 acre feet per year of solids will be placed in
land storage at the site. Based on our experience, any alternatives to deep wells involve long term
construction as well as operating start-up that requires additional time to work out issues.
P.O. Sc*32«9
Sesumori.TX 77704
Tai {<109) 727-9355
-------
Page 2 - Robot E. Smith
February 5, 1998
The DeLisle site is required by the-state to pursue alternatives that are based on environmental and
economic feasibility. DuPont DeLisle has looked at over 100 alternatives to underground injection
wells. The state of Mississippi is in agreement that the DeLisle site does not have a more favorable
environmental alternative than underground injection wells. DeLisle's location is not favorable for
neutralization since there is no land storage on site for the 300 acre feet per year of solids and there is
not a permitted storage facility readily available for the DeLisle solids. In addition, the state is
concerned regarding salts entering the Bay of St. Louis.
As you know, DuPont DeLisle has pursued the no-migration petition process since 1990 when the
petition was submitted to Atlanta EPA (April 4,1990) as the best environmental option for our facility
and we foresee no other available option in the near future. Any alternative would involve at least a five
year construction program. The 2-year National Capacity Variance will allow EPA to complete the no-
migration review and approval process for our DeLisle site. In addition, the option will still be available
for the Agency to grant case-by case extensions to facilities that will be approved, yet the Agency needs
more time to process the application. We understand that the Region has based their work priorities on
the belief that a 2-year National Capacity Variance will be issued as proposed and will be in the final
rules. The Region has stated to us that the Variance needs to be issued because the Agency will not have
a complete product by June 1998.
DuPont appreciates the Agency's support in granting the 2-year National Capacity Variance so that our
facilities can continue operating until the DeLisle petition can be approved and the Johnsonville
alternative is operating.
ledlatlon
James E. Clark
Senior Consulting Associate
JECaa
CC: Bruce Kobelski - EPA - Washington
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Appendix D - Estimate of Time Required to Build an Acid Waste Treatment
System
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APPENDIX D - ESTIMATE OF TIME REQUIRED TO BUILD AN ACID WASTE
TREATMENT SYSTEM
EPA's cost analysis performed for the mineral processing wastes Regulatory Impact
Analysis (RIA),1 assumes that on-site treatment of corrosive liquid wastes, such as the acid
wastes generated by Dupont at the DeLisle and New Johnsonville facilities, involves
neutralization, precipitation, and dewatering, resulting in a sludge requiring
stabilization/solidification. Neutralization is the process of adjusting either acidic or caustic
liquid waste streams to a pH of approximately 7.0. Precipitation, which may occur as a result of
the addition of neutralization reagents, or which may require additional reagents, is necessary to
remove dissolved solids, such as toxicity characteristic metals from solutions. Corrosive waste
streams are neutralized by the addition of an alkaline material, such as lime. Additional reagent
will cause precipitation of dissolved metals. The precipitated metal sludge or slurry is then
dewatered in preparation for stabilization. There is probably no lower limit on the solids content
of sludges handled by cement solidification, although dewatering is advantageous as a volume
reduction measure.
The RIA assumes in preparing cost estimates that the following equipment would be
purchased to construct a treatment system for acidic wastes containing toxic metals.
• At least 1 stainless steel neutralization reactor
• At least 1 stainless steel mix tank
• Piping, electrical and instrumentation
• At least 1 carbon steel holding tank
• At least 3 carbon steel centrifugal pumps for calcium hydroxide solution out of the
mix tank and out of the holding tank, and for waste flow into the reactor
• At least 1 stainless steel centrifugal pump for the waste flow into the reactor
• At least 2 cast iron agitators for the mix tank
• At least 1 stainless steel agitator for the reactor
EPA assumes that large capacity tanks can not be prefabricated and must be field erected
requiring about 7 to 10 weeks lead time.2 The treatment system described above would involve
at a minimum three large capacity tanks. Although these tanks could be field erected
concurrently it is more likely that some work would be performed in tandem extending the time
required to obtain and erect the tanks to as much as 15 to 30 weeks. In addition, time must be
allocated to install piping, pumps, electrical and instrumentation requiring approximately an
additional 4 to 6 weeks. After installation of equipment, additional time must be planned for
testing and operational adjustments before the system is fully operational. This testing and
adjustment could require as much as 4 weeks. Environmental permits (e.g., for air emissions and
'EPA. "Application of Phase IV Land Disposal Restrictions to Newly Identified Mineral Processing
Wastes. Regulatory Impact Analysis," prepared by ICF Inc. For the Office of Solid Waste, Draf. January 28. 1998.
2SAIC & ICF Inc., "Availability and Cost of Storage Units Suitable for Mineral Processing Secondary
Materials," submitted to Office of Solid Waste, EPA, December 18. 1996.
-------
surface waste disposal) must be obtained, which may take weeks to months following
construction and testing. In certain jurisdictions, building permits and other environmental
permits must be obtained before construction may begin. This lead time may range from weeks
to months. Other unforseen delays such as those due to weather could increase the length of time
to complete construction by additional months. Thus, when all the lead time is added, a year or
more could be needed before the treatment system is operational.
-------
Appendix E - Alternative Treatment and Injection Capacity
-------
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EXHIBIT E-1
AVAILABLE COMMERCIAL INJECTION CAPACITY
Facility ID
Facility Name
6I&
Injected
from On-site
(ton*)
BRS Injected
from Off-site
(tons)
BRS Total
Injected
(tons)
BRS Total
Injected
(Mgal)
UIC
Well id
UIC Annual
Injection
Rate
(Mgal/year)
UIC Annual
Injection Rate
(tons/yr)*
Ulfc Max
Injection
Rate
(gal/mln)
Max Injection
Capacity
(Mgal/year)
Available
Capacity
(Mgal/year)
Notes
LAD000618256
Cecos International
(Willow Springs)
58,419
7,728
66,147
15
001
24
161.6
46.75
85
61
LAD000778514
Rollins Environmental
Services of LA, Inc.
20,511
4.074
24,585
6
Well 1
9
150
125
79
70
OH-CWM
Chemical Waste
Management, Inc.
9,166
117,265
126,431
29
2
4
5
6
12
3
14
17
90
90
90
90
75
39
75
85
47
47
47
47
35
45
34
30
TXD WDW-147
Merichem Company
479,163
Not Found
479,163
109
WDW-
147
161
300
Uknown
158
49
BRS volume
used
TXD WDW-157
Empak, Inc.
2,074
21,264
23,338
5
WDW-157
156
100
99.13
53
0
TXD WDW-160
Chemical Waste
Management (Port
Arthur)
107,541
23,101
130,641
30
WDW-160
104
200
154
105
1
TXD WDW-167
Wastewater, Inc.
Not Found
Not Found
Not Found
WDW-167
50
0
26
26
TXD WDW-169
Disposal Systems,
Inc. (Deerpark)
Not Found
56,489
56,489
13
WDW-169
WDW-249
80
80
260
260
64
61.58
137
137
56
56
TXD WDW-186
American Ecology
Corp.
7,821
15,381
23,202
5
WDW-186
107
300
39 42
158
51
TXD WDW-278
Texas Ecologist, Inc.
7,958
Not Found
7,958
2
WDW-278
Unknown
100
24.33
53
51
BRS volume
used
TXD WDW-070
Disposal Systems of
Corpus Christ), GNR
Group
4,765
25,373
30,138
7
WDW-070
80
150
Unknown
79
0
Available Injection Capacity
565
Available Capacity = Maximum Injection Capacity ¦ Annual Injection Rate
Maximum Injection Capacity = Max Injection Rate (gal/min) x 60 min/hr x 24 hr/day x 365 days/year
Annual Injection Rate = UIC Annual Injection Rate or BRS Total Injected whichever is larger, unless noted otherwise.
BRS Total Injected in Mgal estimated Irom BRS Total Injected in tons by applying the conversion factor of 4399 6 tons ol water = 1 Mgal or water.
-------
Appendix E
UMfTEO STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D£. 20460
i
pwnofnrium
smsoF
WATB)
To: Benjie Carroll (0S-321W)
From: Debra DiCianna rfjuititL' & UJXJOU
Engineering and Analysis Division (WH-S52)
Date: April 30, 1993
Subject: Treatment Capacity Information from Waste Treatment Industry Project
Attached is the information you requested regarding available treatment capacity at
Centralized Waste Treatment facilities* This information was collected in the 1991
Waste Treatment Industry Questionnaire by the Office of Water and represents 1989
data. Names and addresses of facilities are also listed.
All of the facilities included have received a final or interim RCRA Permit. None of the
information provided pertains to waste which is underground injected. Some facilities
did not supply the capacity information requested due to complex operations.
Therefore, two totals are presented. One total represents the actual values reported.
The second total Is scaled-up to included facilities which did not submit data. Beiow
are listed the overall totals:
If you wish to obtain any additional information or have any questions, piease contact
me at (202) 260-7141.
Tudor Davies (WH-551)
Ramona Trovato (WH-550G)
Woody Forsht (WH-552)
Bruce Kobeisici (WH-550G)
1989 Reported Capacity Total: 9,669,611,960 gate/year
1989 Scaled-Up Capacity Total: 11,341,084,753 gals/year
( = Reported Capacity Total + 11 * Average Capacity)
-------
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-------
WASTEWATER TREATMENT SYSTEMS DATA FROM THE 1991 BIENNIAL REPORTING SYSTEM
EPA ID NUMBER
INF QUANTITY
GAL
FROM BRS DATA
B
MAX OPP CAP
GAL
FROM BRS DATA
MAX OPP CAP
CAL
FROM OU SURVEY
LIQ EFF QUAN
CAL
FROM BRS DATA
E
NEW OPP
CAPACITY
FROM BRS DATA
F
DIFFERENCE
IN OPP CAP
C-B
G
AMOUNT
AVAILABLE
B-A
CAD050806850
CAD059494310
CAT080033681
CTD000844399
CTD001184894
CTD072138969
CTD990672081
ILD000666206
110064410353
IN0006050967
IN0093219012
MDD980555189
MND981098478
NCD121700777
NED043534635
NJ0002141950
NJD002385730
NJD089216790
NVD980895338
NYD000691949
NY0080336241
OHD000724153
OHD004178612
OHD087433744
OKD007233836
ORD009020231
ORD980725592
PAD010154045
PAD059087072
PAD085690592
RID980906986
TND003376928
UA0041337130
WV0004325353
WVD076826015
1.106,843
2,281,976
4,762,512
360,768,560
574,131
11,185,574
60,067,991
16,231,493
1,793,987
2,772,124,412
53,475,694
1,662,231
4,597,350
1,901,489
6,678,629
655,428
10,347,456,240
48,923,122
641,903
11,222,398
25,079,632
29,714,577
16,642,080
0
570,943,381
185,493,828
39,115,200
17,186,856
26,770,000
1,483,895
1,416,960
7,835,470,800
282,837,630
1,743,953,866
223,468,565
13,
27,
1,207,
2.283,
1,
28.
777,
30.
6.
50.
150,
50,
«.
7
-J;
"I:
240,
75,
98,
354,
728,
76,
27,
981,
3,
8,400,
366,
2,188,
W.
250,000
000,000
824,000
660,000
370,500
632,648
777,310
398,036
240,000
677,025
804,016
360,000
417,487
008,000
191,794
000,000
054,720
112,860
057,200
0
920,000
000,000
160,000
0
285,248
763,458
867,000
000,000
120,000
434,280
961,224
000,000
313,416
298,888
013,402
1.
1,760,
2.
38,
1,760,
106,
1«.
299,
«,
15,
75,
5«,
14,600,
52,
7,
63,
86,
23,
720,
407,
407,
30,
7«,
35,
6.
8,
37,
2,102,
894,333
0
0
668,673
375,000
535,860
668,673
202,000
000,000
0
290,000
100,000
130,000
000,000
243,992
000,000
000,000
560,000
750,400
800,000
0
000,000
300,000
400,000
000,000
788,113
788,113
000,000
200,258
985,587
000,000
710,227
193,500
000,000
0
1,082,109
2.280.000
4,078,584
414,810,000
571,370
9,307,911
60,882,904
8.381.001
1,704,941
2,979,115,244
45,735,915
3,925,928
2,783,240
1,711,340
6,669,144
198,676
10,522,748,640
49,675,058
428,907
11,196,084
24,503,779
37,446,700
13,286,400
0
557,166,418
577,768,882
38,985,200
12,783,720
53,472,500
127,569,600
1,733,520
7,835,470,800
282,401,819
2,537,140,000
217,813,732
0
-11,355,667
12,143,158
0
-27,000,000
24.718,024
0
-1,207,824,000
-522,991,327
1,203,061,488
0
1,922,891,440
0
1,004,500
796,369
0
9,903,212
17,447.074
0
982,891,365
717,709,319
0
75,803,964
14,166,543
0
7,760,000
4,446,013
0
-50,677,025
-2,721,447,387
0
148,485,984
97,328,322
0
•6,260,000
48,697,769
0
6,712,513
3,820,137
0
67,992,000
5,106,511
0
-52,947,802
46,513,165
0
50,000,000
3,344,572
0
535,945,280
3,716,598,480
0
-110,552,860
114,189,738
0
-4,306,800
4,415,297
0
7,800,000
-11,222,398
240,000
-240,920,000
215,840,368
0
-12,000,000
45,285,423
94,500,000
•11,860,000
81,517,920
1,200,000
23,400,000
0
0
365,714,752
-216,658,133
28,902,728
•320,975,345 .
543,269,630
0
, 330,921,113
37,751,800
66,000,000
3,000,000
9,813,144
220,544,853
-906,919,742
954,350,000
0
35,551,307
-1,049,615
0
2,038,776
2,544,264
0
-8,391,209,773
564,529,200
0
•329,119,916
83,475,786
0
-86,298,888
444,345,022
0
-93,013,402
-130,455,164
411,387,581
-9,731,387,784
7,859,283,279
TOTAL
24,707,689,233
32,566,972,513
22,835,584,729
26,444,830,066
-------
REPORT DOCUMENTATION | 1. Report No.
PAGE |
| EPA530-R-99-025
1
12.
1
1
1
| 3. Recipient's Accession No.
1
| PB99-156 002
1
4. Title and Subtitle
Background Document for Analysis of the Land Disposal Restrictions-Phase IV: Underground Injection Data
and Issues
| 5. Report Date
1 April 1998
16.
I
I
I
7. Authors)
| 8. Performing Organization Rept. No.
I
I
I
9. Performing Organization Name and Address
| 10. Project/Task/Work Unit No.
U.S. EPA
OFFICE OF SOLID WASTE
401 M STREET, SW
WASHINGTON, DC 20460
|11. Contract © or Grant (G) No.
|©
1
1(G)
1
1
12. Sponsoring Organization Name and Address
| 13. Type of Report & Period Covered
1
1 Technical Background Document
1 14.
1
1
15. Supplementary Notes
16. Abstract (Limit: 200 words)
Evaluates the impact of the Phase IV LDR rulemaking on underground injection of hazardous waste and the need for national capacity
variances from the land disposal prohibitions. Presents legal background for the LDR program, toxicity characteristic metal wastes, mineral
processing wastes, the Phase IV rulemaking, and the types of wastes covered by the Phase IV LDR rulemaking. Provides background on the
underground injection control program and facilities affected by this rulemaking. Discusses LDR exemptions, Phase IV wastes prohibited from
injection. Details the availability of on-site and off-site alternative treatment and injection capacity. Summarizes the major categories of
injected waste affected by the Phase IV rule and the availability of alternative treatment and injection capacity for underground injection
facilities subject to this rule.
------- |