NATIONAL CAPACITY ASSESSMENT REPORT:
Capacity Planning Pursuant to
CERCLA Section 104(c)(9)
March 25, 2015
U.S. Environmental Protection Agency
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Table of Contents
Executive Summary /'
Introduction 1
Background 2
Data Development 3
Baseyear Data 4
Baseline Data 5
Projection Data 6
Methodology Issues 8
Compilation of Permitted Operating Capacity Data 8
Demand from Facilities Generating Small Amounts of Hazardous Wastes 8
Demand from Nonhazardous Wastes 9
Demand from Foreign Imports and Exports 10
Demand from Mixed RCRA Wastes 10
Demand from Hazardous Wastes Requiring Specialty Management 10
Discussion of National Aggregated Data by EPA 11
National Assessment of Future Capacity 11
Conclusions 12
References 19
Appendix A Commercial Capacity Data 22
Appendix B Commercial Hazardous Waste Management Facilities 130
Appendix C CAP Management Categories 1578
Appendix D Methodology for Estimating Hazardous Waste Demand 170
Appendix E Demand and Capacity at Commercial Hazardous Waste
Specialty Operations Facilities 196
Appendix F 1993 Guidance 202
Appendix G States' Comments on 1989 Capacity Assurance Planning Process 206
(Note: The 1993 Guidance and the State's comments on the 1989 capacity assurance planning process
are available in PDF format only. Appendices F and G include the cover pages of these documents as a
reference.)
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Executive Summary
Section 104(c)(9) of the Comprehensive Environmental Response Compensation, and Liability Act
(CERCLA), or Superfund law, requires that prior to the U.S. Environmental Protection Agency
(EPA) providing funding for any remedial actions, a state must assure the availability of hazardous
waste treatment or disposal facilities that have adequate capacity to manage the hazardous waste
expected to be generated within the state over 20 years. The Congressional intent of this
requirement was to assure that hazardous waste management capacity would be available to
avoid improper disposal and management issues.
To help states fulfill this statutory requirement, a national planning process was developed by a
workgroup comprised of state, EPA, regulated industry, and environmental representatives. This
planning approach is described in the Guidance for Capacity Assurance Planning document dated
May 1993 (hereafter referred to as the 1993 Guidance; available at
http://infohouse.p2ric.org/ref/23/22567.pdf). and involves EPA assessing capacity nationwide by
aggregating state-specific data. Sources used to develop the data needed for the national
assessment include the Hazardous Waste Report (also known as the Biennial Report or BR;
available at http://www.epa.qov/osw/inforesources/data/biennialreport/), information from
commercial management facilities, and results from Internet research. The Agency's national
assessment of capacity for the treatment and disposal of hazardous waste in this Report indicates
that there exists adequate national capacity through the year 2039.
The information presented in this Report shows adequate capacity through 2039 for 10 commercial
management categories. EPA recommends that management of certain waste streams should be
studied in more detail. Specifically, EPA is conducting analyses to examine the generation and
management of wastes containing mercury and wastes containing dioxin. The results of these
analyses will be made available to the public once they are ready for review.
The statutory planning horizon to assess the capacity for the treatment and disposal of hazardous
waste for the next 20 years goes well beyond the normal permitting periods, which are typically 5
to 10 years. For this reason, the uncertainties of the permitting and permit renewal processes are
inherent uncertainties in any long-term projections of capacity. Moreover, because states typically
permit treatment and disposal facilities; and because states are required to provide the CERCLA
assurance to EPA, it is critical that states be fully engaged in the ongoing analysis of national
capacity. EPA also believes that public involvement by all stakeholders at the national and state
level is important regarding issues related to hazardous waste management practices and the
development of hazardous waste management programs. For this reason, EPA plans to take
comments on this Report through EPA's Capacity Assurance Planning web page
(http://www.epa.gov/waste/hazard/tsd/capacitv/index.htm) for consideration in future capacity
assessments.
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Introduction
CERCLA Section 104(c)(9)
(9) Siting. Effective 3 years after the enactment of the Superfund Amendments and Reauthorization Act
of 1986, the President shall not provide any remedial actions pursuant to this section unless the State in
which the release occurs first enters into a contract or cooperative agreement with the President
providing assurances deemed adequate by the President that the State will assure the availability of
hazardous waste treatment or disposal facilities which -
(A) have adequate capacity for the destruction, treatment, or secure disposition of all hazardous wastes that are
reasonably expected to be generated within the State during the 20-year period following the date of such
contract or cooperative agreement and to be disposed of, treated, or destroyed,
(B) are within the State or outside the State in accordance with an interstate agreement or regional agreement or
authority,
(C) are acceptable to the President, and
(D) are in compliance with the requirements of Subtitle C of the Solid Waste Disposal Act
Section 104(c)(9) of the Comprehensive Environmental Response Compensation, and Liability Act
(CERCLA) requires that the U.S. Environmental Protection Agency (EPA) not provide any remedial
action funding to a state unless the state first enters into a state Superfund Contract (SSC) or
Cooperative Agreement (CA) that assures the availability of adequate capacity to manage
hazardous wastes generated in the state for 20 years following the date of the response
agreement. The statute specifies that adequate capacity must be within a State or outside a State
in accordance with an interstate agreement or regional agreement or authority.
A national planning process was developed to help support states in fulfilling this statutory
mandate. The first phase of the national planning approach is to assess the availability of capacity
nationwide. In evaluating capacity nationwide, the Agency assumes private agreements for the
interstate treatment or disposal of hazardous waste have been or will be executed if adequate
capacity otherwise exists.
This Report describes the effort to assess the national capacity by following the analytical
guidelines detailed in the Guidance for Capacity Assurance Planning document dated May 1993
(hereafter referred to as the 1993 Guidance; available at
http://infohouse.p2ric.org/ref/23/22567.pdf; refer to Appendix F) and using 2011 Hazardous Waste
Report data (also known as Biennial Report data or BR data; available at
http://www.epa.qov/osw/inforesources/data/biennialreport/). The purposes of this Report are to
provide: (1) the Agency's assessment that adequate national capacity exists, (2) the Agency's
methodology used to conduct this assessment, (3) resolutions to a number of methodological
issues raised in conducting this assessment, and (4) the data used to conduct this assessment.
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Background
CERCLA was amended by the Superfund Amendments and Reauthorization Act (SARA) on
October 17, 1986. These amendments include the provisions under Section 104(c)(9) that require
states to assure the availability of hazardous waste treatment or disposal facilities that have
adequate capacity to manage the hazardous waste reasonably expected to be generated within
the state over 20 years prior to the President providing funding for any remedial actions.
These assurances are required three years after the enactment of SARA and must be provided in
any SSC or CA entered into between that state and the President. Therefore, after October 17,
1989, no new Superfund remedial actions may be funded using federal remedial action resources
unless a state first enters into such an agreement providing assurances that the President deems
adequate. The President has delegated the authority to determine adequacy to the EPA
Administrator. (Refer to CERCLA Section 104(c)(9).)
Under the program that EPA implemented in 1989, states submitted Capacity Assurance Plans
(CAPs) to the Agency as the basis of their assurance. Through these CAPs, each state had to
demonstrate that it had sufficient in-state capacity or agreements with other states to share
capacity for 20 years. Because of concerns raised by the states over the 1989 capacity assurance
planning process (refer to Appendix G), the Agency worked closely with the states to develop a
planning process that first focuses on an assessment of national capacity. The assessment of
national capacity is intended to better reflect the reality of waste flows and needs for future
management capacity.
In May 1993, EPA finalized the 1993 Guidance. The 1993 Guidance describes a phased approach
for states to assure the future availability of hazardous waste treatment and disposal capacity. The
initial phase involves developing data for demand and commercial capacity, and assessing
capacity on a national level. If capacity is projected to exist after the assessment of the demand
for future capacity, then all states have met the assurance requirement. If shortages are predicted
nationwide, states that have a demand exceeding their supply of capacity in a shortfall
management category are expected to address the shortages through waste minimization and
capacity development efforts.
After the 1993 Guidance was issued, states had one year to prepare the CAP data submissions
needed for the first phase of the national planning process. The data submissions demonstrated
the state's knowledge of its existing hazardous waste management systems, provided the
projections of the state's process or "recurrent" waste demand for commercial management, and
provided the commercial management capacity available within the state. This data submission
also included information about the state's waste minimization program so the state could justify a
10 percent reduction in projected demand. The data submission did not include projected demand
from cleanup or one-time waste due to complexity and consistency issues. In January 1995, EPA
published the One-time Waste Estimates for Capacity Assurance Planning document (available at
http://nepis.epa.qov/Exe/ZvPURL.cqi?Dockev=900V0T00.TXT). This report provided estimates for
Superfund remedial actions, Superfund removal actions, RCRA corrective actions, underground
storage tank cleanups, along with state and private cleanups using a very complicated and
resource intensive formula.
Once the EPA Regions reviewed the data submitted by the states for consistency and accuracy,
EPA Headquarters then calculated the total national demand on commercial management by
aggregating the states' projected demand and projected commercial capacity through the year
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2013. The first national assessment was finalized in November 1996, which was over three and a
half years after states initiated the planning process by developing their data. The results of this
enormous undertaking are presented in a document titled National Capacity Assessment Report:
Capacity Planning Pursuant to CERCLA Section 104(c)(9) dated November 1996 (available at
http://www.epa.gov/waste/hazard/tsd/capacitv/index.htm).
When the final assessment was published in the Federal Register (62 FR2156, January 15, 1997;
available at http://www.gpo.gov/fdsys/pkg/FR-1997-01-15/pdf/97-976.pdf), EPA stated that it would
periodically evaluate hazardous waste generation and management information. The primary
source of these evaluations has been the Hazardous Waste Report summaries developed with
each BR data collection cycle. The BR is completed by hazardous waste generators and
treatment, storage, and disposal facilities every two years. The types of information requested in
the BR on hazardous waste include the quantity, nature, disposition, and the efforts taken to
reduce the volume and toxicity of hazardous waste. In addition to reviewing the summary data,
EPA has conducted a variety of analyses that have examined hazardous waste generation and
management throughout the years to support rulemaking activities. The BR data and the
rulemaking analyses have not indicated any drastic changes in management behavior that could
affect the future availability of hazardous waste management capacity. To gather more information
about current and projected management behavior, in 2014, EPA made the decision to reassess
the national capacity situation using the 1993 Guidance. The next section discusses data
development and modifications to the methodology.
Data Development
To develop the data to assess hazardous waste management demand and capacity at a national
level, EPA referred to the 1993 Guidance. This document provides instructions for developing six
data tables using BR as the primary source of data. The tables include demand for on-site
management, demand for captive management (management of wastes from facilities under the
same ownership) along with the demand and capacity for commercial management. The 1993
Guidance also outlines issues to consider and the methods to project the future availability of
capacity for different waste management categories. The projections are focused entirely on future
demand for commercial management capacity. Furthermore, detailed data gathering efforts were
targeted on management methods such as commercial landfills and incinerators.
The 2014 assessment involved some slight modifications to the approach used in 1993 when
states submitted the six data tables to EPA for aggregation and assessment of future capacity. It
is important to mention that the 1993 Guidance was developed based on the criterion that states
lacked access to a data system that included consistent information for all facilities in the nation
and to software capable of handling complex data manipulations for large volumes of information.
Twenty years ago, most states only had access to hazardous waste generation and management
data for their individual state. Often both the hardware and software for the old data systems were
unreliable, causing some states to use manual manipulation of their data to produce the six tables
for their CAP data submission. Limited access to consistent national data caused the 1993
Guidance to rely heavily on the management codes designated by in-state generators and
managers of hazardous wastes. The 1993 Guidance also focused on process or "recurrent"
wastes, and EPA developed estimates for cleanup or "one-time" wastes due to the complicated
methodology needed to project the future of cleanup wastes.
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The 1991 BR data forms had 64 management methods codes that were consolidated into 10
commercial CAP management categories. When waste was sent to facilities for transfer to out-of-
state management facilities, states had to make assumptions about the final destination of these
wastes and select the most appropriate management code. States also needed to reassign
wastes sent for management designated by "other recovery" and "other treatment" codes to an
appropriate management code. The assumptions, using engineering judgment based on
characteristics of the waste streams, could be inconsistent from state to state. The EPA Regions
not only reviewed the data tables for accuracy but also checked the reassignment of wastes from
transfer/storage facilities and the "other" management codes to help ensure national consistency.
For the assessment presented in this Report, all BR and permit data exist in EPA's Oracle-based
RCRAInfo data system.1 Because EPA was able to use these national data in RCRAInfo in
performing the 2014 assessment, EPA could reduce burden on the states by developing the
national data tables. EPA also was able to use a consistent analytical method to reallocate wastes
sent to management by transfer/storage facilities and wastes reported under "other" management
method codes. In general, EPA incorporated adjustments to reflect: 20 years of changes to RCRA
data collection and information systems along with advances in computing capabilities; policy
considerations, such as burden reduction; and regulatory implications that affected the old
methodology. In addition, due in part to increased knowledge of hazardous waste management,
an ability to analyze trends (over 20 years of BR data collection), and improvements in data
software and hardware capabilities, EPA was able to develop estimates for cleanup wastes based
on BR data instead of the complex calculations used 20 years ago for the CAP program.
The following paragraphs provide an overview of the data development process for the 2014
assessment and Appendix D describes the technical computing aspects of the modified
methodology used to develop the data tables necessary for conducting the national assessment.
For more detailed information about the general CAP process, see the 1993 Guidance and the
National Assessment Report finalized in November 1996.
Baseyear Data
The first step in developing data for the national assessment was to generate "baseyear" demand
and capacity data for each of the CAP management categories. The year 2011 is the "baseyear"
because, at the time the analysis was conducted, this was the most recent year for which BR data
were available. EPA used the 2011 BR data to estimate the demand for hazardous waste
management capacity available for onsite management, captive management, and commercial
management. Onsite management demand includes demand from waste managed in
noncommercial units located onsite at the facility generating the waste. Management demand is
considered captive when waste is shipped offsite for management at facilities owned by the same
company as the generator but located at a different site. Commercial management is available to
all generators through private contracts or agreements.
EPA considered all demand for commercial management units, including demand defined as
onsite and captive demand, as demand for commercial management. This assumption is
reasonable because wastes managed onsite by commercial facilities reduce the capacity that is
commercially available at the facilities. For example, if a commercial landfill facility disposes of its
1 RCRAInfo is a national database used by EPA to track entities regulated under Subtitle C of RCRA
(i.e., hazardous waste handlers). RCRAInfo includes data on general handler information, waste generation and
management, permit or closure status, compliance with Federal and State regulations, and cleanup activities.
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own wastes at the landfill, the landfill capacity used by the commercial facility will not be available
for facilities that send their waste for disposal at the commercial landfill.
For information on available quantities of commercial hazardous waste management capacity,
EPA used data in RCRAInfo's Permit Module; limited consultations with hazardous waste
management facilities; and other data sources, such as the results of Internet research.
Appendix A to this Report presents commercial capacity data used in the analysis. Appendix B
presents a list of commercial hazardous waste management facilities and descriptions for the BR
management codes captured by each CAP management category. See Appendix C for examples
of the various types of management technologies for each category.
In the baseyear data, EPA also: (1) reassigned the "other" management codes to the appropriate
CAP management category; (2) separated foreign imports and exports; (3) separated management
operations permitted for specific waste types (e.g., mixed radioactive, explosive wastes, spent pot-
liners); and (4) corrected obvious data errors (e.g., typos in RCRA identification numbers, unit
conversion errors).
Baseline Data
After obtaining baseyear data, EPA adjusted demand represented by the 2011 BR data to the
current year of 2014. This adjusted set of data is referred to as "baseline data," and was used as
the starting point for projecting demand and capacity availability for commercial management.
For the 2014 baseline demand data, EPA separated process or "recurrent" waste demand from
cleanup or "one-time" waste demand because they needed to be addressed differently for a
couple of reasons. First, process wastes are typically generated on a continual, recurring basis
while cleanup wastes can be a one-time event so generation can fluctuate over time. To address
this issue, EPA averaged several cycles of BR data for cleanup wastes for the 2014 baseline
demand.
In 1993, states were asked to incorporate the effect of regulations, such as the Boiler and Industrial
Furnace (BIF) rulemaking, new Listings, expiration of treatment variances and Land Disposal
Restrictions (LDR) rulemakings, on management behavior when going from baseyear to the
baseline and also into the projection years. However, because the RCRA program is a more
mature regulatory program than it was 20 years ago, no adjustments from the 2011 baseyear data
were made to the 2014 baseline.
For the 2014 baseline capacity data, states were asked to review a list of facilities with commercial
management operations developed using the 2011 BR data. Most states provided several
changes and EPA updated the list to reflect available capacity based on operating status in 2014.
Significant changes in commercial management as reported 2011 to 2014 include removing a
large commercial wastewater treatment facility, DuPont Chambers Works, from the capacity
information. This facility was once the largest commercial manager of wastewaters in the U.S. but
stopped accepting wastewaters from outside companies in 2012. The company reported that this
decision was based on market trends demonstrating that waste minimization and enhanced on-site
treatment capabilities have resulted in decreased wastewater volumes needing commercial
management (South Jersey Times, June 17, 2011).2 In addition, capacity for three commercial
landfills included in the 2011 BR data was not included with the 2014 capacity baseline
2 Available at http://www.ni.com/salem/index.ssf/2011/06/dupont chambers works to phase.html; last
accessed on December 30, 2014.
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information. Two commercial landfills presented in the 2011 BR data, Peoria Disposal and CID
Recycling and Disposal, ceased landfilling of hazardous wastes and a third landfill, Envirosafe, was
not included because the facility did not provide any data to update the permit capacity data from
2005. Finally, EPA took into account state-imposed caps on annual receipts at landfills in Alabama
(600,000 tons) and New York (425,000 tons).
The baseline capacity data include data obtained from communications with all the commercial
landfills and incinerators operating nationwide in 2014. EPA verified information about the RCRA
permits for these facilities and also asked about demand from Small Quantity Generators (SQGs)
and management of nonhazardous wastes. Information received from the facilities is included in
Appendix A.
Projection Data
Capacity planning estimates for future capacity needs and waste generation are based on
historical data and current knowledge. After developing the 2014 baseline data, EPA developed
data for the projection years 2019, 2034 and 2039 pursuant to the 1993 Guidance. The projection
years are intended to account for shifts in the management of wastes, and incorporate changes in
the operating status of hazardous waste facilities. EPA does not believe that any current
hazardous waste regulatory activities will substantially alter management behaviors within the next
five years. In addition, projected changes in demand can be due to plant closures and the opening
of new facilities. EPA knows of no facilities closing or opening that would substantially affect the
future demand for hazardous waste capacity.
Waste minimization efforts also can affect future demand. Most of the 1993 CAP data submissions
included information about a State's Waste Minimization Programs. Based on these efforts, the
1993 Guidance allowed for a 10 percent waste reduction credit for future years. Because EPA
does not have current information about all the states' Waste Minimization Programs, no waste
reduction credit was incorporated into the projection year demand estimates.
EPA knows of no commercial management facilities closing or opening that would affect the future
availability of national capacity, so capacity was held constant except for landfills. Since landfill
capacity is consumed over time, EPA depleted the amount of available commercial landfill capacity
over the projection period. Because landfill capacity also is depleted by the wastes from Small
Quantity Generators/Conditional Exempt Small Quantity Generators (SQGs/CESQGs), foreign
imports, and nonhazardous wastes, EPA developed estimates for these wastes and incorporated
the demand into the availability of future capacity.
Exhibit 1 illustrates the data assessment process for the landfill CAP management category.
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Exhibit 1
Data Development Process for the Landfill CAP Management Category
K
&
Process Hazardous
Waste
530,000 tons/year
Clean-Up Hazardous
Waste
670,000 tons/year
Hazardous Waste
Received from Foreign
Countries
23,000 tons/year
Hazardous Waste
Shipped to Foreign
Countries
34,000 tons/year
SQG/CESQGand
Transfer/Storage Facility
Hazardous Waste
400,000 tons/year
Non-Hazardous
Waste
1,800,000 tons/year
H 3,851,218 tons Hfe
¦ > Chemical Waste
1^^ Management
Alabama _
California
Colorado
*
Idaho
I
Indiana
16,236,716 tons
> Clean Harbors
> Chemical Waste
Management
2,535,203 tons
> Clean Harbors
Deer Trail
13,936,000 tons
> US Ecology Idaho
Site B
20,664,782 tons
> Heritage
Environmental
Services
5,036,956 tons
> Chemical Waste
Management
Michigan
15,200,000 tons
> Wayne Disposal
628,000 tons
> US Ecology
Nevada
Nevada
4
New York
V
Ohio
\j
Oklahoma
Texas
k
1,800,000 tons
> US Ecology Texas
140,000 tons
> CWM Chemical
Services
Utah
Louisiana
Oregon
140,000 tons
> CWM Chemical
Services
Otons
> Enfirosafe
Services of Ohio
2,712,840 tons
> Clean Harbors
Lone Mountain
5,612,432 tons
> Chemical Waste
Management of
the Northwest
*
Projected Remaining Commercial Subtitle C
Hazardous Waste Landfill Capacity at 20 and 25 years:
2034: 89,000,000 tons - (20 years x 3,455,000 tons/yr) = 19,900,000 tons
2039: 89,000,000 tons - (25 years x 3,455,000 tons/yr) = 2,625,000 tons
Demand on Commercial Hazardous Waste Landfills Total Maximum Operational Commercial Hazardous Waste Landfill Capacity
3,455,000 tons Year 2014: 89,000,000 tons
25 Years of Future Available Capacity
a Graphics in the exhibit were obtained from the following web sites: http://www.clemson.edu/research/safetv/hazardouswaste/: (2) http://mvmontvs.com/wordpress/?taa=soil-test: (3)
http://www.hubspot.com/small-business-marketinq-hub; (4) http://www.darkecountv.com/news/imaqe-qrants-for-export-assistance.aspx; (5) http://www.123rf.com/photo 11840279 world-trade-and-qlobal-
commerce-as-an-international-svmbol-of-business-tradinq-in-exports-and-import.html: (6) https://www.eqonline.com/lndustries-We-Serve/Refininq-Petrochemical-Chemical.aspx: and
(7) http://www.qolder.com/in/modules.php%3Fname%3DProiects%26sp id%3D80%26sector id%3D44. All web sites last accessed on December 15, 2014.
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Methodology Issues
Upon reviewing the demand and capacity data, the Agency identified some issues it needed to
address before it could complete the assessment of national capacity. Many of the demand issues
arise because the BR data represents only hazardous waste generation and management reported
by Large Quantity Generators (LQGs) and Treatment Storage and Disposal Facilities (TSDFs).
Consequently, the Agency has limited data collected on demand from either SQG/CESQG wastes
or nonhazardous wastes. In most instances, EPA used available data to estimate current demand
rather than use the demand estimates developed for the 1993 national assessment of capacity.
The following discussion describes the issues and their resolution. Most of the resolutions err on
the side of overestimating demand and underestimating capacity.
Compilation of Permitted Operating Capacity Data
The Agency found that some capacity information in RCRAInfo concerning permits issued under
RCRA Subtitle C authority is of limited use for capacity planning purposes. In most cases, the
reported capacity for the permit was actually the ideal, maximum design or theoretical capacity of
the unit not the practical, real-time operating capacity. Using the theoretical capacity and not the
practical capacity can overestimate the amount of readily available capacity. To evaluate available
operating capacity for the facilities, the Agency calculated a practical operating capacity reflecting
real-time operational limitations, which include such considerations as down-time, permit
restrictions, and the optimization of operation for profit.
A confounding variable to the problem of excessive capacity reported in the permit data is the
conversion of capacity into consistent units of measurement. Theoretical design capacity
estimates are often used for purposes of permit approvals and expansions of hazardous waste
management units. These theoretical amounts are measured in units such as British Thermal
Units (BTU) per hour for incinerators and total cubic yards or acres for landfills. Because "tons of
waste per year" was the common measurement unit selected for aggregating all CAP information,
many facility capacities had to be converted to tons of waste per year. This was done by making
assumptions about operating conditions and average waste characteristics. For example, when an
incinerator designed on a BTU per hour basis is converted to tons per year, assumptions about
average waste heating value and density need to be made.
To resolve the issue of theoretical versus practical capacity, EPA conducted limited consultations
with hazardous waste management facilities. Through these consultations, the Agency was able
to obtain remaining permitted capacity at commercial hazardous waste landfills, as well as
information that was used to develop assumptions for real-time operation (e.g., waste heating
value, hours or days of operation in a year). Appendix A to this document presents information
obtained through consultations with commercial hazardous waste management facilities.
Demand from Facilities Generating Small Amounts of Hazardous Wastes
LQGs generate 1,000 kilograms per month or more of hazardous waste, or more than 1 kilogram
per month of acutely hazardous waste. SQGs generate more than 100 kilograms, but less than
1,000 kilograms of hazardous waste per month. Conditionally Exempt Small Quantity Generators
(CESQGs) may not accumulate more than 1,000 kilograms of hazardous waste at any time.
Hazardous waste demand on commercial capacity from (SQGs/CESQGs) is difficult to estimate for
several reasons, including:
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• Data Reporting. All LQGs are required to submit BR data but SQGs/CESQGs are not
required by federal law to complete a BR so information on their demand is not readily
available.
• Transfer/storage facilities. Because SQGs/CESQGs generate small volumes of wastes, they
often send their wastes to transfer/storage facilities. These management facilities primarily
bulk wastes for shipment to off-site treatment, disposal, or recycling facilities. Sometimes
waste can be shipped to several other transfer/storage facilities so tracking a waste from a
particular generator may not be possible due to data limitations. Another issue that complicates
this analysis is that 10-day transfer/storage facilities may not be required to have RCRA
identification numbers.
• State Hazardous Waste Programs. Because state hazardous waste programs can be
broader in scope and more stringent than the federal regulations, some states regulate
nonhazardous wastes as hazardous, such as used oil and polychlorinated biphenyl (PCB)
cleanup wastes. The facilities that often manage these wastes are the transfer/storage
facilities. Many of the transfer/storage facilities may not be required to report BR data.
The instructions in the 1993 Guidance describe how to organize the generation data so that wastes
reported by transfer/storage facilities are separated from the 10 commercial management
categories. This portion of the methodology helps avoid double counting of wastes and provides
data needed to estimate SQG/CESQG demand for commercial management capacity. When
using BR data, double counting of waste demand can happen when waste is shipped off site for
management. Generally, this can be an issue when the generator sending waste to a
transfer/storage facility reports the ultimate disposition of the waste instead of using the
transfer/storage facility management code, and then the transfer/storage facility also reports the
ultimate disposition of the same waste. The CAP methodology uses the BR data submitted by the
generator to estimate demand and examines the transfer/storage data separately thereby avoiding
the double counting of waste quantities reported by transfer/storage facilities.
EPA was able to estimate the demand on commercial capacity from SQGs/CESQGs waste by
referring to information submitted by commercial hazardous waste management facilities. In
particular, the Agency identified the generators of waste that was received by commercial
hazardous waste management facilities in 2011 by examining information in the commercial
facilities' BR form referred to as Waste Received from Off-Site (WR) Form. EPA first developed a
list of all facilities shipping wastes to commercial hazardous waste management facilities
(e.g., landfill facilities, incinerator facilities). The Agency deleted from this list the generators who
submitted a Generation and Management (GM) Form indicating that they shipped waste off site for
management. The Agency then used information from commercial facilities who reported receiving
waste from the remaining list of generators (i.e., the potential SQGs/CESQGs and transfer/storage
facilities) to determine how SQG/CESQG and transfer/storage facility wastes were managed. The
Agency's analysis of this demand appears in Table VI under the column "SQG/CESQG and
Transfer/Storage Facilities" and Appendix D describes the methodology used in estimating the
demand.
Demand from Nonhazardous Wastes
Nonhazardous wastes are wastes that are not federally defined as RCRA hazardous wastes.
Hazardous wastes are wastes with properties that make them dangerous or potentially harmful to
human health or the environment, and are defined at 40 CFR 261.3.
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The overall management trend for all nonhazardous wastes (that is, wastes not otherwise
regulated as RCRA hazardous wastes) is disposal in landfills meeting RCRA Subtitle D
requirements; however, many RCRA permitted TSDFs reported receiving substantial amounts of
wastes not otherwise regulated as RCRA hazardous for management. This may be due to state
hazardous waste regulations, which can be broader in scope and more stringent than the federal
regulations. While the demand for capacity from nonhazardous waste varies considerably by CAP
management category, the demand from nonhazardous wastes as it relates to the assessment of
future capacity does affect the landfill CAP management category because landfill capacity
depletes over time. EPA was able to broadly estimate demand from nonhazardous waste through
limited consultations with commercial hazardous waste management facilities (refer to Appendix A)
and other data sources. Much of the demand is from PCB cleanup wastes according to
information obtained from the commercial hazardous waste landfills. The Agency's analysis of this
demand appears in Table VI under the column "Non-RCRA Industrial Wastes."
Demand from Foreign Imports and Exports
EPA analyzed the data from foreign imports and exports separately from the process and cleanup
waste. Pursuant to the 1993 Guidance, EPA assumed these wastes place a demand on
commercial capacity within the U.S., and are incorporated into the assessment of future capacity
available at commercial facilities. The Agency's analysis of demand from wastes exported to
foreign countries appears in Table VI under the column "Wastes Shipped to Foreign Countries."
Foreign imports also place a demand on capacity similar to waste demand from SQG/CESQG and
nonhazardous wastes. Although there is no federal requirement that these wastes be managed by
commercial hazardous waste facilities in the U.S., they consume available capacity and need to be
accounted for in the National Assessment of Capacity. The Agency's analysis of this demand
appears in Table VI under the column "Wastes Received from Foreign Countries."
Demand from Mixed RCRA Wastes
As part of the Low-Level Radioactive Waste Policy Act (LLRWPA) of 1980 and its 1985
amendments, individual states or groups of states that form compacts are responsible for
disposing of all the low-level radioactive mixed waste generated within their borders, except for
waste produced by federal facilities (which the federal government has taken responsibility for).
This Act establishes a waste management planning, treatment, and disposal framework
independent of the CAP process that specifically deals with the disposal of non-federal radioactive
mixed waste. For federal radioactive waste, the Federal Facilities Compliance Act establishes a
planning process to ensure that these wastes are properly managed. In the Agency's judgment,
treatment capacity for radioactive mixed wastes will be met through these planning mechanisms.
There are two landfills designed and operating primarily for the management of mixed wastes
(refer to Appendix A for additional information on these two landfills). Demand from mixed RCRA
wastes and the two landfills were separated from the general CAP analyses. An analysis of low-
level radioactive RCRA waste demand for landfill capacity shows that there is capacity through
2039 for these wastes (refer to Appendix E).
Demand from Hazardous Wastes Requiring Specialty Management
Some wastes, such as explosive wastes, require management in units specifically designed for the
unique management required by these wastes. These units typically are permitted to meet the
exact specifications of the unique waste stream and not available for management of all waste
types. In particular, one commercial incinerator currently operating has been designed exclusively
for treatment of explosive wastes. In addition, one permitted incinerator has capacity in the permit
10
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designated for the management of spent potliners from primary aluminum reduction (i.e., EPA
listed K088 waste). These wastes and the dedicated capacity to manage these wastes were
evaluated separately from the incinerators permitted to accept a variety of different hazardous
wastes (refer to Appendix A for additional information on these commercial management facilities).
The analysis shows that there is capacity through 2039 for all these wastes (refer to Appendix E).
Discussion of National Aggregated Data by EPA
Tables I through V of this Report show EPA's aggregation of hazardous waste demand and
capacity data:
• Table I, titled "2011 National Baseyear Data Representing Hazardous Waste Generated and
Managed Onsite," shows a national aggregation of 2011 baseyear demand data for waste
managed on site.
• Table II, titled "2011 National Baseyear Data Representing Management of Hazardous Waste
at Captive Facilities," presents wastes generated and managed in-state at captive facilities.
Captive facilities are facilities owned by the same company as the generator but are at a
different physical location. Their capacity can only be used by generators under the same
ownership or by generators with whom the facility has an agreement to manage their waste.
• Table III, titled "2011 National Baseyear Data Representing Management of Hazardous Waste
at Commercial Facilities," shows wastes managed at commercial facilities. National demand
estimates for the baseyear include hazardous wastes shipped to other states and wastes
generated and managed in-state. The table also includes maximum operational commercial
hazardous waste management capacity.
• Table IV, titled "National Baseline and Projected Demand for Commercial Hazardous Waste
Management Capacity," reports projected demand of hazardous wastes generated by LQGs
and TSDFs for commercial capacity. Demand is projected for both process or "recurrent"
wastes and cleanup or "one-time" wastes.
• Table V, titled "National Baseline and Projected Maximum Commercial Hazardous Waste
Management Capacity," shows capacity data for the baseline and projection years.
National Assessment of Future Capacity
The national assessment of hazardous waste capacity for 20 years is presented in Table VI, titled
"National Capacity Assessment of Projected Remaining Commercial Hazardous Waste
Management Capacity." Specifically, the information in Table VI shows:
• Projected remaining commercial hazardous waste capacity not utilized by hazardous waste.
This is the maximum commercial hazardous waste management capacity for year 2039 from
Table V minus the demand for year 2039 from Table IV.
• Estimated additional demand for commercial capacity. In assessing future capacity, the
Agency considered the impact that additional demand may have on commercial hazardous
waste management capacity. In particular, the Agency considered demand from
SQGs/CESQGs and transfer/storage facilities, exports and imports of hazardous wastes, and
nonhazardous wastes managed at hazardous waste management facilities.
11
-------
• Agency's assessment of future capacity.
As shown in Table VI, there is adequate capacity through the year 2039 for all 10 CAP
management categories. For landfills, the projected remaining management capacity calculation
takes into account the depletion of available landfill capacity over time.
Conclusions
EPA has updated the national assessment of capacity for the treatment and disposal of hazardous
wastes for the next 20 years. Based on its analyses of the data presented in this Report, the
Agency has determined that adequate national capacity for the treatment and disposal of
hazardous waste exists for 20 years (i.e., year 2034) and through the year 2039. Although EPA
believes there is national capacity, states and regional groupings of states should continue
hazardous waste management planning activities to ensure that adequate capacity exists in the
future.
While currently there is adequate hazardous waste treatment and disposal capacity, there is the
potential for unforeseen circumstances (e.g., new federal regulations, permit denials, taxes on
management, statutory limitations on landfills, and changing market conditions) that could affect
the future availability of management capacity. Nationally, the industry is consolidating and
restructuring as indicated by the existence of fewer landfills, incinerators, and energy recovery
facilities permitted under RCRA Subtitle C requirements than reported in the 1993 CAP data
submissions. The dynamic hazardous waste market and the uncertainty of the permitting process
make it difficult to guarantee that the current surpluses of hazardous waste management capacity
will continue to exist. Although the Agency believes the information presented in this Report
demonstrates the future availability of treatment and disposal capacity, the Agency will continue to
periodically collect and evaluate data to ensure that the requirements of CERCLA 104(c)(9) are
satisfied.
While implementation of the methodology presented in the 1993 Guidance predicts the future
availability of capacity through 2039 for all 10 CAP management categories, EPA believes that
management of certain waste streams should be studied in more detail. Specifically, EPA plans to
conduct analyses to examine the generation and management of wastes containing mercury and
wastes containing dioxin. The results of these studies will be made available to the public once
they are ready for review.
Furthermore, assuring adequate capacity requires active planning on the part of all parties,
including states, tribal governments, industry, and commercial management facilities. This
necessitates that all states periodically examine their capacity situations, identify areas of concern,
and develop plans that consider future needs. These planning exercises will add to states'
knowledge of their hazardous waste management systems, help them implement waste
minimization programs, and encourage companies to replace inefficient treatment technologies
with safer and more innovative technologies. This can be especially important if studies of
hazardous waste management data show capacity issues for specific waste streams anticipated to
be generated within a state's borders.
12
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Table I
2011 National Baseyear Data Representing Hazardous Waste Generated and Managed On Site
Hazardous Waste
CAP Management Category
Managed On Site
(Tons)
RECOVERY
Metals Recovery
29,000
Solvents Recovery
54,000
Inorganics Recovery
47,000
Energy Recovery
660,000
TREATMENT
Fuel Blending
3,600
Incineration
530,000
Wastewater Treatment
35,000,000
Sludge Treatment/Stabilization/Encapsulation
54,000
DISPOSAL
Land Treatment or Application
17,000
Landfill
2,300,000
Deepwell or Underground Injection
21,000,000
TRANSFER/STORAGE
Transfer/Storage
370,000
13
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Table II
2011 National Baseyear Data Representing Management of Hazardous Waste at Captive Facilities
Hazardous Waste
CAP Management Category
Managed at Captive
Facilities
(Tons)
RECOVERY
Metals Recovery
50
Solvents Recovery
2,300
Inorganics Recovery
0
Energy Recovery
26,000
TREATMENT
Fuel Blending
0
Incineration
84,000
Wastewater T reatment
310
Sludge Treatment/Stabilization/Encapsulation
0
DISPOSAL
Land Treatment or Application
0
Landfill
200
Deepwell or Underground Injection
57,000
TRANSFER/STORAGE
Transfer/Storage
0
14
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Table III
2011 National Baseyear Data Representing Management of Hazardous Waste at Commercial Facilities
CAP Management Category
Demand for Commercial
Hazardous Waste Management Capacity
Maximum Operational Commercial
Hazardous Waste Management
Capacity
(Tons/Year)
Process Waste
(Tons)
Cleanup Waste
(Tons)
RECOVERY
Metals Recovery
930,000
700
1,800,000
Solvents Recovery
150,000
100
2,500,000
Inorganics Recovery
430,000
3,800
526,000
Energy Recovery
590,000
80
1,900,000
TREATMENT
Fuel Blending
390,000
1,100
4,300,000
Incineration
280,000
90,000
1,100,000
Wastewater T reatment
570,000
41,000
12,000,000
Sludge Treatment/Stabilization/Encapsulation
480,000
140,000
8,100,000
DISPOSAL
Landfill
530,000
670,000
89,000,000 (Total permitted tons)
Deepwell or Underground Injection
2,300,000
3,700
3,300,000
TRANSFER/STORAGE
Transfer/Storage
170,000
4,500
15
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Table IV
National Baseline and Projected Demand for Commercial Hazardous Waste Management Capacity
Data represents demand from only Large Quantity Generators (LQGs)
and Treatment Storage and Disposal Facilities (TSDFs)
CAP Management Category
Demand for Commercial Hazardous Waste Management Capacity
2014 Baseline
2019
2034
2039
Process
Waste
(Tons)
Cleanup
Waste
(Tons)
Process
Waste
(Tons)
Cleanup
Waste
(Tons)
Process
Waste
(Tons)
Cleanup
Waste
(Tons)
Process
Waste
(Tons)
Cleanup
Waste
(Tons)
RECOVERY
Metals Recovery
930,000
700
930,000
700
930,000
700
930,000
700
Solvents Recovery
150,000
100
150,000
100
150,000
100
150,000
100
Inorganics Recovery
430,000
3,800
430,000
3,800
430,000
3,800
430,000
3,800
Energy Recovery
590,000
80
590,000
80
590,000
80
590,000
80
TREATMENT
Fuel Blending
390,000
1,100
390,000
1,100
390,000
1,100
390,000
1,100
Incineration
280,000
90,000
280,000
90,000
280,000
90,000
280,000
90,000
Wastewater Treatment
570,000
41,000
570,000
41,000
570,000
41,000
570,000
41,000
Sludge Treatment/
Stabilization/
Encapsulation
480,000
140,000
480,000
140,000
480,000
140,000
480,000
140,000
DISPOSAL
Landfill
530,000
670,000
530,000
670,000
530,000
670,000
530,000
670,000
Deepwell or Underground
Injection
2,300,000
3,700
2,300,000
3,700
2,300,000
3,700
2,300,000
3,700
16
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Table V
National Baseline and Projected Maximum Commercial Hazardous Waste Management Capacity
CAP Management Category
Baseline,
2014
(Tons/Year)
Maximum Commercial Hazardous Waste Management Capacitya
2019
(Tons/Year)
2034
(Tons/Year)
2039
(Tons/Year)
RECOVERY
Metals Recovery
1,800,000
1,800,000
1,800,000
1,800,000
Solvents Recovery
2,500,000
2,500,000
2,500,000
2,500,000
Inorganics Recovery
526,000
526,000
526,000
526,000
Energy Recovery
1,900,000
1,900,000
1,900,000
1,900,000
TREATMENT
Fuel Blending
4,300,000
4,300,000
4,300,000
4,300,000
Incineration
1,100,000
1,100,000
1,100,000
1,100,000
Wastewater Treatment
12,000,000
12,000,000
12,000,000
12,000,000
Sludge Treatment/
Stabilization/Encapsulation
8,100,000
8,100,000
8,100,000
8,100,000
DISPOSAL
Landfill
89,000,000
(Total permitted tons)
83,000,000
(Total permitted tons)
65,000,000
(Total permitted tons)
59,000,000
(Total permitted tons)
Deepwell or Underground
Injection
3,300,000
3,300,000
3,300,000
3,300,000
3 Estimates do not take into account capacity not currently permitted but potentially available for operation.
17
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Table VI
National Capacity Assessment of Projected Remaining
Commercial Hazardous Waste Management Capacity through 2039
CAP Management Category
Data from Table V:
Projected Remaining
Commercial Hazardous
Waste Capacity Not
Utilized by
LQGs and TSDFs
(Tons/Year)
Estimated Additional Demand for Commercial Capacity
Assessment of the
Continued
Availability of
Commercial
Capacity through
the year 2039
SQG/CESQG and
Transfer/Storage
Facilities
(Tons)
Wastes
Shipped
to Foreign
Countries
(Tons)a
Wastes
Received
from Foreign
Countries
(Tons)
Non-RCRA
Industrial Wastes
(Tons)
RECOVERY
Metals Recovery
869,000
170,000
109,000
35,000
63,000
Sufficient Capacity
Solvents Recovery
2,300,000
19,000
30,000
1,900
71,000
Sufficient Capacity
Inorganics Recovery
92,000
47,000
40,000
4,300
No Estimate
Sufficient Capacity
Energy Recovery
1,200,000
160,000
22,000
1,200
39,000
Sufficient Capacity
TREATMENT
Fuel Blending
3,900,000
79,000
0
1,500
No Estimate
Sufficient Capacity
Incineration
720,000
140,000
14,000
7,100
140,000
Sufficient Capacity
Wastewater T reatment
11,000,000
55,000
41,000
70
280,000
Sufficient Capacity
Sludge Treatment/
Stabilization/Encapsulation
7,400,000
130,000
0
1,100
23,000
Sufficient Capacity
DISPOSAL
Landfill
59,000,000
(Total permitted tons
remaining after depleting
demand from
LQGs and TSDFs)
Annual
400,000
25-Year Total
10,000,000
Annual
34,000
25-Year Total
850,000
Annual
21,000
25-Year Total
525,000
Annual
1,800,000
25-Year Total
45,000,000
Sufficient Capacity
Deepwell or Underground
Injection
990,000
120,000
0
4,400
33,000
Sufficient Capacity
3 U.S. Environmental Protection Agency, ORCR's Export-Import Database, 2010 Annual Export Report data. Data current as of October 18, 2011.
18
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References
ICF; Personal Communication with J. Scott Kirk, Vice President, Licensing and Regulatory Affairs,
Waste Control Specialists LLC; December 2014.
ICF; Personal Communication with Dave Zoghby, Senior Director of Marketing & Commercial
Contracts, EBV Explosives Environmental; November-December 2014.
ICF; Personal Communication with Phillip Retallick, Clean Harbors; November-December 2014.
ICF; Personal Communication with Tom Baker, Director, Environment and Transportation,
Industrial Business, Veolia North America; November-December 2014.
ICF; Personal Communication with D. Lyn Shepherd, Environmental Manager, Alcoa Gum Springs
Plant; November-December 2014.
ICF; Personal Communication with Susan K. Kaiser, Corporate EHS Manager, Ross Incineration
Services, Inc.; November-December 2014.
ICF; Personal Communication with John Avdellas, President, Heritage Thermal Services;
November 2014.
ICF; Personal Communication with Steve Dannenman, Program Manager, Corporate Compliance,
Heritage, Environmental Services, LLC; November 2014.
ICF; Personal Communication with Andrew Marshall, US Ecology; November 2014.
ICF; Personal Communication with Tim Orton, EnergySolutions; October 2014.
National Governors' Association; Hazardous Waste Management in the States: A Review of the
Capacity Assurance Process] 1992.
U.S. Environmental Protection Agency (EPA), Office of Resource Conservation and Recovery
(ORCR); Personal Communication with Sue Briggum, Vice President, Federal Public
Affairs, Waste Management; October-December 2014.
U.S. Environmental Protection Agency (EPA), Office of Resource Conservation and Recovery
(ORCR); RCRAInfo, Permit Module; data current as of September 9-December 5, 2014.
U.S. Environmental Protection Agency (EPA), Office of Resource Conservation and Recovery
(ORCR); RCRAInfo, 2009 Hazardous Waste Report; data current as of September
29,2014.
U.S. Environmental Protection Agency (EPA), Office of Resource Conservation and Recovery
(ORCR); RCRAInfo, 2011 Hazardous Waste Report; data current as of September
20,2014.
U.S. Environmental Protection Agency (EPA), Office of Resource Conservation and Recovery
(ORCR); Export-Import Database, 2010 Annual Export Report data; October 18, 2011.
19
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U.S. Environmental Protection Agency (EPA), Office of Solid Waste and Emergency Response
(OSWER); National Capacity Assessment Report: Capacity Planning Pursuant to CERCLA
Section 104(c)(9), EPA530 R 95-016, November 1996. Available online at
http://www.epa.gov/waste/hazard/tsd/capacitv/index.htm; last accessed on December 30,
2014.
U.S. Environmental Protection Agency (EPA), Office of Solid Waste and Emergency Response
(OSWER); One-time Waste Estimates for Capacity Assurance Planning: Capacity Planning
Pursuant to CERCLA Section 104(c)(9), EPA530-R-94-002; January 1995. Available online
at: http://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=900V0T00.TXT; last accessed on
December 30, 2014.
U.S. Environmental Protection Agency (EPA), Office of Solid Waste and Emergency Response
(OSWER); Guidance for Capacity Assurance Planning, OSWER Directive 9010.02; May
1993. Available online at http://infohouse.p2ric.org/ref/23/22567.pdf; last accessed on
December 30, 2014.
20
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21
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Appendix A
Commercial Capacity Data
22
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23
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Commercial Capacity Data
This appendix provides commercial capacity data used in conducting the national capacity
assessment. In particular, this appendix provides the following information:
• Summary of commercial capacity data
- Landfills
- Incineration
- Energy recovery
- All other CAP management categories
• Information verified/obtained through consultations with commercial hazardous waste
management facilities
- List of commercial hazardous waste management facilities contacted
- Feedback provided by commercial hazardous waste management facilities
o Landfills
o Incineration
o Specialty operations
Click on any of the above links for quick access to specific sections of the appendix.
24
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25
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Summary of Information on
Commercial Capacity Data
26
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27
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Summary of Capacity Data for Commercial Hazardous Waste Landfill Facilities a
EPA ID
Site Name
Total Annual Landfilled Quantity of
Hazardous Waste and Other Wastes
Total
Currently
Permitted and
Available
Landfill
Capacityb
(Tons)
Anticipated
Expansion
under Permit
Modification/
Renewal
(Tons)
Year of Permit
Modification/
Renewal
Subtitle C
(Tons)
Non-Subtitle C
(Tons)
Mixed Waste
(Tons)
Total
(Tons)
ALD000622464
CHEMICAL WASTE
MANAGEMENT
52,630 (60%)c
35,086 (40%)c
0
87,716d
3,851,218
21,000,000
2015
CAD980675276
CLEAN HARBORS
BUTTONWILLOW, LLC
260,950
89,050
0
350,000
9,362,500
875,000
In progress
CAT000646117
CHEMICAL WASTE
MANAGEMENT, INC.
4,031 (60%)c
2,687 (40%)c
0
6,718
6,874,216
Not available
2014
CO D991300484
CLEAN HARBORS DEER TRAIL
LLC
29,700
14,680
0
44,380
2,535,203
0
2018
IDD073114654
US ECOLOGY IDAHO INC SITE B
113,647 (16%)e
596,647 (84%)e
0
710,295
13,936,000
0
2014
IND980503890
HERITAGE ENVIRONMENTAL
SERVICES, LLC
77,142 (26%)f
219,558 (74%)f
0
296,700
20,664,782
0
2019
LAD000777201
CHEMICAL WASTE
MANAGEMENT
120,060 (60%)c
80,040 (40%)c
0
200,100
5,036,956
0
2020g
MID048090633
WAYNE DISPOSAL INC
61,401 (39%)e
96,038 (61%)e
0
157,439
15,200,000
0
2022
NVT330010000
US ECOLOGY NEVADA
60,877 (83%)e
12,469 (17%)e
0
73,346
628,000
5,000,000
2016
NYD049836679
CWM CHEMICAL SERVICES LLC
56,363 (60%)c
37,575 (40%)c
0
93,938h
140,000
6,000,000
In progress
OHD045243706
ENVIROSAFE SERVICES OF
OHIO INC
48,830'
52,899J
0
101,729J
0k
Not Available
2015g
OKD065438376
CLEAN HARBORS LONE
MOUNTAIN LLC
88,472
82,861
0
171,333
2,712,840
3,361,800
In progress
ORD089452353
CHEMICAL WASTE
MANAGEMENT OF THE NW
103,304 (60%)c
68,869 (40%)c
0
172,173
5,612,432
Not Available
2016g
28
-------
Summary of Capacity Data for Commercial Hazardous Waste Landfill Facilities a
EPA ID
Site Name
Total Annual Landfilled Quantity of
Hazardous Waste and Other Wastes
Total
Currently
Permitted and
Available
Landfill
Capacityb
(Tons)
Anticipated
Expansion
under Permit
Modification/
Renewal
(Tons)
Year of Permit
Modification/
Renewal
Subtitle C
(Tons)
Non-Subtitle C
(Tons)
Mixed Waste
(Tons)
Total
(Tons)
TXD069452340
US ECOLOGY TEXAS
87,815 (18%)e
400,045 (82%)e
0
487,859
1,800,000
10,400,000
(modification)
2023
UTD991301748
CLEAN HARBORS GRASSY
MOUNTAIN, LLC.
82,311
34,827
0
117,138
717,151
None
anticipated in
next renewal
2022
Total
1,247,533
1,823,331
0
3,070,864
89,071,298
46,636,800
a Unless otherwise noted, information was obtained through consultations conducted in October-December 2014. Table contains rounding error.
b This column reflects all remaining permitted capacity in landfills currently in operation, under construction, and not yet built.
c Chemical Waste Management estimated the total tonnage of wastes received at each of its facilities and stated that the quantity of non-Subtitle C waste is on average 40% of the total waste
received at the facilities. This table reflects a 60%/40% split between Subtitle C and non-Subtitle C waste for each facility.
d This facility, in Emelle, Alabama, has a state-imposed cap on annual receipts of 600,000 tons.
6 US Ecology provided a percentage breakdown in wastes and materials that it landfilled in 2014 (% hazardous waste, % non-hazardous waste, etc.). This was used in conjunction with its total
quantity of hazardous waste landfilled (as reported in the 2011 Hazardous Waste Report) to approximate the total annual quantity of Subtitle C and non-Subtitle C waste, as presented in this
table. Note that the Wayne facility in Michigan is owned by US Ecology.
f Heritage provided a total annual tonnage of all wastes and materials landfilled and estimated that Subtitle C wastes comprise 26% and non-Subtitle C wastes comprise 74%.
5 Data from "Maximum Operational Commercial Subtitle C Landfill Capacity" document
h This facility, in Model City, New York, has a state-imposed cap on annual receipts of 425,000 tons. Certain remediation and de-characterized wastes are exempted from the state cap.
' Based on GM Onsite and WR Form data from the 2011 Hazardous Waste Report. Data current as of September 20, 2014.
1 Estimated quantity. Based on average of the percentages provided by all facilities consulted for Subtitle C and Non-Subtitle C wastes landfilled (i.e., 48% Subtitle C wastes and 52% Non-Subtitle C
wastes).
k Assumed to be zero. Available data in RCRAInfo's Permit Module is 10 years old. Facility did not provide current capacity data, and their permit gets renewed in 2015.
29
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Summary of Capacity Data for Commercial Hazardous Waste Incineration Facilities a
EPA ID
Site Name
Total Annual Incinerated Quantity of
Hazardous Waste and Other Wastes
Total Currently
Permitted and
Available
Capacityb
(Tons/Year)
Anticipated
Expansion under
Permit Modification/
Renewal
(Tons/Year)
Year of Permit
Modification/
Renewal
Subtitle C
(Tons)
Non Subtitle C
(Tons)
Total
(Tons)
ARD069748192
CLEAN HARBORS EL
DORADO, LLC
74,368
23,798
98,166
245,325°
75,000 (recent)/
No expansion
anticipated in 2018d
2018
ILD098642424
VEOLIA ES TECHNICAL
SOLUTIONS LLC
15,625 (62.5%f
9,375 (37.5%)e
25,000
30,000
0
In progress
NED981723513
CLEAN HARBORS ENV
SERVICES
34,823f
Not Available
34,823
72,000s
Not Available
Not Available
OHD048415665
ROSS INCINERATION
SERVICES INC
76,406
4,844
81,250
84,112
0
2024
OHD980613541
HERITAGE- WTI, INC
61,425 (97.5%)h
1,575 (2.5%)h
63,000
70,000'
0
In progress
TXD000838896
VEOLIA ES TECHNICAL
SOLUTIONS LLC
56,950 (85%)J
10,050 (15%)J'
67,000
87,500k
0
2014
TXD055141378
CLEAN HARBORS DEER
PARK LP
88,972
85,482
174,454
293,138'
0
2014
UTD981552177
CLEAN HARBORS
ARAGONITE LLC
60,459f
Not Available
60,459
120,000g
Not Available
Not Available
Total
589,028
135,124
724,152
1,123,575
75,000
3 Unless otherwise rioted, information was obtained through consultations conducted in October-December 2014. Table contains rounding error.
b This column reflects practical operating capacity (i.e., capacity at operational units accounting for planned outages, maintenance, etc.) unless otherwise indicated.
c This capacity is based on 8,040 operating hours/unit/year. Clean Harbors indicated this reflects actual experience with all of its incinerators.
dThe Arkansas DEQ recently issued RCRA Part B and CAA Title V permits to construct and operate a new rotary kiln incinerator with a permitted capacity of approximately 75,000 tons per year. This 75,000-ton
increase is not reflected in its total currently permitted and available capacity because it is not yet built. No change in capacity is anticipated in its 2018 renewal.
8 Veolia indicated that non-Subtitle C receipts vary but could represent 25% - 50 % of the total waste incinerated. A mid-point of 37.5% is reflected in the table for non-Subtitle C waste and 62.5% for Subtitle C waste
f Based on GM Onsite and WR Form data from the 2011 Hazardous Waste Report. Data current as of September 20, 2014.
8 Based on permitted capacity information in RCRAInfo, which is expressed in tons or pounds per hour. Multiplied this by 8,040 hours/year as recommended by Clean Harbors.
h Heritage indicated that non-Subtitle C waste represents less than five percent of its annual incineration volume. A mid-point between 0% and 5% is reflected in the table for non-Subtitle C waste (2.5%) and 97.5%
for Subtitle C waste.
1 Heritage is permitted for 2 incinerators and its RCRA permitted capacity is greater than 88,000 tons/year per incinerator (176,000 tons per year). One incinerator is built and operating, with a practical capacity of
70,000 tons/year. The other is not built and hence not reflected in the table.
' Veolia indicated that non-Subtitle C receipts vary but could represent 10% - 20 % of the total waste incinerated. A mid-point of 15% is reflected in the table for non-Subtitle C waste and 85% for Subtitle C waste
k Veolia indicated that its practical capacity is approximately 75,000 -100,000 tons/year. A midpoint of 87,500 tons/year is reflected in the table.
1 Clean Harbors estimated a total incineration capacity of 36.46 tons/hour and 8,040 hours/year of operation. This equates to 293,138 tons/year of capacity.
30
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Summary of Capacity Data for Commercial Hazardous Waste Energy Recovery Facilities a
EPA ID
Site Name
Process Type
Total Currently
Permitted and
Available Capacity
(Tons/Year)
Anticipated Expansion
under Permit
Modification/ Renewal
(Tons/Year)
Year of Permit
Modification/
Renewal
ARD981512270
ASH GROVE CEMENT COMPANY
Cement Kiln
211,291b
Not Available
Not Available
IND005081542
ESSROC CEMENT CORPORATION
Cement Kiln
318,384 b
Not Available
Not Available
IND006419212
LONE STAR GREENCASTLE WDF
Cement Kiln
100,500 b
Not Available
Not Available
KSD031203318
ASH GROVE CEMENT COMPANY
Cement Kiln
162,569
Not Available
Not Available
LAD008161234
ECO SERVICES OPERATIONS LLC
Combustion Device in
Recovery of Sulfur
from Acid
24 b-c
Not Available
Not Available
MOD054018288
GREEN AMERICA RECYCLING, LLC
Cement Kiln
98,168 b
Not Available
Not Available
MOD981127319
LONE STAR INDUSTRIES
Cement Kiln
86,941b
Not Available
Not Available
MSD077655876
HOLCIM (US) INC/GEOCYCLE LLC
Cement Kiln
131,454 b
Not Available
Not Available
NYD080469935
NORLITE LLC
Aggregate Kiln
20,732 b
Not Available
Not Available
OKD064558703
TULSA CEMENT LLC D/B/A CENTRAL PLAINS COM
Cement Kiln
103,153 b
Not Available
Not Available
PAD002389559
KEYSTONE CEMENT CO
Cement Kiln
80,513 d
Not Available
Not Available
SCD003351699
GIANT CEMENT COMPANY
Cement Kiln
233,160 b
Not Available
Not Available
SCD003368891
HOLCIM US INC GEOCYCLE LLC
Cement Kiln
293,125 d
Not Available
Not Available
TND982109142
DIVERSIFIED SCIENTIFIC SERVICES INC. (DSSI)
Boiler
5,133 b
Not Available
Not Available
TXD001700806
ASCEND CHOCOLATE BAYOU PLANT
Boiler
6 b'c
Not Available
Not Available
TXD008099079
RHODIA
Halogen Acid Furnace
95,848 b c
Not Available
Not Available
Total
1,941,001
Not Available
a Unless otherwise noted, information was obtained from RCRAInfo's Permit Module in December 2014.
b This capacity is based on 8,040 operating hours/unit/year.
c This capacity is based on a heat content of hazardous waste of 8,598 BTU/pound.
d This capacity is based on 335 operating days/unit/year.
31
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Summary of Commercial Capacity Data for All Other CAP Management Categories
CAP Management Category
Maximum Operational
Commercial Hazardous
Waste Management
Capacity
(Tons/Year)a
Estimated Additional
Demand for
Commercial Capacity
from Non-RCRA
Industrial Wastes
(Tons)d
RECOVERY
Metals Recovery
1,800,000
5%
Solvents Recovery
2,500,000
35%
Inorganic Recovery
526,000 b
No Estimate
TREATMENT
Fuel Blending
4,300,000
No Estimate
Wastewater Treatment
12,000,000 c
39%
Sludge Treatment/ Stabilization/Encapsulation
8,100,000
3%
DISPOSAL
Deepwell or Underground Injection
3,300,000
26%
3 Unless otherwise noted, capacity estimate obtained from EPA's National Capacity Assessment Report: Capacity Planning
Pursuant to CERCLA Section- 104(c)(9) (i.e., the 1996 capacity assessment report), EPA530-R-95-016, p. 21,
November 1996. This is the most recent estimate of national capacity for this CAP management category.
b Capacity estimate based on demand in 2011 for management of wastes using inorganics recovery technologies.
c Capacity estimate obtained from the 1996 capacity assessment report was decreased by 28,000,000 tons to account for
the reduction in wastewater treatment capacity associated with the decision of DuPont Chamber Works to stop accepting
wastewaters from outside companies.
d Percent of total demand (i.e., [process waste] + [cleanup waste] + [SQG/CESQand transfer/storage facilities]+ [wastes
shipped to foreign countries] + [wastes received from foreign countries]). These assumptions were obtained from the
1996 capacity assessment report (p. 22).
32
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33
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Information Verified/Obtained through Consultations
with Commercial Hazardous Waste Management Facilities
34
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[Page intentionally left blank.]
35
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EPA ID
Facility Name
Date Facility Was
First Contacted
Date of Latest
Response from
Facility
ALD000622464
CHEMICAL WASTE MANAGEMENT
October 9, 2014
December 4, 2014
CAT000646117
CHEMICAL WASTE MANAGEMENT, INC.
LAD000777201
CHEMICAL WASTE MANAGEMENT
NYD049836679
CWM CHEMICAL SERVICES LLC
ORD089452353
CHEMICAL WASTE MANAGEMENT OF THE NW
CAD980675276
CLEAN HARBORS BUTTONWILLOW, LLC
November 4, 2014
December 4, 2014
COD991300484
CLEAN HARBORS DEER TRAIL LLC
OKD065438376
CLEAN HARBORS LONE MOUNTAIN LLC
UTD991301748
CLEAN HARBORS GRASSY MOUNTAIN, LLC.
IDD073114654
US ECOLOGY IDAHO INC SITE B
October 29, 2014
November 5, 2014
MID048090633
WAYNE DISPOSAL INC
NVT330010000
US ECOLOGY NEVADA
TXD069452340
US ECOLOGY TEXAS
IND980503890
HERITAGE ENVIRONMENTAL SERVICES, LLC
October 24, 2014
November 17,2014
OHD045243706
ENVIROSAFE SERVICES OF OHIO INC
November 4, 2014
No Response
ARD069748192
CLEAN HARBORS EL DORADO, LLC
November 13, 2014
December 4, 2014
NED981723513
CLEAN HARBORS ENV SERVICES
November 13, 2014
No Response
TXD055141378
CLEAN HARBORS DEER PARK LP
November 13, 2014
December 4, 2014
UTD981552177
CLEAN HARBORS ARAGONITE LLC
November 13, 2014
No Response
ILD098642424
VEOLIA ES TECHNICAL SOLUTIONS LLC
November 11, 2014
December 3, 2014
TXD000838896
VEOLIA ES TECHNICAL SOLUTIONS LLC
OHD048415665
ROSS INCINERATION SERVICES INC
November 14, 2014
December 2, 2014
OHD980613541
HERITAGE -WTI, INC
November 13, 2014
November 18, 2014
TXD988088464
WASTE CONTROL SPECIALISTS
October 24, 2014
December 5, 2014
UTD982598898
ENERGYSOLUTIONS
October 24, 2014
October 28,2014
ARD006354161
REYNOLDS METALS COMPANY
November 25, 2014
December 3, 2014
. MOD985798164
EBV EXPLOSIVES ENVIRONMENTAL CO
November 18, 2014
December 2, 2014
36
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Commercial Hazardous Waste Landfill Facilities
37
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[Page intentionally left blank.]
38
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Chemical Waste Management
Information on WM Subtitle C Facility Capacity
Public Submission
Information requested by EPA in 2014 for 2013-2014
WM SUBTITLE C CAPACITY 2013-2014
LANDFILL
Annual
Annual
State Cap on Annual
Remaining Permitted
Receipts
Receipts 2014
Receipts (tons)
Capacity
2013 (tons)
(projected
tons)
(Site Life as of Dec.
2013)(tons)
Arlington
172,173
110,000
No Cap
5,612,432
Emelle
87,716
112,550
600,000
2,750,870**
Lake Charles
200,100
203,800
No Cap
5,036,956
Model City
93,938
80,000
425,000*
140,000
Kettleman
6,718
13,761
No Cap
14,216
Total
560,645
520,111
1,025,000
13,554,474
*Certain remediation & decharacterized wastes are exempted from the state regulatory Cap for Model
City
**Working to permit Trench 23 in 2015 for 15MM Cu Yds.
Note that this is total tonnage through the gate. Those who report differently (for example, for soil,
they adjust the tonnage reported to the state by a fraction that represents only on hazardous waste and
not the dirt included in a shipment), the number has converted to simple tons of material received.
Additional information
• Please give a generic description of the kinds of customers using the facilities - manufacturers,
federal government (Superfund or use by federal agencies), academic institutions, etc.
Manufacturers, state DECs, EPA, academic institutions, developers, brokers, manufacturers
throughout the region, some County and City residential (household and SQG), various government
entities, and voluntary cleanup efforts, CERCLA cleanups, Petroleum and Chemical companies,
Infrastructure Developments including Caltrans (roads), brownfield developments (public and
private)
• Please identify generally the kinds of non-Subtitle C special or event waste received (e.g.,
brownfields cleanup, Superfund waste not specifically RCRA Subtitle C, tank cleanup,
industrial non-hazardous waste, pharmaceutical waste - anything, not just RCRA listed or
characteristic haz waste).
Answers vary by facility but include: Brownfield cleanups, tank clean up, some manufacturing
industrial waste, minute amounts of pharmaceutical waste, friable asbestos, PCB (TSCA) waste,
California-only hazardous waste.
39
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• How much of total tonnage received is special/event waste (as opposed to on-going contracts
for newly generated waste) - an approximate % is fine.
Ranges from 20% to 80%
• If the facility can track receipt of hazardous waste from small quantity generators or
conditionally exempt waste, please identify the percentage of wastes this constitutes (an
approximation is OK).
Between 1% and 5%
• How is daily cover handled in your "remaining capacity" number? Would EPA have to subtract
a percent from this estimate to account for daily cover when evaluating the remaining life
estimate?
No, EPA does not have to subtract anything to account for daily cover.
• Please indicate the duration of your permit (renewal every 5 or 10 years?).
Split between 5 and 10 year permit duration.
• Are you permitted to accept dioxin or mercury wastes? If so, does it require a special permit?
Are there any other RCRA haz wastes your facility isn't able to accept under your permit?
Dioxin waste must have been treated to LDF. Facilities cannot accept Radioactive Wastes,
Compressed Gases, Forbidden Explosives, or Biological/Infectious Wastes.
• Has your facility attempted to delist a customer's waste stream in the past 5 years? Do not
include any delistings filed by a customer attempting to avoid having to send waste to us by
petitioning for delisting.
No facility has attempted to delist a waste. One facility has a variance for one waste stream.
• Does your state have any legislation/regulation that allows potential customers to avoid using
our facility and instead diverts waste to less regulated units like recycling facilities or quarry
fill?
The State of California has allowed Cal Trans to use California-hazardous waste (areal lead-
impacted soil) to be used as backfill under roads.
40
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Additional questions for some sites:
• For Kettleman and Model City, please identify the annual and total capacity you could handle
if your pending expansion permits are granted, but don't assume you will get your expansion
permit in filling out the chart.
Model City:
Annual capacity with expansion will be 500,000 tons with no exemptions. The expansion
provides for 4,000,000 cy of airspace (6,000,000 tons).
KHF:
Capacity - B18 Phases l/ll
• Remaining capacity as of 12/31/14 is 17,770 cubic yards (AUF 0.80) or 14,216 tons
• Permitted for RCRA, TSCA, Non-RCRA (Cal Haz), and CERCLA
Capacity - B18 Phase III
• Capacity is 4,900,000 cubic yards (AUF 1.4) or 6,860,000 tons
• Permitted for RCRA, Non-RCRA (Cal Haz), and CERCLA
• We have applied for TSCA and should receive approval after the Part B Permit renewal, most
likely in 2016
• Please explain the status of WM Mercury Wastes Solution - what we do, how much product
we can sell, where the unsold product is stored.
WM Mercury Waste Solutions (WMMWS), located in Union Grove, Wl, recovers mercury from
various hazardous and non-hazardous waste streams using two types of retort operations - 1)
stationary retort batch process, which has 1100 55-gallon drum/month capacity; and 2)
continuous flow retort, designed for flowable materials with a 1300 55-gallon drum per month
capacity.
The RCRA landfill disposal restrictions (LDR) require retort of mercury-contaminated wastes with TCLP >
0.2 ppm and total mercury > 260 ppm prior to disposal. WMMWS recovers mercury, purifies it to at
least 99.5% and sells the elemental mercury (~ 4-10 metric tons/year) to domestic users. WMMWS
places mercury that cannot be sold domestically in long-term storage.
WMMWS also receives mercury and mercury wastes from third parties for purification and long-term
storage. Most of the storage capacity is located at WM Emelle and housed in a RCRA Part B storage
facility. WMMWS is offering this service because mercury can no longer be exported, but must be
stored indefinitely until DOE builds a national mercury storage facility. Development of the national
facility has been delayed indefinitely due to lack of Congressional funding.
41
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Based upon volume projections we have received from our third party customers, between our Emelle
and WMMWS facilities, we have the capacity to store mercury until October of 2020. Currently we have
122 tons of third party mercury and 16 tons of WM produced mercury stored at our Emelle and
WMMWS facilities.
WMMWS operates under the Boiler Industrial Furnace Exemption for Mercury Recovery Furnaces 40
CFR Part 266(d)(1). The facility has a RCRA Part B permit, but can only accept hazardous waste with
recoverable levels of mercury, total organics of < 500 ppm and a BTU value < 5,000 per pound.
Supplemental Questions to WM
1) Does "site life" mean operating capacity remaining in the current permits (which can be a
timeframe of 5 years or 10 years)? If so could you also provide estimates for the amount of
total capacity (undeveloped land/not constructed with liners and leachate collection) available if
all future cells would receive approval for permit renewals/expansions from the states (i.e.,
capacity available until landfill closes and ceases further operations).
Lake Charles' capacity is for the total remaining permitted tons.
Model City had 140,000 tons of capacity in RMU-1 as of 1/1/14. RMU-2 would add an additional
6 million tons of capacity.
Arlington: "Site Life" is the capacity of the landfills currently listed in the permit today at
today's waste acceptance rates. The permit is renewed every 10 years.
Emelle: Site life for Emelle is viewed as how much available air space is remaining for landfill
development. The answer is 2,050 acres or at current landfill disposal volumes 100 years plus of
landfill operating life. We currently have 2,750,870 CY of airspace permitted under a 5-year
permit expiring in 2015. We will renew our permit in 2015 for this remaining airspace in trench
22 and add additional airspace for trench 23, adding 15 million CY's of airspace with the 2015
Part B permit renewal.
Kettleman Hills:
Landfill B18 Phase III (8 years of capacity per the SEIR)
• Provides 4.9 million cubic yards of capacity
• Presently permitted for RCRA and Non-RCRA Hazardous Waste
• KHF has applied for TSCA authorization (US EPA-IX to process permit request after DTSC
Part B Renewal is processed)
Landfill B20 (24 years of capacity per the SEIR)
• Provides 14.2 million cubic yards of capacity
• Local CUP and CEQA process is complete
• Permitting process has not been started
KHF has a total of 1,600 acres
• The current CUP (including B18 III and B20) make up 729 acres
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2) Why do the densities vary from 0.8 to 1.4 at the Kettleman facility. We are still trying to
determine an "average" density to convert cubic yards to tons of waste and I was wondering if
we should take an average or is one more common for production wastes and another for
cleanup wastes?
o Waste types disposed in the landfill can vary greatly, thus varying the AUF (density),
o Historically, KHF volumes were made up of 70% event waste, which were predominantly
contaminated soils and 30% base business waste, which were a variety of waste types
including very light debris waste to very heavy stabilized waste,
o Based on annual flyover data, KHF's AUF is calculated to be approximately 1.4
3) Which Agency is working on the mercury storage and disposal issue with your company? I think
you mentioned DOE is responsible for helping to secure a permanent "storage" facility. Is this
because they generate most of the waste or most comes from light bulbs? Has EPA granted a
LDR treatment variance? How much waste or elemental mercury do you currently have onsite
in storage at the Wisconsin facility?
• We currently have 20 Metric Ton containers and 70 flasks for MEBA storage. The mercury will be
cleaned and repackaged and eventually shipped to Emelle
• We have approximately 8 tons of mercury for sale on site. That mercury is cleaned and resold
domestically as a product.
• We are working with the DOE for long-term storage from a federal prospective. In addition, both
WM Mercury Waste and Emelle are working directly with prospective state agencies.
• By law the DOE is required to construct the "permanent storage facility." This is addressed in
the 2013 Mercury Export Ban Act. In the law, there is a provision that a private RCRA facility can
store mercury long-term until the DOE facility is constructed as long as they notify the DOE. Both
WM Mercury Waste and Emelle have received permission from the state agencies to store
mercury long term.
4) Do you ever receive infectious waste medical for disposal?
No. No site is permitted to receive waste that is infectious.
5) Finally, Larry Zaragoza has some questions about Dioxin wastes that can be accepted by your
facilities. Can you accept all dioxin wastes or have there been issues with incinerating them to
meet the LDR levels before disposal? (I have CC Larry on this email so he can ask more specifics
about this category of wastes).
There is only one facility in North American that can accept dioxin waste that needs treatment
(F020-F028) - the Swan Hills facility in Alberta, Canada (not ours). If the dioxin waste is
hazardous, it must meet LDRs before receipt at a WM facility. Our facilities generally receive
little post-treatment dioxin waste; the most common is non-hazardous soil with no free liquid
but with dioxins and furans and WWT sludge with low-level dioxins - all meeting LDR standards.
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Questions on Landfill Capacity for Clean Harbors Buttonwillow, LLC
(EPA ID CAD980675276)
Instructions: Please provide responses to the questions below. The first set of questions asks
about the annual quantity of wastes and materials that you landfill. The second set asks about
your current and future landfill capacity. Provide responses in the blank space below each
question or on a separate sheet of paper. For your assistance, attached is some RCRAInfo
permit module data on your landfills.
Annual Quantity of Landfilled Wastes and Materials
1. Total Annual Landfilled Quantity: What is the total quantity of all wastes and
materials disposed of in your facility's landfill(s) in a typical calendar year? This should
include everything placed in the landfills, i.e., federal and state-only hazardous waste,
non-hazardous waste, and miscellaneous materials (e.g., stabilization materials, dirt,
etc.). These wastes and materials are further addressed in Questions 2 through 4.
~300,000 ton/year.
2. Based on the 2011 Hazardous Waste Report, your facility landfilled 348,971 tons of
hazardous waste (i.e., 348,949 tons reported on Form WR and 22 tons on Form GM).
This is our best estimate of the total quantity of federally regulated hazardous wastes
landfilled. If you also landfilled state-only hazardous wastes, what percent of your total
annual landfilled quantity (as provided in Question 1) do they represent approximately
(e.g., 5%, 10%, negligible)?
~60%
3. Besides hazardous waste, 1) what types of non-hazardous wastes does your facility
dispose of in your landfill and 2) what percent of your total annual landfilled quantity (as
provided in Question 1) do they represent approximately? This could include, for
example, TSCA waste, municipal waste, and other non-hazardous waste.
All types of nonhazardous industrial waste. ~25%
No TSCA or municipal waste
4. Besides the wastes described above, 1) what materials do you place in the landfill that
use up capacity (e.g., stabilization materials, dirt, etc.) and 2) what percentage of total
annual landfilled quantity (as provided in Question 1) do they represent approximately?
5. For purposes of analysis, we assume that your total annual landfilled quantity in
Question 1 consists entirely of the hazardous wastes described in Question 2, the non-
hazardous wastes in Question 3, and the materials in Question 4. Please ensure that
your estimates in Questions 2 thru 4 approximate (mathematically) the total annual
landfilled quantity in Question 1. If they do not, please clarify why not.
44
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6. Do you expect your total annual landfilled quantity (as provided in Question 1) to
remain steady, grow or decline over the next 20 years? If it will grow or decline, at what
annual rate?
Remain the same.
7. Is the facility permitted to accept dioxin and elemental mercury wastes?
Dioxin no, mercury yes.
8. Are there any wastes that the facility cannot accept? If so, please describe.
Permit prohibit the following:
1. Radioactive materials greater than 1800 piC/gram;
2. Infectious or bio-hazardous materials
3. DOT Class 1 explosives;
4. Municipal garbage or refuse;
5. PCBs greater than 50 ppm;
6. Dioxin waste codes F020, F021, F022, F023, F026, and F027.
7. Bulk or containerized hydrazine (U133);
8. Compressed gas cylinders greater than 1 liter.
Landfill Capacity
9. What is the currently permitted and available landfill capacity at the facility in tons (if
not provided in tons, please provide the unit of measure and conversion factor for
tons)? This includes all remaining permitted capacity in landfills currently in operation,
under construction, not yet built, etc.
Permitted capacity is 13,325,000 cubic yards. Volume consumed = ~5,835,000 cubic
yards. Volume remaining =~7,490,000 cubic yards.
Conversion rate is ~1.25 tons/cubic yard.
10. Do you plan on using all of this capacity in the future?
Yes
11. What conversion factor do you use to convert waste volume (e.g., acre-foot) to tons,
e.g., for purposes of estimating landfill capacity?
2017 tons/acre.
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12. What is the available capacity in the currently lined and operating cells that have a
permit in tons?
Permit is in yards and it has ~700,000 cubic yards remaining.
13. What is the remaining life of the currently lined and operating cells that have a permit?
1.5 years
14. When does the facility's RCRA permit need to be renewed? Does the facility plan to
continue landfill operations over the next 20 years?
Permit renewal application was submitted in 2005. DTSC is working on renewing it. No
estimated time for completion. Yes
15. How much additional capacity would be available under the next permit renewal? [This
should be additive to the amount in Question 9.]
Assuming the permit was renewed in 2014, it would be ~700,000 cubic yards. However,
it is estimated that it will take DTSC 4 addition years before a renewed permit is issued.
16. Are there any plans to expand the landfill capacity at the facility beyond the amounts in
the current permit and next renewal? If so, what is the timeframe and how much? [This
should be additive to the amounts in Questions 9 and 15.]
Not yet.
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ATTACHMENT: RCRAINFO PERMIT MODULE DATA FOR
CLEAN HARBORS BUTTONWILLOW, LLC LANDFILLS
RCRAInfo Permit Module on Landfill Capacity - September 16, 2014
Unit Name
Capacity
Capacity
UOM*
Capacity
Type
WMU28
210.7
Ac-F
Design
WMU33
1,147
Ac-F
Design
WMU34
213.8
Ac-F
Design
WMU35
6,632
Ac-F
Permitted
TOTAL
8,203.5
Ac-F
*Ac-F = acre-foot.
WMU 28, 33 and WMU 35, Cells and 2 have been closed. WML) 34 is almost full. WML) 35, Cells 3 and 4
are operational. WML) 35, Cells 5 through 9 are constructed but have not been constructed.
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FOLLOW UP QUESTIONS ON YOUR SUBMISSION ON LANDFILL CAPACITY
Buttonwillow (EPA ID CAD980675276)
Landfilled Quantity
The table below summarizes the data received from the facility in response to Questions 1 through 4 of
the questionnaire (see Row 1). Column A presents your response to Question 1, Columns B and C to
Question 2, Column D to Question 3, and Column E to Question 4. As requested in the questionnaire,
the sum of Columns B, C, D and E should equal Column A. However, this is not the case for your
responses, as shown in the table. If Columns B through E are added up, we get 603,971 tons as the total
quantity of landfilled waste and materials, not 300,000 tons. Please reconcile your estimates in
Columns A through E so that the sum of Columns B through E equals A. (We assume you need not
revise Column B because it is based on the 2011 Biennial Report; however, if it is not representative of
your average annual quantity of federally regulated waste landfilled, please modify). Present your
revised estimates in Row 2.
A
B
C
D
E
Total Quantity
of Landfilled
Waste and
Materials
(Question 1)
Federally
Regulated
Hazardous
Waste
(Question 2)
State-Only
Hazardous
Waste
(Question 2)
All Non-
Hazardous
Waste
(Question 3)
All Materials
(e.g.,
stabilization
materials)
(Question 4)
1. Your
original
responses
Approx
300,000 tons
348,971 tons
(based on 2011
Biennial
Report)
60% of Column
A: 180,000 tons
25% of Column
A: 75,000 tons
0 tons
2. Your
revised
responses
350,000 tons
35,500 tons
225,450
80,500
8,550 tons
Note that the DTSC Biennial Report requires that the landfill facility combine Federal RCRA and Cal
State Hazardous Waste into one reporting number. I have separated out the Federal Hazardous Waste
from the total number reported to the DTSC for the 2011 reporting year. PGR 11/25/2014
Remaining Permitted Landfill Capacity
We also would like to confirm your remaining permitted landfill capacity:
• Your response to Question 9 indicates that your landfills have a permitted remaining capacity of
~7,490,000 cubic yards, or 9,362,500 tons. Your response to Question 15 indicates that, if
granted a permit renewal, you expect an additional 700,000 cubic yards, or 875,000 tons, of
capacity. In total, this reflects 10,237,500 tons of total capacity (i.e., the 875K tons under the
renewal is additive to the 9.6M tons currently under the permit). Is this correct? Yes, that is
correct. PGR 11/25/2014
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Questions on Landfill Capacity for Clean Harbors Deer Trail, LLC
(EPA ID COD991300484)
Instructions: Please provide responses to the questions below. The first set of questions asks
about the annual quantity of wastes and materials that you landfill. The second set asks about
your current and future landfill capacity. Provide responses in the blank space below each
question or on a separate sheet of paper. For your assistance, attached is some RCRAInfo
permit module data on your landfills.
Annual Quantity of Landfilled Wastes and Materials
1. Total Annual Landfilled Quantity: What is the total quantity of all wastes and
materials disposed of in your facility's landfill(s) in a typical calendar year? This should
include everything placed in the landfills, i.e., federal and state-only hazardous waste,
non-hazardous waste, and miscellaneous materials (e.g., stabilization materials, dirt,
etc.). These wastes and materials are further addressed in Questions 2 through 4.
44,380 tons
2. Based on the 2011 Hazardous Waste Report, your facility landfilled 29,700 tons of
hazardous waste. This is our best estimate of the total quantity of federally regulated
hazardous wastes landfilled. If you also landfilled state-only hazardous wastes, what
percent of your total annual landfilled quantity (as provided in Question 1) do they
represent approximately (e.g., 5%, 10%, negligible)?
negligible
3. Besides hazardous waste, 1) what types of non-hazardous wastes does your facility
dispose of in your landfill and 2) what percent of your total annual landfilled quantity (as
provided in Question 1) do they represent approximately? This could include, for
example, TSCA waste, municipal waste, and other non-hazardous waste.
All types of nonhazardous industrial waste. 27%
4. Besides the wastes described above, 1) what materials do you place in the landfill that
use up capacity (e.g., stabilization materials, dirt, etc.) and 2) what percentage of total
annual landfilled quantity (as provided in Question 1) do they represent approximately?
Stabilization reagents. 20%
49
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5. For purposes of analysis, we assume that your total annual landfilled quantity in
Question 1 consists entirely of the hazardous wastes described in Question 2, the non-
hazardous wastes in Question 3, and the materials in Question 4. Please ensure that
your estimates in Questions 2 thru 4 approximate (mathematically) the total annual
landfilled quantity in Question 1. If they do not, please clarify why not.
6. Do you expect your total annual landfilled quantity (as provided in Question 1) to
remain steady, grow or decline over the next 20 years? If it will grow or decline, at what
annual rate?
Remain the same.
7. Is the facility permitted to accept dioxin and elemental mercury wastes?
Only Dioxins that meet the LDR treatment standards.
No to elemental mercury.
8. Are there any wastes that the facility cannot accept? If so, please describe.
Compressed gases
Air reactive Materials
Shock Sensitive Materials
Infectious Wastes
DOT Forbidden Explosives
Landfill Capacity
9. What is the currently permitted and available landfill capacity at the facility in tons (if
not provided in tons, please provide the unit of measure and conversion factor for
tons)? This includes all remaining permitted capacity in landfills currently in operation,
under construction, not yet built, etc.
1,864,120 cu yds (conv factor = 1.36 cy/ton)
10. Do you plan on using all of this capacity in the future?
Yes.
11. What conversion factor do you use to convert waste volume (e.g., cubic yards) to tons,
e.g., for purposes of estimating landfill capacity?
1.36 cy/ton
50
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12. What is the available capacity in the currently lined and operating cells that have a
permit in tons?
45,000 cy yd (61,200 tons)
13. What is the remaining life of the currently lined and operating cells that have a permit?
1+ years for the current operating cell. 5-6 years for the cell that is currently under
construction.
14. When does the facility's RCRA permit need to be renewed? Does the facility plan to
continue landfill operations over the next 20 years?
April 15, 2018
Yes.
15. How much additional capacity would be available under the next permit renewal? [This
should be additive to the amount in Question 9.]
The facility will not need to add additional capacity with the next permit renewal.
16. Are there any plans to expand the landfill capacity at the facility beyond the amounts in
the current permit and next renewal? If so, what is the timeframe and how much? [This
should be additive to the amounts in Questions 9 and 15.]
Not at this time.
51
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ATTACHMENT: RCRAINFO PERMIT MODULE DATA FOR
CLEAN HARBORS DEER TRAIL, LLC LANDFILLS
RCRAInfo Permit Module on Landfill Capacity - September 16, 2014
Unit Name
Capacity
Capacity
UOM
Capacity
Type
SECURE LANDFILL
2,530,000
Cu-Yd
Undefined
SECURE LF - CELL 3
414,000
Cu-Yd
Undefined
TOTAL
2,944,000
Cu-Yd
52
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Questions on Landfill Capacity for Clean Harbors Lone Mountain, LLC
(EPA ID OKD065438376)
Instructions: Please provide responses to the questions below. The first set of questions asks
about the annual quantity of wastes and materials that you landfill. The second set asks about
your current and future landfill capacity. Provide responses in the blank space below each
question or on a separate sheet of paper. For your assistance, Attachment 1 provides some
RCRAInfo permit module data on your landfills and Attachment 2 provides some data provided
by the Lone Mountain facility on October 29, 2014. We have attempted to map some of the
data from Attachment 2 to our questions, below; they are indicated with an Please revise
as appropriate.
Annual Quantity of Landfilled Wastes and Materials
1. Total Annual Landfilled Quantity: What is the total quantity of all wastes and
materials disposed of in your facility's landfill(s) in a typical calendar year? This should
include everything placed in the landfills, i.e., federal and state-only hazardous waste,
non-hazardous waste, and miscellaneous materials (e.g., stabilization materials, dirt,
etc.). These wastes and materials are further addressed in Questions 2 through 4.
135,837 tons
2. Based on the 2011 Hazardous Waste Report, your facility landfilled 88,472 tons of
hazardous waste (i.e., 84,468 tons reported on Form WR and 4,004 tons on Form GM).
This is our best estimate of the total quantity of federally regulated hazardous wastes
landfilled. If you also landfilled state-only hazardous wastes, what percent of your total
annual landfilled quantity (as provided in Question 1) do they represent approximately
(e.g., 5%, 10%, negligible)?
Oklahoma does not have a state hazardous waste.
3. Besides hazardous waste, 1) what types of non-hazardous wastes does your facility
dispose of in your landfill and 2) what percent of your total annual landfilled quantity (as
provided in Question 1) do they represent approximately? This could include, for
example, TSCA waste, municipal waste, and other non-hazardous waste.
1) TSCA Mega rule and nondescript nonhazardous waste.
2) Approximately 35%
53
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4. Besides the wastes described above, 1) what materials do you place in the landfill that
use up capacity (e.g., stabilization materials, dirt, etc.) and 2) what percentage of total
annual landfilled quantity (as provided in Question 1) do they represent approximately?
1) Cement Kiln Dust (CKD), Portland Cement, and Fly Ash
2) Approximately 26%
5. For purposes of analysis, we assume that your total annual landfilled quantity in
Question 1 consists entirely of the hazardous wastes described in Question 2, the non-
hazardous wastes in Question 3, and the materials in Question 4. Please ensure that
your estimates in Questions 2 thru 4 approximate (mathematically) the total annual
landfilled quantity in Question 1. If they do not, please clarify why not.
Waste to landfill tonnage (questions 1,2, and 3) is based on waste received and does not use
stabilization materials from question 4.
6. Do you expect your total annual landfilled quantity (as provided in Question 1) to
remain steady, grow or decline over the next 20 years? If it will grow or decline, at what
annual rate?
Remain steady but business depends on market conditions.
7. Is the facility permitted to accept dioxin and elemental mercury wastes?
The facility can take dioxins that meet LDR standards or is incorporated into non-hazardous
waste.
The facility cannot accept elemental mercury.
8. Are there any wastes that the facility cannot accept? If so, please describe.
• Bulk fuel (tankers) without special arrangements
• Bulk stabilization of waste with a flash point <120°F - 130°F without special limitations
• Biohazard and infectious wastes
• TSCA PCB wastes subject to full regulation. Only "exempt" PCB waste and non-liquid
Mega-Rule PCB waste (Remediation, Bulk Product, etc.) are accepted, on a case-by-case.
• Explosives
• Compressed gases
• NRC-regulated radioactive and nuclear wastes
• Municipal trash
• Unknown waste
54
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Landfill Capacity
9. What is the currently permitted and available landfill capacity at the facility in tons (if
not provided in tons, please provide the unit of measure and conversion factor for
tons)? This includes all remaining permitted capacity in landfills currently in operation,
under construction, not yet built, etc.
*Clean Harbors has indicated that the "current permitted capacity of Cell 15 is 5,078,500 CY"
and the "current consumed capacity of Cell 15 is 2,817,800 CY." This indicates that the
currently permitted and available landfill capacity at the facility is 2,260,700 CY. For conversion
factor use 1 ton = 1 cu yd.
10. Do you plan on using all of this capacity in the future?
Yes.
11. What conversion factor do you use to convert waste volume (e.g., cubic yards) to tons,
e.g., for purposes of estimating landfill capacity?
To account for reagents and compaction use 1.2 cu yd/ton.
12. What is the available capacity in the currently lined and operating cells that have a
permit in tons?
*Clean Harbors has indicated that the "current constructed capacity of Cell 15 is 3,231,010 CY"
and the "current consumed capacity of Cell 15 is 2,817,800 CY." This indicates that the
available capacity in the currently lined and operating cells that have a permit is 413,210 CY.
In addition, Clean Harbors indicated that it is "currently in the construction process of adding 2
more subcells (subcell 12 and 13) of Cell 15 which will add roughly 910,211 CY of constructed
capacity hopefully by the end of the year."
13. What is the remaining life of the currently lined and operating cells that have a permit?
Approximately 3 years. Current construction of subcells 12 and 13 will be completed in
approximately 8 weeks will add an additional 6 V* years of life.
55
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14. When does the facility's RCRA permit need to be renewed? Does the facility plan to
continue landfill operations over the next 20 years?
The next renewal is due October 1, 1020, the permit expires April 1, 2021. The facility does
plan to continue landfill operations over the next 20 years.
15. How much additional capacity would be available under the next permit renewal? [This
should be additive to the amount in Question 9.]
*Clean Harbors indicated that it is "currently in the permitting process to increase the capacity
of cell 15 by approximately 2,801,500 CY. We hope this is complete by early next year."
16. Are there any plans to expand the landfill capacity at the facility beyond the amounts in
the current permit and next renewal? If so, what is the timeframe and how much? [This
should be additive to the amounts in Questions 9 and 15.]
Unknown at this time.
56
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ATTACHMENT 1: RCRAINFO PERMIT MODULE DATA FOR
CLEAN HARBORS LONE MOUNTAIN, LLC LANDFILLS
RCRAInfo Permit Module on Landfill Capacity - September 16, 2014
Unit Name
Capacity
Capacity
UOM*
Capacity
Type
01
215
Ac-F
Permitted
CELL 15
42
Ac-F
Permitted
TOTAL
257
Ac-F
*Ac-F = acre-foot.
57
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ATTACHMENT 2: PREVIOUS EMAIL FROM CLEAN HARBORS
From: ADAIR, ALAN JAY [mailto:adair.alan@cleanharbors.com]
Sent: Wednesday, October 29, 2014 1:51 PM
To: Chen, Lixia (Alicia)
Cc: STEWART, LON R
Subject: RE: Lone Mountain HW landfill capacity in OK
Here are the numbers that I have not including any of the capacity of the closed landfills which include
the drum cell and cells 1 through 8.
The current permitted capacity of Cell 15 is 5,078,500 CY.
The current constructed capacity of Cell 15 is 3,231,010 CY.
The current consumed capacity of Cell 15 is 2,817,800 CY.
We are currently in the construction process of adding 2 more subcells (subcell 12 and 13) of Cell 15
which will add roughly 500,000 CY of constructed capacity hopefully by the end of the year.
Also, we are currently in the permitting process to increase the capacity of cell 15 by approximately
2,801,500 CY. We hope this is complete by early next year.
Lon, feel free to add anything that I may have left out.
Hope this information is what your were looking for.
58
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FOLLOW UP QUESTIONS ON YOUR SUBMISSION ON LANDFILL CAPACITY
Lone Mountain, LLC (EPA ID OKD065438376)
Landfilled Quantity
The table below summarizes the data received from the facility in response to Questions 1 through 4 of
the questionnaire (see Row 1). Column A presents your response to Question 1, Columns B and C to
Question 2, Column D to Question 3, and Column E to Question 4. As requested in the questionnaire,
the sum of Columns B, C, D and E should equal Column A, unless specified otherwise. In your
responses, you estimate 88,472 tons of federally regulated hazardous waste and no state-only
hazardous waste. You also indicate that non-hazardous waste are 35% of total landfilled waste and
materials, and finally, materials such as ash and cement are 26% of all landfilled waste but are not
included in the total quantity of landfilled waste and materials provided in Question 1. If Columns B
through E are added up, we get 171,333 tons as the total quantity of landfilled waste and materials. If
the numbers in the table are correct, please so state. If they are not correct, please reconcile your
estimates in Columns A through E so that the sum of Columns B through E equals A. (We assume you
need not revise Column B because it is based on the 2011 Biennial Report; however, if it is not
representative of your average annual quantity of federally regulated waste landfilled, please
modify). Present your revised estimates in Row 2.
A
B
C
D
E
Total Quantity
of Landfilled
Waste and
Materials
(Question 1)
Federally
Regulated
Hazardous
Waste
(Question 2)
State-Only
Hazardous
Waste
(Question 2)
All Non-
Hazardous
Waste
(Question 3)
All Materials
(e.g.,
stabilization
materials)
(Question 4)
1. Your
original
responses
Approx
135,837 tons
(excluding Col
E)) and
171,333 tons
(including Col
E)
88,472 tons
(based on 2011
Biennial
Report)
0 tons
35% of Column
A: 47,543 tons
26% of
Column A:
35,318 tons
2. Your
revised
responses
171,333 tons
88,472 tons
0 tons
47,543 tons
35,318 tons
Remaining Permitted Landfill Capacity
We also would like to confirm your remaining permitted landfill capacity:
• Your response to Question 9 indicates that your landfills have a remaining permitted capacity of
2,260,700 cubic yards, or 2,712,840 tons. Your response to Question 15 indicates that, if
granted a permit renewal currently in the permitting process, you expect an additional
2,801,500 cubic yards, or 3,361,800 tons, of capacity. In total, this reflects 6,074,640 tons of
59
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total capacity (i.e., the 3.36M tons under the renewal is additive to the 2.7M tons currently
under the permit). Is this correct? Yes, that is the correct number PGR 11/254/2014
60
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Questions on Landfill Capacity for Clean Harbors Grassy Mountain, LLC
(EPA ID UTD991301748)
Instructions: Please provide responses to the questions below. The first set of questions asks
about the annual quantity of wastes and materials that you landfill. The second set asks about
your current and future landfill capacity. Provide responses in the blank space below each
question or on a separate sheet of paper. For your assistance, attached is some RCRAInfo
permit module data on your landfills.
Annual Quantity of Landfilled Wastes and Materials
1. Total Annual Landfilled Quantity: What is the total quantity of all wastes and
materials disposed of in your facility's landfill(s) in a typical calendar year? This should
include everything placed in the landfills, i.e., federal and state-only hazardous waste,
non-hazardous waste, and miscellaneous materials (e.g., stabilization materials, dirt,
etc.). These wastes and materials are further addressed in Questions 2 through 4.
89,300 tons
2. Based on the 2011 Hazardous Waste Report, your facility landfilled 73,381 tons of
hazardous waste (i.e., 73,113 tons reported on Form WR and 268 tons on Form GM).
This is our best estimate of the total quantity of federally regulated hazardous wastes
landfilled. If you also landfilled state-only hazardous wastes, what percent of your total
annual landfilled quantity (as provided in Question 1) do they represent approximately
(e.g., 5%, 10%, negligible)?
10%
3. Besides hazardous waste, 1) what types of non-hazardous wastes does your facility
dispose of in your landfill and 2) what percent of your total annual landfilled quantity (as
provided in Question 1) do they represent approximately? This could include, for
example, TSCA waste, municipal waste, and other non-hazardous waste.
All types of nonhazardous industrial waste. 2%
TSCA PCB waste (soils, debris, electrical components). 24%
4. Besides the wastes described above, 1) what materials do you place in the landfill that
use up capacity (e.g., stabilization materials, dirt, etc.) and 2) what percentage of total
annual landfilled quantity (as provided in Question 1) do they represent approximately?
Stabilization reagents
13%
61
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5. For purposes of analysis, we assume that your total annual landfilled quantity in
Question 1 consists entirely of the hazardous wastes described in Question 2, the non-
hazardous wastes in Question 3, and the materials in Question 4. Please ensure that
your estimates in Questions 2 thru 4 approximate (mathematically) the total annual
landfilled quantity in Question 1. If they do not, please clarify why not.
6. Do you expect your total annual landfilled quantity (as provided in Question 1) to
remain steady, grow or decline over the next 20 years? If it will grow or decline, at what
annual rate?
Remain the same.
7. Is the facility permitted to accept dioxin and elemental mercury wastes?
Only Dioxins that meet the LDR treatment standards.
No to elemental mercury.
8. Are there any wastes that the facility cannot accept? If so, please describe.
a. Explosive wastes or materials (defined as DOT Forbidden, DOT Division 1.1, 1.2,
1.3, 1.4, 1.5, and 1.6explosives.
b. DOT Division 4.1(2) Type A and Type B materials, and in Utah Admin. Code
R315-2-9(f)(l)(vi)-(viii), except for wastes that do not meet the RCRA definition
of ignitability (D001) and/or reactivity (D003).
c. Spontaneously combustible (pyrophoric and self-heating) wastes and materials,
DOT Division 4.2 (Except in Lab Pack Quantities for storage only).
d. Water reactive materials, DOT Division 4.3, (Except in Lab Pack Quantities for
storage only or for treatment with prior approval of the Director).
e. Shock sensitive materials.
f. Radioactive waste, unless authorized for acceptance by the NRC or Utah Division
of Radiation Control, whichever has jurisdiction over the waste.
g. Infectious waste, as defined in the Utah Code Annotated, Title 19, Section 6,
Subsection 102 and Condition I.F.F (Definitions).
62
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Landfill Capacity
9. What is the currently permitted and available landfill capacity at the facility in tons (if
not provided in tons, please provide the unit of measure and conversion factor for
tons)? This includes all remaining permitted capacity in landfills currently in operation,
under construction, not yet built, etc.
Cell Permitted Capacity Remaining Capacity
B/6 1,125,000 306,100 cy
7 1,106,000 267621 cy
Conversion factor 1.25 tons/cubic yard
10. Do you plan on using all of this capacity in the future?
Yes
11. What conversion factor do you use to convert waste volume (e.g., acre-foot) to tons,
e.g., for purposes of estimating landfill capacity?
2017 tons/acre
12. What is the available capacity in the currently lined and operating cells that have a
permit in tons?
717,151 tons
13. What is the remaining life of the currently lined and operating cells that have a permit?
Approximately 8 years
14. When does the facility's RCRA permit need to be renewed? Does the facility plan to
continue landfill operations over the next 20 years?
September 28, 2022.
Yes.
15. How much additional capacity would be available under the next permit renewal? [This
should be additive to the amount in Question 9.]
The cells are permitted on an as needed basis and not specifically listed in the permit.
Approximately 70% of the 640 acres of permitted part of the facility is available for
future landfill construction.
63
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16. Are there any plans to expand the landfill capacity at the facility beyond the amounts in
the current permit and next renewal? If so, what is the timeframe and how much? [This
should be additive to the amounts in Questions 9 and 15.]
Not at this time.
64
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ATTACHMENT: RCRAINFO PERMIT MODULE DATA FOR
CLEAN HARBORS GRASSY MOUNTAIN, LLC LANDFILLS
RCRAInfo Permit Module on Landfill Capacity - September 16, 2014
Unit Name
Capacity
Capacity
UOM*
Capacity
Type
CELL 7
275
Ac-F
Permitted
CELL B/6
306
Ac-F
Permitted
TOTAL
581
Ac-F
*Ac-F = acre-foot.
65
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FOLLOW UP QUESTIONS ON YOUR SUBMISSION ON LANDFILL CAPACITY
Grassy Mountain, LLC (EPA ID UTD991301748)
Landfilled Quantity
The table below summarizes the data received from the facility in response to Questions 1 through 4 of
the questionnaire (see Row 1). Column A presents your response to Question 1, Columns B and C to
Question 2, Column D to Question 3, and Column E to Question 4. As requested in the questionnaire,
the sum of Columns B, C, D and E should equal Column A. However, this is not the case for your
responses, as shown in the table. If Columns B through E are added up, we get 117,138 tons as the total
quantity of landfilled waste and materials, not 89,300 tons. Please reconcile your estimates in Columns
A through E so that the sum of Columns B through E equals A. (We assume you need not revise
Column B because it is based on the 2011 Biennial Report; however, if it is not representative of your
average annual quantity of federally regulated waste landfilled, please modify). Present your revised
estimates in Row 2.
A
B
C
D
E
Total Quantity
of Landfilled
Waste and
Materials
(Question 1)
Federally
Regulated
Hazardous
Waste
(Question 2)
State-Only
Hazardous
Waste
(Question 2)
All Non-
Hazardous
Waste
(Question 3)
All Materials
(e.g.,
stabilization
materials)
(Question 4)
1. Your
original
responses
73,381 tons
(based on 2011
Biennial
Report)
10% of Column
A: 8,930 tons
26% of Column
A: 23,218 tons
13% of
Column A:
11,609 tons
2. Your
revised
responses
117,138 tons
73,381 tons
8,930 tons
23,218 tons
11, 609 tons
Remaining Permitted Landfill Capacity
We also would like to confirm your remaining permitted landfill capacity:
• Your response to Question 9 indicates that your landfills have a remaining capacity of 573,721
cubic yards, or 717,151 tons. You do not provide an estimate of additional capacity under your
next permit renewal under Question 15. We want to confirm that you cannot provide a
conservative estimate of additional capacity under a future permit modification or renewal (i.e.,
an amount that would be in addition to the 717K).
We do not anticipate requesting additional cell capacity in the upcoming facility permit
renewal as we have sufficient disposal capacity for the next five years. PGR 11/25/2014
66
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US Ecology
Questions on Landfill Capacity at each Facility
1. Besides Subtitle C hazardous waste, what types of wastes does the facility accept for
landfill disposal and in general what percent of its annual landfiiled quantity do they
represent (e.g., negligible, 20%, 50%)? This could include, for example, TSCA/PCB waste,
non-hazardous waste, etc]
Based on 2014 volumes the % breakdown is presented below These percentages may change
over time
facility
RCRA and
TSCA (PCBl
ten Ha/
State Hai
Waste
5eatr>
63
14
Grsnc Vt?*
ts
F C
-1**
>vayfie
39
54
7
2. Do you receive any state-only hazardous wastes and what percent of your annual
landfiiled quantity do they represent?
Yes, all of our facilities receive state only hazardous waste, however we do not track :rdently
the volumes received by each facility separately from RCRA hazardous waste
3. Is the facility permitted to accept dioxin and elemental mercury wastes?
AH of the US Ecology Landfills can accept elemental Mercury, provided the total concentration ts <
260 mg/l ana the waste mees LDRs. Robstown is Ihe only taoiity expressly prohibited torn taking
drown waste,
4. Are there any wastes that the facility cannot accept? Examples include explosives,
mixed radioactive waste, dkmns-
Facility
Prohsb ted wave
BeaBy
Sc-i-fMnst faflicacavs rratsrs soTsprfssed c-' p*?ssjrzK gases sif eswes
DiotogiatwpWgc'rfKncuj, Uqud 0*9111: jtracfi >5N ccr.anerzsc c.cs ;taB(»as;i «rtr
Diadtoraesilt acsot-riis
Grans V«*
Eoosves pyToenow, sicc* strt5.11>* iadrw, esaecol ccipresiK jasses
Rcos»»n
OOOJ farr-uat e iquas PCS - tipomt'i. Dorrs a*~-;r?s—-3 etoogias *;-te -nu-»cical
*3itf TiKca: *:str a.r»j{itte wast? seotaje
~C03 eic-c?u*s. lurmaoies. is* *.e -aaoacive *are jna 3-ono na wwitee pi Inr
What is the currently permitted and available andfilJ capacity at the facility, in tons if
possible? This includes all remaining permitted capacity in landfills currently in
operation, under construction, not yet built, etc.
Facility
K.?rn=ir,irtg Pemitted Capacity
;tans:
$«;<
iZl COC
Graic Vie*
1 v.t tjc
I see 90C
»Vav*ie
¦5.:cc >DC
1
67
-------
s.
Do you pian on using all of this capacity in the future?
Yes
What conversion factor do you typically use to convert waste volume (e.g., cubic yards)
to mass (tons) for purposes of estimating landfill capacity?
We make adjustments to the conversion factor based on surveyed volumes and waste
receipt data. Generally that conversion is 1.2 - 1.3 tons/cy.
Besides the waste itself, what other materials are placed into the landfill that will use up
capacity {e.g., stabilization materials, etc.) and what percentage of total iandfilted
Faciin
J Regents
Beany
20-S
Gfaic Vim
16%
RdOSVMI
9S
Wayne
unknown
9. Are these materials taken into account in the available landfill capacity estimates
provided in Question 5?
Ves
10. What is the availabe capacity in the currently lined and operating eel s that have a
permit in tons?
aolity
Remaning constructed
Cao.ic tv
I -
S28 03C
Srax View
1 55" 03C
F.C3Stt*n
1 soc ooe
rt'ape
J 177 ;tu
11. What is the remaining life of the currently ined and operating ce Is that have a perm it?
Facility
Rnwrninq lit:-(war-,
5rj-<
Gra-c Vie*
i
Rcosxwr
«Var»e
9
12. When does the facility's RCRA permit need to be renewed' Does the facility plan to
continue landfill operations over the next 20 years?
Facility
Pc-miit expiration
Se3!5>
Ceie-nte- 2016
C-a-e Vie*
Nc.fvM' :ou
Rcsroar
Marcn :o:3
»V3i*ie
ua« t 2022
2
68
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13. How much additional capacity would be available under the next permit renewal? [This
should be additive to the amount in Question 5.]
Faolily
Capacity at Renewal date
(torn)
Beas>
5 MC 090
Grarc vim
C
Rcos»*n
10 iOC 0Q€
A'ayne
c
14. Are there any plans to expand the andfill capacity at the facility beyond the amounts in
the current permitted and next renewal? If so, what is the timeframe and how much?
[This should be additive to the amounts in Questions S and 13.)
The capacity expansion at Robstown presented in Question 13 will occur pnor © the permit renewal
time. Generally our capacity expanses are revested through permit modifications that do not
coincide iwth permit renewal timelines,
15. Do you expect the quantity of wastes you landfill over the next 20 years to remain
steady, grow or decline, in comparison with the 2011 quantity? tf it will grow or decline,
at what annual rate?
Assuming no significant regulatory changes that impact hazartous waste disposal, we anticipate
volumes to be Sat However the type of wastes generated my change ever time
69
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Heritage Environmental Services
o HERITAGE
CKMfKSNVi; IsfTAL SERVICES
7S01 WwUomsSSreei
hdanapob, N 46231
57X365778
Vis Email
November 17.2014
Mr. J. Ear! Harris
tCF International
9300 Lee Highway
Fairfax, VA 22031
Re; RF1 - Heritage Environmental Services. IXC
EPA ID IMD90O5O399O
Dear Mr. Harris:
Please find enclosed the reponse to your request for information related to capacity of the
Heritage Environmental Services, LLC landfill operated in Roachdaie Indiana. Please
contact me with any questions at steve-danenman ^henagg-enMro.coro or (317)466-2722.
Sincerely
Heritage Environmental Services, LLC
Steven ...
Danenman HZ
Steven Danenman
Program Manager, Corporate Compliance
wwvv.heritage-efwro. com
PEOPLE PROVIDING
70
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Questions on Landfill Capacity for
Heritage Environmental Services LLC (Indiana)
(EPA ID 1ND980503890)
Instructions Please provide responses to tie cue it ton below The first set of questions asks
a boat the sinus i quantify of wastes and materia J tiat you lancfl. The second set asks about
your current and future landfill capacity- Provide responses in the Blank space Oelow each
quest ion or on a separate sheet of paper. For your assistance, attached is some RCRAInfo
permit moduie data on your landfills.
Annus! Quantity of landfilled Wastes and Materials
1. Total Annual LandfiUcd Quantity What is the total Quantity of all wastes and
materials disposed of in your facility's laidfill(s) in a typical calendar year? This should
include everything placed in the landfills. It federal arc stste-orly hazardous waste,
non-haza-cous waste and miscellaneous materials le g., staa ization materials, cirt,
etcj. These wastes and materials are further addressed in Questions 2 througi 4,
The average annual receipts of all wastes tie past three (3)yea's is 296 700
tons.
2. Based on the 2011 Hazardous Waste Report, your facility landfilled 100.115 tors of
hazardous waste. This a our best est mate of the tota1 quantity of federally regulated
hazardous wastes tandflted. tf you also landfilled state-on y hazardous wastes, what
percent of your total annual landfilled quantity (as a'ov ctd in Question 1} do they
rep'eseit approximately (e.g.. 5 V 10V reg igible)?
The facility does not have any actve waste p'ofi «s fo' state-or ty haiardous
wastes.
3 Besides hazareo us waste. 1) what types of non-hazardous wastes does your facil ty
dispose of in your landfill are 2) what percent of your total annual landfilled quantity (as
provided in Quest on 1) do they represent approximately' This cou
-------
4. Beside: tie M anes cescribed above. 1) wist materials do you place in the ancf: that
Lie up capacity |e.g . stabilization materials, dirt, etc.) and 2} what oe*centi;e of total
annual ar dfilied quantity (as provided in Question 1) do they represent approximately?
Da;ly Cove - - It is estimated to be 2^> annually.
5 For purposes of analysts, we assume that your total annual landfilled quantity in
Question 1 consists entirety of the hsis-eious wastes described in Question 2, the non-
haiardous wastes in Question 3, and tie materials in Question 4. Please ensure that
your estimates in Questions 2 thru 4 approximate (mathematically) the total annual
landfilled quantity in Question 1. If they do not, please clarify why not.
The nasarcous tons prov dec by USEPA in question 2 are forcalercar year 2011.
Our estimates j*e based on ave-aees over mult pe caencar years. The average
percent of receipts being RCRA hazardous waste over a longer period is 26V
6 Do you expect your total annual iandfilied quantity (as provided in Question 1) to
remain steady, grow or decline over the next 20 years' If it will grow or deciine, at wiat
annual 'ate?
We expect the quart'ity to remain steady the next three (3) years. We have not
projected the next 20 years.
7. Is the facility permittee to accept dioxin and elemental mercury wastes?
No
6. Are there any w astes that the facility cannot accept? If so. please descrioe.
Municipal waste
Racioactive Waste
NORM
Drummed or similarly containerized waste
Medical or infectious waste
Sewage or biologxal sludge
Landfill Capacity
9 What is the currently perm itted and avai able landfill capacity at the facility in tons (if
not proviced in tons, please provide tie unit of measure and conversion •'actor for
tons)? This includes all remaining perm itted capacity in landfills current^ in ©perat on
under construction, not yet built, etc
16.531.826 cubic yards Convers on Factor = 0.8 cubic ya'dsAon
2
72
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10. Do you s ir on using ail of this capacity in the future?
Yes
11. What conversion factor do you use to cor ve*t waste volume (e acre-foot) to tors,
eg . f
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ATTACHMENT: RCRAJNfO PERMIT MODULE DATA FOR
HERITAGE LLC (INDIANA) LANDFILLS
RCRAlnro Permit Module on Lanoflll Capacity - SeptamDer 1€, 2014
Unit Nairn
Capacity
Capacity
JOM
Capacity
Type
sW13LFUN!T2
120
Acres
Undefined
4
74
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[Page intentionally left blank.]
75
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Commercial Hazardous Waste Incineration Facilities
76
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[Page intentionally left blank.]
77
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Questions on Incineration Capacity for
Clean Harbors Facility (Arkansas)
(EPA ID ARD069748192)
Instructions: Please provide responses to the questions below. The first set of questions asks
about the annual quantity of wastes and materials that you incinerate. The second set asks
about your current and future incineration capacity. Provide responses in the blank space
below each question or on a separate sheet of paper. We will use your input to estimate the
quantity of hazardous waste to be incinerated at your facility and your facility's permitted and
available incineration capacity over the next 20 years. For your assistance, attached is some
RCRAInfo permit module data on your incinerators.
Annual Quantity of Incinerated Wastes and Materials
1. Total Annual Incinerated Quantity: What is the total quantity of all wastes and
materials incinerated by your facility in a typical calendar year? This should include all
federal and state-only hazardous waste, non-hazardous waste, and all other materials.
These wastes and materials are further addressed in Questions 2 through 4.
2011- 88,923 tons of customer waste incinerated
2011 - 9268 tons of on-site generated waste incinerated
2011- 98,191 tons total incinerated on-site
2. Based on the 2011 Hazardous Waste Report, your facility incinerated 65,100 tons of
hazardous waste (i.e., 64,025 tons reported on Form WR and 1,075 tons on Form GM).
This is our best estimate of the total quantity of federally regulated hazardous wastes
incinerated. If you also incinerated state-only hazardous wastes, what percent of your
total annual incinerated quantity (as provided in Question 1) do they represent
approximately (e.g., 5%, 10%, negligible)?
Arkansas does not have state-only regulated waste
3. Besides hazardous waste, 1) what types of non-hazardous wastes does your facility
incinerate and 2) what percent of your total annual incinerated quantity (as provided in
Question 1) do they represent approximately? This could include, for example, TSCA
waste, municipal waste, medical waste, and other non-hazardous waste.
2011 Customer Hazardous waste 65,100 tons 67%
2011 Customer Non-hazardous waste 23,798 tons 24%
2011 On-site generated waste 9268 tons 9 %
2011 Customer Total waste incinerated 98,191 tons 100%
Examples of customer non-hazardous waste include: universal waste, consumer
commodities, soils, manufacturing debris, freons, lean waters, witness burn DEA
Schedule 4 drugs and other drug paraphernalia. The El Dorado Facility does not possess
a TSCA License to incinerate PCBs,
78
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4. Besides the wastes described above, 1) what materials do you incinerate that use up
capacity and 2) what percentage of total annual incinerated quantity (as provided in
Question 1) do they represent approximately?
On site generated waste (ppe, lab trash, lab samples, reburn ash, tank sludge, sump
pump outs, equipment decon)
2011 In house waste incinerated on-site 9,268 tons
5. For purposes of analysis, we assume that your total annual incinerated quantity in
Question 1 consists entirely of the hazardous wastes described in Question 2, the non-
hazardous wastes in Question 3, and the materials in Question 4. Please ensure that
your estimates in Questions 2 thru 4 approximate (mathematically) the total annual
incinerated quantity in Question 1. If they do not, please clarify why not.
Okay- balanced
6. Do you expect your total annual incinerated quantity (as provided in Question 1) to
remain steady, grow or decline over the next 20 years? If it will grow or decline, at what
annual rate?
The annual rate of incineration should remain steady until the new incinerator
construction is complete which is due approximately in the beginning of 2017.
The new incinerator will increase the sites incineration capacity by 100% from 61,025/1 b
hr to 122,050/lbs hr.
7. How will the demand for incineration capacity at your facility be affected by the recent
U.S. Court of Appeals decision to vacate the "comparable fuels rule," which provides an
exclusion from RCRA hazardous waste regulations for certain fuels derived from
hazardous waste?
The US Court of Appeals Decision will have negligible impact on the El Dorado
Incineration Facility. We are prepared to manage formally classified Comparable Fuels
as a RCRA Liquid Hazardous Waste if our customer requires us to do so.
8. Are there any hazardous wastes that the facility cannot accept (e.g., pumpable (liquid)
or non-pumpable (solid) waste)? If so, please describe.
Yes - the facility cannot accept for storage nor incinerate the following waste codes in
liquid or solid form: D003 for explosive; F020, F021, F022, F023, F026, F027, F028, P009,
P065, P081.
The facility can accept and incinerate the following waste codes but cannot store them
in their storage tanks: K043, K090, K091, K099, P087, P113, P115, P119, P120, U151,
U214, U215, U216, and U217
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Incinerator Capacity
9. What is the currently permitted and available incineration capacity at the facility in tons
(if not provided in tons, please provide the unit of measure and conversion factor for
tons)? This includes all permitted capacity in operation, under construction, not yet
built, etc. per our CPT test results.
10.
Unit
Pump
Liquids Ibs/hr
Solids Ibs/hr
total mass feed (Ibs/hr)
Kiln #1
5,005
8,378
13,383
Kiln #2
9,527
20,641
30,168
see
13,601
-
13,601
WFB
3,873
-
3,873
Newly
permitted
Rotary Kiln 44
&SCC
(permitted but
not yet
constructed)
45,000
Note: the conversion factor is: lbs per hour X 8040 hours per year / 2000 tons = tons/year
10. What is the maximum operating capacity of the facility's incinerators (if different from
the amount in Question 9)?
11. Do you plan on increasing/decreasing the currently permitted and available incineration
capacity under your current permit and, if so, by how much and when?
The Arkansas DEQ recently issued RCRA Part B and CAA Title V permits to construct and
operate a new rotary kiln incinerator with a permitted capacity of approximately 75,000
tons per year
12. When does the facility's RCRA permit need to be renewed? Do you intend to
increase/decrease your incineration capacity under your permit renewal and, if so, by
how much? [This should be additive to the amounts in Questions 9 thru 11.]
March 2018
13. Are there any plans to increase/decrease the incineration capacity at the facility beyond
the amounts in the current permit and next renewal? If so, what is the timeframe and
how much? [This should be additive to the amounts in Questions 9 thru 12.]
No
14. Does the facility plan to continue incineration operations over the next 20 years?
Yes
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15. Are there any limitations on your incinerator's operation due to operational or permit
requirements (e.g., metals, CO emissions, Btu values, water content)?
Yes, based on EEE standards and CPT results.
Emission Standards per unit
Incineration Units:
40 CFR § 63.1219(a)( l)(ii)
Dioxins/furans (D/F)
ng TEQ/dscm
0.40
40 CFR § 63.1219(a)(2)
Mercury
l-ig/dscm
130
40 CFR § 63.1219(a)(3)
Semi volatile metals
(SVM)
l-ig/dscm
230
40 CFR § 63.1219(a)(4)
Low volatility metals
(LVM)
l-ig/dscm
92
40 CFR § 63.1219(a)(6)
Total chlorine (HCl/CL)
ppmv (dry)
32
40 CFR § 63.1219(a)(7)
Particulate matter (PM)
gr/dscf
0.013
40 CFR § 63.1219(a)(5)(ii)
Carbon monoxide (CO)
ppmv (dry)
100
40 CFR § 63.1219(c)(1)
Destruction and removal efficiency (DRE) of 99.99 percent for each designated
Principal Organic Hazardous Constituent (POHC)
Waste Fired Boiler:
40 CFR § 63.1217(a)(5)
Dioxins/furans (D/F)
na
Compliance with the CO
emission standards
40 CFR § 63.1217(a)(2)(ii)
Mercury
lb/MMBtu
4.2E-05
40 CFR § 63.1217(a)(3)(ii)
Semi volatile metals
(SVM)
lb/MMBtu
8.2E-05
40 CFR § 63.1217(a)(4)(ii)
Chromium
lb/MMBtu
1.3E-04
40 CFR § 63.1217(a)(6)(ii)
Total chlorine (HCI/CI2)
lb/MMBtu
5.1E-02
40 CFR § 63.1217(a)(7)
Particulate matter (PM)
mg/dscm
801
40 CFR § 63.1217(a)(5)(i)
Carbon monoxide (CO)2
ppmv(dry)
100
40 CFR §63.1217 (c)(1)
Destruction and removal efficiency (DRE) of 99.99 percent for each designated
Principal Organic Hazardous Constituent (POHC)
OPL's for the Current Incinerator Unit and WF
B
Parameter
OPL
Emission Standard
Kiln No. 1 combustion chamber temperature
861° F
HC and DRE
Kiln No. 2 combustion chamber temperature
875° F
HC and DRE
Secondary Combustion Chamber temperature
1851°F
HC and DRE
Waste Fired Boiler combustion chamber temperature
1856 ° F
HC and DRE
Maximum mass waste feed rate Kiln No 1
13,383 lbs/hr
HC, DRE, and D/F
Maximum pumpable waste feed rate Kiln No 1
5,005 lbs/hr
HC, DRE, and D/F
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Maximum mass waste feed rate Kiln No 2
30,168 lbs/hr
HC, DRE, and D/F
Maximum pumpable waste feed rate Kiln No 2
9,527 lbs/hr
HC, DRE, and D/F
Maximum mass feed rate to SCC
13,601 lbs/hr
HC, DRE, and D/F
Maximum mass feed rate to the entire incineration system
50,505 lbs/hr
HC, DRE, and D/F
Maximum liquid feed rate to WFB
3,873 lbs/hr
HC, DRE, and D/F
Maximum combustion gas flow rate (measured at stack)
100,568 acfm
HC, DRE, D/F, PM, SVM, LVM,
and HCl/Ck
Waste Fired Boiler combustion gas flow rate
8,630 scfm
HC, DRE, D/F, PM, SVM, LVM,
and HCl/Ck
Maximum total ash feed rate total system
12,642 lbs/hr
PM
Maximum total ash feed rate to WFB
164.2 lbs/hr
PM
Maximum feed rate of mercury total system
0.46(3'lbs/hr
Mercury
Maximum thermal input of mercury waste fired boilers
0.187 131
lbs/MMBtu
Mercury
Maximum feed rate of SVM total system
116 131
SVM
Maximum thermal input of SVM waste fired boiler
3.12 131
lbs/MMBtu
SVM
Maximum feed rate of LVM total system
114 13' lb/lir
LVM
Maximum feed rate of chromium waste fired boiler
30 141 lbs/hr
LVM
Maximum thermal input of chromium waste fired boiler
2.87 131
lbs/MMBtu
LVM
Maximum feed rate of total chlorine/chloride total system
3,117 lb/lir
SVM, LVM, and HCl/Cb
Maximum thermal input of chlorine/chloride waste fired
boiler
1020 131
lbs/MMBtu
SVM, LVM, and HCl/Cb
Maximum stack gas carbon monoxide ( 1'
100 ppmv CO
HC and DRE
Maximum WFB exit duct carbon monoxide (1'
100 ppmv CO
HC and DRE
Minimum Kiln #1 draft 12'
0.0 in. w.c.
Fugitive emissions
Parameter
OPL
Emission Standard
Minimum Kiln #2 draft12'
0.0 in. w.c.
Fugitive emissions
Minimum SCC draft12'
0.0 in. w.c.
Fugitive emissions
Minimum WFB draft12'
0.0 in. w.c.
Fugitive emissions
Minimum HES pH
3.0
HCl/CL
Minimum HES liquid flow rate
696 gpm
HCl/CL
Minimum HES pressure drop
34 in. w.c.
HCl/CL
82
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Minimum HES blowdown rate
19 pgm
hci/ci2
Minimum HES tank liquid level
3.0 ft
HCI/Cb
Minimum carbon injection rate
22.7 lb/hr
D/F and mercury
Minimum carbon carrier fluid flow rate
32 scfm
D/F and mercury
Maximum Baghouse inlet temperature
214 °F
D/F and mercury
1 Corrected to seven percent oxygen.
2 This parameter is instituted with a one second delay.
3 Metals feed rate total and thermal, and chlorine thermal feed rate based on calculations from the 2011 test results.
4 USEPA requested a WFB chromium feed rate limit (lbs/hr) be calculated under the Phase I emission limit of 92(i/dscm in
addition to the thermal waste feed limit for liquid fired boilers.
Since the new incinerator is not built and no CPT has occurred no OPL's have been set yet.
16. Do you foresee any significant problems or delays in renewing your permits or
expanding your capacity under RCRA or CAA?
No
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ATTACHMENT: RCRAINFO PERMIT MODULE DATA FOR
CLEAN HARBORS INCINERATOR FACILITY (ARKANSAS)
RCRAInfo Permit Module on Incinerator Capacity - September 16, 2014
Unit Name
Capacity
Capacity
UOM
Capacity
Type
INCIN
30.51
T/Hr
Operating
84
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Questions on Incineration Capacity for
Clean Harbors Facility (Texas)
(EPA ID TXD055141378)
Instructions: Please provide responses to the questions below. The first set of questions asks
about the annual quantity of wastes and materials that you incinerate. The second set asks
about your current and future incineration capacity. Provide responses in the blank space
below each question or on a separate sheet of paper. We will use your input to estimate the
quantity of hazardous waste to be incinerated at your facility and your facility's permitted and
available incineration capacity over the next 20 years. For your assistance, attached is some
RCRAInfo permit module data on your incinerators.
Annual Quantity of Incinerated Wastes and Materials
1. Total Annual Incinerated Quantity: What is the total quantity of all wastes and
materials incinerated by your facility in a typical calendar year? This should include all
federal and state-only hazardous waste, non-hazardous waste, and all other materials.
These wastes and materials are further addressed in Questions 2 through 4.
174454 tons/year.
2. Based on the 2011 Hazardous Waste Report, your facility incinerated 157,971 tons of
hazardous waste (i.e., reported on Form WR). This is our best estimate of the total
quantity of federally regulated hazardous wastes incinerated. If you also incinerated
state-only hazardous wastes, what percent of your total annual incinerated quantity (as
provided in Question 1) do they represent approximately (e.g., 5%, 10%, negligible)?
Negligible as the facility does not typically receive any CERCLA waste.
3. Besides hazardous waste, 1) what types of non-hazardous wastes does your facility
incinerate and 2) what percent of your total annual incinerated quantity (as provided in
Question 1) do they represent approximately? This could include, for example, TSCA
waste, municipal waste, medical waste, and other non-hazardous waste.
PCB, used oil, alternative fuels, non-hazardous commercial products, confiscated street
drugs and household pharmaceuticals.
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4. Besides the wastes described above, 1) what materials do you incinerate that use up
capacity and 2) what percentage of total annual incinerated quantity (as provided in
Question 1) do they represent approximately?
The 49% of non-hazardous wastes comes from TSCA regulated PCB, along with
alternative fuels, and used oil.
It is approximately 51% hazardous (88,971.54 tons) and 49% non-hazardous (85,482.46
tons).
5. For purposes of analysis, we assume that your total annual incinerated quantity in
Question 1 consists entirely of the hazardous wastes described in Question 2, the non-
hazardous wastes in Question 3, and the materials in Question 4. Please ensure that
your estimates in Questions 2 thru 4 approximate (mathematically) the total annual
incinerated quantity in Question 1. If they do not, please clarify why not.
It is mass-balanced as noted in question Number 4's response. A majority of CERCLA
Remediation Waste is landfilled.
6. Do you expect your total annual incinerated quantity (as provided in Question 1) to
remain steady, grow or decline over the next 20 years? If it will grow or decline, at what
annual rate?
We expect current incineration capacity to remain steady with no infrastructure
modifications to significantly increase capacity.
7. How will the demand for incineration capacity at your facility be affected by the recent
U.S. Court of Appeals decision to vacate the "comparable fuels rule," which provides an
exclusion from RCRA hazardous waste regulations for certain fuels derived from
hazardous waste?
This Federal Appeals Court decision and subsequent rulemaking has a negligible impact
on plant operations as we can manage a wide range of comparable fuels and this market
place has been made aware of our ability to manage comparable fuels.
8. Are there any hazardous wastes that the facility cannot accept (e.g., pumpable (liquid)
or non-pumpable (solid) waste)? If so, please describe.
Per our RCRA permit we cannot accept Radioactive wastes, Explosive material, as defined by
the Department of Transportation under 49 CFR Part 173; Dioxin-containing wastes, identified by
EPA as F020, F021, F022, F023, F026, and F027 wastes in 40 CFR 261.31, except for storage only
in authorized units; Municipal garbage, Cyanide or sulfide compounds with ten (10) percent or
greater concentrations of CN or S" (except in lab packs, compressed cylinders, and liquid storage
containers).
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Incinerator Capacity
9. What is the currently permitted and available incineration capacity at the facility in tons
(if not provided in tons, please provide the unit of measure and conversion factor for
tons)? This includes all permitted capacity in operation, under construction, not yet
built, etc.
Train I capacity of 13.98 tons/hr, Train II capacity of 22.49 tons/hr
10. What is the maximum operating capacity of the facility's incinerators (if different from
the amount in Question 9)
It is not different then the data presented above and in the answer to question #1
11. Do you plan on increasing/decreasing the currently permitted and available incineration
capacity under your current permit and, if so, by how much and when?
There are no plans to increase or decrease the current permitted capacity.
12. When does the facility's RCRA permit need to be renewed? Do you intend to
increase/decrease your incineration capacity under your permit renewal and, if so, by
how much? [This should be additive to the amounts in Questions 9 thru 11.]
RCRA permit was renewed in 2014, with no request for an increase in incineration
capacity.
13. Are there any plans to increase/decrease the incineration capacity at the facility beyond
the amounts in the current permit and next renewal? If so, what is the timeframe and
how much? [This should be additive to the amounts in Questions 9 thru 12.]
There are no plans to increase the permitted capacity.
14. Does the facility plan to continue incineration operations over the next 20 years?
Yes
15. Are there any limitations on your incinerator's operation due to operational or permit
requirements (e.g., metals, CO emissions, Btu values, water content)?
Yes, all of the above plus particulate, dioxin and HCI.
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Do you foresee any significant problems or delays in renewing your permits
expanding your capacity under RCRA or CAA?
No. Waiting on the draft Title V permit but expect no major issues.
88
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ATTACHMENT: RCRAINFO PERMIT MODULE DATA FOR
CLEAN HARBORS INCINERATOR FACILITY (TEXAS)
RCRAInfo Permit Module on Incinerator Capacity - September 16, 2014
Unit Name
Capacity
Capacity
UOM
Capacity
Type
INCTRAINS l&ll
200,000,000
BTU/Hr
Permitted
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Questions on Incineration Capacity for
Veolia Technical Solutions Facility (Illinois)
(EPA ID ILD098642424)
Instructions: Please provide responses to the questions below. The first set of questions asks
about the annual quantity of wastes and materials that you incinerate. The second set asks
about your current and future incineration capacity. Provide responses in the blank space
below each question or on a separate sheet of paper. We will use your input to estimate the
quantity of hazardous waste to be incinerated at your facility and your facility's permitted and
available incineration capacity over the next 20 years. For your assistance, attached is some
RCRAInfo permit module data on your incinerators.
Annual Quantity of Incinerated Wastes and Materials
1. Total Annual Incinerated Quantity: What is the total quantity of all wastes and
materials incinerated by your facility in a typical calendar year? This should include all
federal and state-only hazardous waste, non-hazardous waste, and all other materials.
These wastes and materials are further addressed in Questions 2 through 4.
Veolia Response: Approximately 50,000,000 lbs. of all waste types are incinerated per
year.
2. Based on the 2011 Hazardous Waste Report, your facility incinerated 11,212 tons of
hazardous waste (i.e., based on tons reported on Form WR). This is our best estimate
of the total quantity of federally regulated hazardous wastes incinerated. If you also
incinerated state-only hazardous wastes, what percent of your total annual incinerated
quantity (as provided in Question 1) do they represent approximately (e.g., 5%, 10%,
negligible)?
Veolia Response: Illinois does not have a defined state-only hazardous waste. As a
result 100% of the hazardous waste is also state hazardous waste.
3. Besides hazardous waste, 1) what types of non-hazardous wastes does your facility
incinerate and 2) what percent of your total annual incinerated quantity (as provided in
Question 1) do they represent approximately? This could include, for example, TSCA
waste, municipal waste, medical waste, and other non-hazardous waste.
Veolia Response: The facility accepts and incinerates all types of non-hazardous
including off-specification products, industrial waste, controlled substances and other
consumer products. The facility does not accept TSCA waste, municipal waste or
medical waste. Non-hazardous waste receipts vary but could represent 25% - 50 % of
the total waste incinerated.
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4. Besides the wastes described above, 1) what materials do you incinerate that use up
capacity and 2) what percentage of total annual incinerated quantity (as provided in
Question 1) do they represent approximately?
Veolia Response: There are no other waste that we incinerate that uses existing
capacity. No products are added to the combustion process. The answer is 0%.
5. For purposes of analysis, we assume that your total annual incinerated quantity in
Question 1 consists entirely of the hazardous wastes described in Question 2, the non-
hazardous wastes in Question 3, and the materials in Question 4. Please ensure that
your estimates in Questions 2 thru 4 approximate (mathematically) the total annual
incinerated quantity in Question 1. If they do not, please clarify why not.
Veolia Response: The figures approximately add up but variations in hazardous and
non-hazardous waste designations can affect these figures
6. Do you expect your total annual incinerated quantity (as provided in Question 1) to
remain steady, grow or decline over the next 20 years? If it will grow or decline, at what
average annual rate?
Veolia Response: Remain Steady. We are at functional capacity.
7. How will the demand for incineration capacity at your facility be affected by the recent
U.S. Court of Appeals decision to vacate the "comparable fuels rule," which provides an
exclusion from RCRA hazardous waste regulations for certain fuels derived from
hazardous waste?
Veolia Response: Should have little to no effect. These type of fuels will probably go
to cement kilns who use these as fuel sources.
8. Are there any hazardous wastes that the facility cannot accept (e.g., pumpable (liquid)
or non-pumpable (solid) waste)? If so, please describe.
Veolia Response: No, the facility can accept drum and bulk liquids, solids and sludges,
along with compressed gases.
Incinerator Capacity
9. What is the currently permitted and available incineration capacity at the facility in tons
(if not provided in tons, please provide the unit of measure and conversion factor for
tons)? This includes all permitted capacity in operation, under construction, not yet
built, etc.
Veolia Response: The total permitted capacity is 69,432 tons per year, however that
number reflects 24 hours of operation per day, 365 days a year.
10. What is the maximum operating capacity of the facility's incinerators (if different from
the amount in Question 9)?
Veolia Response: The practical capacity is approximately 30,000 tons. This is based
on on-stream time, planned shutdowns and waste type availability.
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11. Do you plan on increasing/decreasing the currently permitted and available incineration
capacity under your current permit and, if so, by how much and when?
Veolia Response: No, the permitted capacity will stay the same.
12. When does the facility's RCRA permit need to be renewed? Do you intend to
increase/decrease your incineration capacity under your permit renewal and, if so, by
how much? [This should be additive to the amounts in Questions 9 thru 11.]
Veolia Response: Permit in renewal process currently. No, the permitted capacity will
stay the same.
13. Are there any plans to increase/decrease the incineration capacity at the facility beyond
the amounts in the current permit and next renewal? If so, what is the timeframe and
how much? [This should be additive to the amounts in Questions 9 thru 12.]
Veolia Response: No, the permitted capacity will stay the same.
14. Does the facility plan to continue incineration operations over the next 20 years?
Veolia Response: Yes, the facility plans on operating over the next 20 years.
15. Are there any limitations on your incinerator's operation due to operational or permit
requirements (e.g., metals, CO emissions, Btu values, water content)?
Veolia Response: Yes, Btu, chlorine and metal concentration limits.
16. Do you foresee any significant problems or delays in renewing your permits or
expanding your capacity under RCRA or CAA?
Veolia Response: No
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ATTACHMENT: RCRAINFO PERMIT MODULE DATA FOR
VEOLIA INCINERATOR FACILITY (ILLINOIS)
RCRAInfo Permit Module on Incinerator Capacity - September 16, 2014
Unit Name
Capacity
Capacity
UOM
Capacity
Type
FIXED HEARTH #2
16
MBTU/Hr
Permitted
FIXED HEARTH #3
16
MBTU/Hr
Permitted
TRANSPORTABLE #4
50
MBTU/Hr
Permitted
TOTAL
82
MBTU/Hr
93
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Questions on Incineration Capacity for
Veolia Technical Solutions Facility (Texas)
(EPA ID TXD000838896)
Instructions: Please provide responses to the questions below. The first set of questions asks
about the annual quantity of wastes and materials that you incinerate. The second set asks
about your current and future incineration capacity. Provide responses in the blank space
below each question or on a separate sheet of paper. We will use your input to estimate the
quantity of hazardous waste to be incinerated at your facility and your facility's permitted and
available incineration capacity over the next 20 years. For your assistance, attached is some
RCRAInfo permit module data on your incinerators.
Annual Quantity of Incinerated Wastes and Materials
1. Total Annual Incinerated Quantity: What is the total quantity of all wastes and
materials incinerated by your facility in a typical calendar year? This should include all
federal and state-only hazardous waste, non-hazardous waste, and all other materials.
These wastes and materials are further addressed in Questions 2 through 4.
Veolia Response: Approximately 134,000,000 lbs. (67,000 tons) of wastes and
materials were incinerated in 2013, which approximates a typical year.
2. Based on the 2011 Hazardous Waste Report, your facility incinerated 41,829 tons of
hazardous waste (i.e., 38,862 tons reported on Form WR and 2,967 tons on Form GM).
This is our best estimate of the total quantity of federally regulated hazardous wastes
incinerated. If you also incinerated state-only hazardous wastes, what percent of your
total annual incinerated quantity (as provided in Question 1) do they represent
approximately (e.g., 5%, 10%, negligible)?
Veolia Response: Texas does not have a defined state-only hazardous waste. As a
result 100% of the hazardous waste is also state hazardous waste.
3. Besides hazardous waste, 1) what types of non-hazardous wastes does your facility
incinerate and 2) what percent of your total annual incinerated quantity (as provided in
Question 1) do they represent approximately? This could include, for example, TSCA
waste, municipal waste, medical waste, and other non-hazardous waste.
Veolia Response: The facility accepts and incinerates all types of non-hazardous
wastes including off-specification products, Texas Class 1 - 3 industrial wastes, medical
waste, DEA controlled substances, PCB wastes, and other consumer products. The
facility does not accept municipal garbage. Non-hazardous waste receipts vary but
could represent 10 % - 20 % of the total waste incinerated.
94
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4. Besides the wastes described above, 1) what materials do you incinerate that use up
capacity and 2) what percentage of total annual incinerated quantity (as provided in
Question 1) do they represent approximately?
Veolia Response: The facility incinerates various absorbent materials and carriers
added to bulk solid waste mixtures, which primarily consist of rice hulls and 60/40 clay
sand mixture. Also, the facility utilizes an additive to control slag accumulation, and
occasionally neutralization products are added to certain wastes. The combined
annual total for these additives range from 2,000 - 5,000 tons and comprises
approximately 5% of total annual incinerated quantity. Furthermore, the facility
annually incinerates approximately 150 tons of fuel oil and toluene from line flushing
and 500 tons of fuel as an auxiliary fuel. In addition to all types of materials already
discussed, the incinerator annually uses approximately 250,000 - 300,000 MMBTUs of
natural gas as an auxiliary fuel.
5. For purposes of analysis, we assume that your total annual incinerated quantity in
Question 1 consists entirely of the hazardous wastes described in Question 2, the non-
hazardous wastes in Question 3, and the materials in Question 4. Please ensure that
your estimates in Questions 2 thru 4 approximate (mathematically) the total annual
incinerated quantity in Question 1. If they do not, please clarify why not.
Veolia Response: The total in Question 1 does not include the amount of natural gas
used as an auxiliary fuel. Otherwise, the figures approximately add up but variations
in hazardous and non-hazardous waste designations can affect these figures.
6. Do you expect your total annual incinerated quantity (as provided in Question 1) to
remain steady, grow or decline over the next 20 years? If it will grow or decline, at what
annual rate?
Veolia Response: Slight increase. We are near functional capacity.
7. How will the demand for incineration capacity at your facility be affected by the recent
U.S. Court of Appeals decision to vacate the "comparable fuels rule," which provides an
exclusion from RCRA hazardous waste regulations for certain fuels derived from
hazardous waste?
Veolia Response: The facility maintains adequate capacity in order to accommodate
an increase of waste fuels when or if a demand arises. To date, we have been
contacted by a few companies exploring alternate disposal options for their
comparable fuels; however, these wastes will probably be shipped to cement kilns at
lesser costs due to their high fuel content.
8. Are there any hazardous wastes that the facility cannot accept (e.g., pumpable (liquid)
or non-pumpable (solid) waste)? If so, please describe.
Veolia Response: No, the facility can accept pumpable liquids, solids, containers,
gases, and sludges.
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Incinerator Capacity
9. What is the currently permitted and available incineration capacity at the facility in tons
(if not provided in tons, please provide the unit of measure and conversion factor for
tons)? This includes all permitted capacity in operation, under construction, not yet
built, etc.
Veolia Response: According to NSR Permit 42450, the total permitted capacity of
waste feed and auxiliary fuel is 150,000 tons per year.
10. What is the maximum operating capacity of the facility's incinerators (if different from
the amount in Question 9)?
Veolia Response: The practical capacity is approximately 75,000 -100,000 tons/year.
This is based on on-stream time, planned shutdowns and waste type availability.
11. Do you plan on increasing/decreasing the currently permitted and available incineration
capacity under your current permit and, if so, by how much and when?
Veolia Response: No, the permitted capacity will stay the same.
12. When does the facility's RCRA permit need to be renewed? Do you intend to
increase/decrease your incineration capacity under your permit renewal and, if so, by
how much? [This should be additive to the amounts in Questions 9 thru 11.]
Veolia Response: The application to renew the facility's RCRA Permit (Hazardous
Waste Permit No. 50212) was submitted to TCEQ on August 15, 2014 and did not
include a capacity increase.
13. Are there any plans to increase/decrease the incineration capacity at the facility beyond
the amounts in the current permit and next renewal? If so, what is the timeframe and
how much? [This should be additive to the amounts in Questions 9 thru 12.]
Veolia Response: No, the permitted capacity will stay the same.
14. Does the facility plan to continue incineration operations over the next 20 years?
Veolia Response: Yes, the facility plans on operating over the next 20 years.
15. Are there any limitations on your incinerator's operation due to operational or permit
requirements (e.g., metals, CO emissions, Btu values, water content)?
Veolia Response: The facility's permits establish emission limits for several air
contaminants including but not limited to CO, NOx, and VOCs. The facility's permits
also establish feed rate limits for organic content, organic halogen, metals, total
chlorine, ash, and total mass along with operating parameters for combustion
chamber conditions. The incinerator is also subject to feed rate and emission
limitations established during each Combustor NESHAP Comprehensive Performance
Test (CPT).
96
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16. Do you foresee any significant problems or delays in renewing your permits or
expanding your capacity under RCRA or CAA?
Veolia Response: No
97
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ATTACHMENT: RCRAINFO PERMIT MODULE DATA FOR
VEOLIA INCINERATOR FACILITY (TEXAS)
RCRAInfo Permit Module on Incinerator Capacity - September 16, 2014
Unit Name
Capacity
Capacity
UOM
Capacity
Type
INCINERATOR TRAIN
175,000,000
BTU/Hr
Permitted
98
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Questions on Incineration Capacity for
Ross Environmental Services Inc. Facility (Ohio)
(EPA ID 0HD048415665)
Instructions: Please provide responses to the questions below. The tint set of questions asks about
the Annual quantity of wastes and materials that you incinerate. The second set asks about your
current and future incineration capacity. Provide responses in the blank space below each question
or on a separate sheet of paper. We will use your input to estimate the quantity of hazardous
waste to be incinerated at your facility and your facility's permitted and available incineration
capacity over the next 20 years. For your assistance, attached is some ACRAInfo permit module
data on your incinerators.
Annual Quantity of Incinerated Wastes and Materials
1. Totai Annual Incinerated Quantity What is the total quantity of al wastes and materials
incinerated by your facility in a typical calendar year? The should include all federal and
stale-only hazardous waste, non-hazardous waste, and al other materials. These wastes
and materials are further addressed to Questions 2 through 4.
For the calendar year 2013 - Ross Incineration Senices, Inc. (JUS) mcmeraied ~ 6, JOS. 8 6
com hazardous waste and 4,$44.32 torn non-hazardous waste.
2- Based on the 2011 Hazardous Waste Report, your facility incinerated {.yiSMorts of
hazardous waste (i.e., by.208tons reported on Form WR and H ft oris on Form GM). This is
our best estimate of the total quantity ol federally reyulated hazardous wastes incinerated.
If you also incinerated state-only hazardous wastes, what percent of your total annual
incinerated quantity {as provided in Question 1) do they represent approximately (e.g., 5%,
10%, negligible)?
The state-only hazardous waste mcmeraied atRIS represents approximate!) 2.5', of the
total annuel waste mcmeraied at HIS
3. Besides hazardous waste, 1) what types of non-hazardous wastes does your facility
incinerate and 2) what percent of your total annual incinerated quantity (as provided in
Question 1) do they represent approximately? This could include, for example, TSCA waste,
municipal waste, medical waste, and other non-hazardous waste.
(1) The non-hazardous waste mcmeraied at RIS consists of waste from chemical
manufacturers, automobile manufacturers and intermediary waste managers. Typical
hazardous and non-hazardous waste types received the RIS are: halogenated and non-
halogenated spent soh-ents, pami and adhesn-e-related wastes, contaminated soil, debris,
1
99
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aerosols, aqueous coolant solutions, acidic caustic solutions. off-speqfication commercial
chemical products, consumer products, spill residues, and wastes generated At the
follmmg industries: paint and coarmgs, organic and inorganic chemical adhesh-e,
pesticide, petroleum refining, and the mk formulation industries This list is not all-
inclusive, but represents most categories of waste handled at the RIS faculty. RIS does not
accept dioxm containing waste or explosh-es. Additionally, RIS is not permitted to receh e
TSCA regulated PCBs. radioacthe waste and or infectious wastes.
(2) The non-hazardous waste incinerated at RIS represents approximately 6*. of the total
annual waste incinerated at RIS.
4. Besides the wastes described above, 1) what materials da you incinerate that use up
capacity and 2) what percentage of total annual incinerated quantity (a* provided in
Question 1) do they represent approximately?
None.
5. For purposes of analysis, we assume that your total annual incinerated quantity in Question
1 consists entirely of the hazardous wastes described in Question 2, the non-hazardous
wastes in Question 3, and the materials in Question 4. Please ensure that your estimates in
Questions 2 thru 4 approximate (mathematically I the total annual incinerated quantity in
Question 1. If they do not, please clarify why not.
The estimates in Questions 2 thru J do not mathematically approximate the total annua!
incinerated quantity m Question 1 because Question 91 is based on 2013 total annual
incmeraied quantity and Question *2 is based on 2011 total annua! incinerated quantity\
6. Do you expect your total annual incinerated quantity (as provided in Question 1) to remain
steady, grow or decline over the next 20 years? If it will grow or decline, at what annual
rate?
At this rime, RIS expects its total annual tncmerated quantity to grow slightly
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8. Are there any hazardous wastes that the fadHty cannot accept (e.g.. pumpable (liquid) or
nonpumpaWe (solid) waste)? If so, please describe
RIS accepts liquids, solids end aerosol wastes. RI,S does net accept cylinders of compressed
gases, dioxin containing waste or explosn-es. Additional!} . RIS is not permitted to receive
TSCA regulated PCBs, radioacme waste and or infectious wastes.
Incinerator Capacity
9. What is the currently permitted and available incineration capacity at the facility in tons (if
not provided in tons, please provide the unit of measure and conversion factor for tons|?
This includes all permitted capacity'n operation, under construction, not yet built, etc.
The maximum feed rate to RIS' incineration system is 26,05' pounds per hour andlOSJJO
tons per year, including the weight of the containers
10. What is the maximum operating capacity of the facility's incinerators (H different from the
amount in Question 9)?
So different than Question *9.
11. Do you plan on increasing/decreasing the currently permitted and available incineration
capacity under your current permit and, if so, by how much and when?
At this ame; there are no plans to modtfi the currently permirted and available incineration
capacity at RIS.
12. When does the facility's RCftA permit need to be renewed? Do you intend to
increase/decrease your incineration capacity under your permit renewal and, if so, by how
much? [This should be additive to the amounts in Questions 9 thru 11.)
RIS' Ohio Hazfirdous Waste Facility RCR.1 Part B permit wcj issued on January 29, 201J
and expires on January 29, 292J. RIS' Federal R CR.4 Part B permit was issued on May 23,
2014 end expires on Januaty 29, 202J.
13. Are there any plans to increase/decrease the incineration capacity at the facility beyond die
amounts In the current permit and ne*t renewal? H so, what is the timeframe and how
much? [This should be additive to the amounts in Questions 9 thru 12.)
At this ame. there are no plans to modify the currently permitted and wwiable incineration
capacity at RIS.
3
101
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14. Does the facility plan to continue incineration operations over the next 20 yean?
At this ame, RJS p!ens to continue operation for at leau 29 yeert.
15. Are there any limitations on your incinerator's operation due to operational or permit
requirements [e.g., metals, CO emissions, Btu values, water content}?
To, there are Imitations on RJS' operation due to permit requirements (e.g., meiah).
16. Do you foresee any significant problems or deiarys in renewing your permits or expanding
your capacity under ACRA or CAA?
At this ame, RJS doei nor see any problem or delay in renen mg in RCR.4 Pert B Permit
nor res Tide I'Air Perms.
102
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ATTACHMENT: RCRAINffO PERMIT MODULE DATA FOR
ROSS ENVIRONMENTAL SERVICES INC. FACILITY (OHIO)
RCRAJnio Permrt Module on Incinerator Capacity - September 16, 2014
UnRName
Capacity
Capacity
UOM
Capacity
Type
INCINERATOR
3.30C
Gal-Hr
undefined
S
103
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Questions on Incineration Capacity for
Heritage Thermal Services (Ohio)
(EPA ID OHD980613541)
Instructions: Please provide responses to the questions below. The first set of questions asks
about the annual quantity of wastes and materials that you incinerate. The second set asks
about your current and future incineration capacity. Provide responses in the blank space
below each question or on a separate sheet of paper. We will use your input to estimate the
quantity of hazardous waste to be incinerated at your facility and your facility's permitted and
available incineration capacity over the next 20 years. For your assistance, attached is some
RCRAInfo permit module data on your incinerators.
Annual Quantity of Incinerated Wastes and Materials
1. Total Annual Incinerated Quantity: What is the total quantity of all wastes and
materials incinerated by your facility in a typical calendar year? This should include all
federal and state-only hazardous waste, non-hazardous waste, and all other materials.
These wastes and materials are further addressed in Questions 2 through 4.
The total quantity of material incinerated over the past year was approximately 63,000 tons.
2. Based on the 2011 Hazardous Waste Report, your facility incinerated 42,737 tons of
hazardous waste (i.e., 42,239 tons reported on Form WR and 498 tons on Form GM).
This is our best estimate of the total quantity of federally regulated hazardous wastes
incinerated. If you also incinerated state-only hazardous wastes, what percent of your
total annual incinerated quantity (as provided in Question 1) do they represent
approximately (e.g., 5%, 10%, negligible)?
The percentage of "state-only hazardous waste" would be negligible.
3. Besides hazardous waste, 1) what types of non-hazardous wastes does your facility
incinerate and 2) what percent of your total annual incinerated quantity (as provided in
Question 1) do they represent approximately? This could include, for example, TSCA
waste, municipal waste, medical waste, and other non-hazardous waste.
Some examples of non-hazardous waste incinerated would include off-spec consumer
commodities, non-regulated pharmaceuticals, non-regulated DEA material, non-TSCA <49 ppm
PCB waste, etc. These represent less than five percent of our annual incineration volume.
104
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4. Besides the wastes described above, 1) what materials do you incinerate that use up
capacity and 2) what percentage of total annual incinerated quantity (as provided in
Question 1) do they represent approximately?
To date, no other materials have taken any additional capacity from our operation, so this
percentage would be zero.
5. For purposes of analysis, we assume that your total annual incinerated quantity in
Question 1 consists entirely of the hazardous wastes described in Question 2, the non-
hazardous wastes in Question 3, and the materials in Question 4. Please ensure that
your estimates in Questions 2 thru 4 approximate (mathematically) the total annual
incinerated quantity in Question 1. If they do not, please clarify why not.
Correct
6. Do you expect your total annual incinerated quantity (as provided in Question 1) to
remain steady, grow or decline over the next 20 years? If it will grow or decline, at what
annual rate?
We anticipate a growth rate of 5-10% per year over the next 5 years. This will be accomplished
through permit modifications, asset investments and process improvements.
7. How will the demand for incineration capacity at your facility be affected by the recent
U.S. Court of Appeals decision to vacate the "comparable fuels rule," which provides an
exclusion from RCRA hazardous waste regulations for certain fuels derived from
hazardous waste?
We have the capacity to process a considerable amount of liquids and fuels in bulk and drum
quantities resulting from this ruling.
8. Are there any hazardous wastes that the facility cannot accept (e.g., pumpable (liquid)
or non-pumpable (solid) waste)? If so, please describe.
Please see attached list
Incinerator Capacity
9. What is the currently permitted and available incineration capacity at the facility in tons
(if not provided in tons, please provide the unit of measure and conversion factor for
105
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tons)? This includes all permitted capacity in operation, under construction, not yet
built, etc.
Our RCRA permitted capacity is greater than 88,000 tons/year per incinerator. Facility is
actually permitted for two (2) incinerators - total permitted incineration capacity is 176,000
tons per year.
Our MACT permitted capacity is greater than 35,069 lbs. total waste per hour. For our second
incinerator to be constructed and permitted, HTS would be required to complete CPT to
identify feed rate limits per MACT.
10. What is the maximum operating capacity of the facility's incinerators (if different from
the amount in Question 9)?
98 Million BTUs per hour.
11. Do you plan on increasing/decreasing the currently permitted and available incineration
capacity under your current permit and, if so, by how much and when?
There are no current plans to increase our capacity at this time.
12. When does the facility's RCRA permit need to be renewed? Do you intend to
increase/decrease your incineration capacity under your permit renewal and, if so, by
how much? [This should be additive to the amounts in Questions 9 thru 11.]
Facility submitted its permit renewal 9/23/14. HTS did not request an increase or decrease in
the permitted incineration capacity. The permitted incineration capacity will remain the same,
88,000 tons/year/incinerator.
13. Are there any plans to increase/decrease the incineration capacity at the facility beyond
the amounts in the current permit and next renewal? If so, what is the timeframe and
how much? [This should be additive to the amounts in Questions 9 thru 12.]
No.
14. Does the facility plan to continue incineration operations over the next 20 years?
Yes
15. Are there any limitations on your incinerator's operation due to operational or permit
requirements (e.g., metals, CO emissions, Btu values, water content)?
The Facility must comply with an annual metals emissions limit as described by the RCRA
permit. The incinerator is not equipped with a continuous/semi-continuous flue gas monitoring
106
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device. Therefore, HTS must track all metal emissions limits by tracking the amount of metals
contained in the waste fed into the incinerator.
16. Do you foresee any significant problems or delays in renewing your permits or
expanding your capacity under RCRA or CAA?
HTS does not foresee any significant problem with the RCRA permit renewal. Currently, HTS is
not requesting any incineration capacity increase.
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ATTACHMENT: RCRAINFO PERMIT MODULE DATA FOR
HERITAGE INCINERATOR FACILITY (OHIO)
RCRAInfo Permit Module on Incinerator Capacity - September 16, 2014
Unit Name
Capacity
Capacity
UOM
Capacity
Type
INCINERATOR
97.80
MBTU/Hr
Undefined
108
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Heritage Thermal Services APP-106 Page 1 of 4
WASTE CODES ACCEPTED FOR INCINERATION AT HERITAGE THERMAL SERVICES
(HTS)
Codes that appear in Bold Type indicate that certain restrictions apply The following is a key for the
types of restrictions
DT
The customer must provide analytical results showing that waste earning
FQ39. K043. or K099 meets LDP. treatment standards for dioxins and
furans.
D
Dilution Rule For HTS to accept waste carrying this code, it must be
exempt from the dilution rule as specified in 40 CFR 268,3
HG
Mercury Restrictions: The total mercury content of waste carrying this
code must be less than 260 ppm.
L
Landfill Restrictions One or more of the landfills that HTS uses for
residual disposal does not accept this code. HTS will accept waste
carrying this code for campaign bums.
MR
Metals Recover: The waste code has a specified LDR treatment of Metals
Recovery HTS will only accept this code if the waste has been treated
by a Metals Recovery facility.
S
Stabilization: This code has a specified LDR. treatment technology of
Stabilization- HTS will accept waste earning this code for campaign
bums. The pnee of material with this waste code may be adjusted to
cover the cost of stabilization folio wine incineration
109
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Heritage Thermal Services
APP-ioe
Page 2 of 4
D001
FOW
K030
K099 D T
K174
D002
F0O5
K031
KIOOD
K1"?L
D003
F006 D
K032
K101
K176
D004 D
F007 D
K033
K102
K177
DO0? D
FOOS D
KO 34
K103
K178
DOW D
F009 D
K035
K104
K181L
DOO"* D
F010D
K036
K105
P001
D008 D
F011D
K037
K106D
P002
DOW D
foi: D
K03S
K107
P003
D010 D
F019D
K039
K108
P004
Don p
F024
K040
K109
POOS
D012
F025
K04I
K110
P006
D013
F032
K042
Kill
POO 7
D014
F034
K043 D/F
K112
POOS
D015
FQ35
K044
K113
P009
D016
F037
K045
K114
P010D
D017
F038
K046
K115
P011D
D01S
F039 D F
K047
K116
P012 D
D019
K001
K048
K117
P013 D
D020
K002D
K049
K118
P014
D021
K003 D
K050
K123
P015 MR. D
D022
K004D
K05I
K124
P016
D023
K005D
K052
K125
P017
D024
K006D
K060
K126
P018
D025
K007D
K061D
K131
P020
D026
KOOSD
K062
K132
P021
D027
K009
K064
K136
P022
D028
K010
K065
K141
P023
D029
K011
K066
K142
P024
D030
K013
K069D
K143
P026
D031
K014
K071D
K144
P027
D032
K015
K073
K145
P028
D033
K016
K0S3
K147
P0I9 D
D034
K017
K084
K148
P030
DQ35
K018
K085
K149
P034
D036
K019
K086
K150
P036
D037
K020
K087
K151
P037
D038
K021
K08S L
K156
P038
D039
K022
KQ90
K157
P039
D040
K023
K091
K158
P040
D041
K024
K093
K159
P041
D042
K025
K094
K161
P042
D043
K026
K095
K169
P043
F001
K027
K096
K170
P044
F002
K028
K097
K171
P045
F003
K029
K098
K172
P046
110
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Heritage Thermal Services
APP-106
Page 5 of 4
P047
Pill
U019
U069
U118
P048
PI 13 S, D
U020
U070
U119
P049
P114D
U021
U071
U120
P050
P115S.D
U022
U072
U121
P051
PI 16
U023
U073
U122
P054
PI 18
U024
U074
U123
P057
PI 19 S, D
U025
U076
U124
P058
P120 S.D
U026
U077
U125
P059
P121D
U027
U078
U126
P060
PI 22
U028
U079
U127
P062
P123
U029
U080
U12S
P064
P127
U030
U081
U129
P065 HG
P128
U031
U082
U130
P066
P185
1032 D
U083
U131
P067
PI 88
U034
U084
U132
P06S
PI 89
U035
U085
U133
P069
P190
U036
U086
U134
P070
P191
U037
U087
U136
P071
P192
U03S
U088
U137
P072
PI 94
U039
U089
U138
P073
PI 96
U041
U090
U140
P074
P197
U042
U091
U141
P075
P198
U043
U092
U142
P077
P199
U044
U093
U143
P081
P201
U045
U094
U144
P082
p:o:l
U046
U095
V145 D
P084
P203
U047
U096
U146
P085
P204
U048
U097
U147
P087 \IR. D
P205
U049
U098
U148
P088
U001
U050
U099
U149
P089
U002
U051
U101
U150
P092 HG
U003
U052
U102
1151 HG. D
P093
U004
U053
U103
U152
P094
U005
U055
U105
U153
P097
U006
U056
U106
U154
P098
U007
U057
U107
U155
P099D
U008
U058
U108
U156
P101
U009
U059
U109
U157
PI 02
U010
U060
U110
U158
PI 03
U011
U061
Ulll
U159
P104D
U012
U062
U112
U160
PI 05
L'014
U063
U113
U161
PI 06
U015
U064
U114
U162
P108
U016
U066
U115
U163
PI 09
U017
U067
U116
U164
PI 10
U018
U068
U117
U165
Ill
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Heritage Tbenaai Services
APP-1Q6
Page-* of 4
U166
U217S.D
U167
U218
U168
U219
U169
U220
U170
U221
U171
U222
U172
U223
U173
U225
U174
U226
U176
U227
U177
U228
U178
U234
U179
U235
U1S0
U236
U181
U237
U182
U238
U183
U239
U184
U240
U185
U243
U186
U244
U187
U246
U188
U247
U189
U248
U190
U249
U191
U271
U192
U278
U193
U279
U194
17280
U196
U328
U197
U353
U200
U359
U201
U364
U202
U367
U203
U372
12 04 D
U373
U205 D
U387
U206
U389
U207
U394
U208
U395
U209
U404
U210
U409
U211
U410
U213
U411
V1U s
U215 S
U216 S. D
112
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Tbetmat
APP-10?
rmt 1 of 2
WASTE C ODES NOT AC CEPTED EOR INCINERATION
F020 F026 P033 P07S U033
F021 F027 P056 P095 U075
F022 F02S P063 P096 U135
F023 P031 P076 PI12
WASTES HERITAGE THERMAL SERVICES (HTS) CANNOT ACCEPT
• Chemical Warfare Agent; (CWA) and Other Chemical Weapon; - Warfare agent, or
other chemical weapons or debns generated from the manufacture and or clean-up of
CWA's. These are defined as toxic chemicals and precursors listed m Schedule 1 of the
Chemical Weapons C onvention (CWC) Treaty
• Compressed Gases - Wastes that are gases at standard temperature (6SeF) and standard
pressure {14.7 psia). Other than the following:
o Telomer gas stream,
o Chloro difluoro methane,
o Til fluoro methane.
o Aerosol cans defined as thin walled cans designed to hold liquid, which are less
than a liter m volume The gas may be present only for the purpose of expelling
die liquid m the can.
• Dioxins Furans - Wastes that contain dioxins furans in concentianons above Land
Disposal Restriction (T_DR) treatment standards.
• Infectious waste — Waste that is classified as infectious waste under Ohio EPA
regulation: which is not also a RCRA hazardous waste
• Polychiormated biphenyls (PCBs) - Waste that has a source concentration of PCBs
greater than 50 ppm or is regulated under the Toxic Substance Control Act (TSCA).
• Radioactive Wastes - Waste where the measured radioactivity exceeds background
radiation
• Prion waste, prion contaminated debns. pnon related waste or prion related contaminated
debns.
OTHER RESTRICTIONS
• Asbestos and asbestos waste are accepted for storage and off-site transfer only
• The customer must provide analytical results showing that waste carrying F039. K043. or
K099 meets LDR treatment standards for dioxnis and fiirans.
• Aerosol cans are acceptable for treatment, with some conditions The aerosol cans must
be thin-walled metal containers, one liter or less in volume, and designed to hold liquids.
Also, the gas m die aerosol can must only be used to expel liquid from the container
• Heritage Thermal Services can accept some NFPA Class 1A Flammables. These
materials are volatile liquids that have flash points of less than 73® F and boiling points of
less than I OCT F. These materials must be processed upon receipt may not be stored.
113
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n»ri«aJ Scn co AFP* 107 p^e | of 2
Heritage Thermal Services cannot incinerate wastes subject to the dilution rule (see 40
CFR 26$ 3 and OAC 3745-270-03). Heritage Thermal Services can arrange foi the thud-
party disposal of dilution rule waste.
Additional restrictions may apply to waste streams being processed for off-site transfer
and fuel blending.
All Hg can be accepted mto the facility. High inorganic Hg must be sent to a thud party
facility. Low Hg and organic Hg can be incinerated onstte
Additional restrictions may be placed on wastes that are unusually toxic, reactive, shock
sensitive, temperature sensitive, or explosive. This includes waste carrvms the following
waste codes: P009. P065. P0S1. P105. P122. U017, U023. U096. U133, U142. U160. and
U234.
o Materials shipped as explosive (DOT Class 1) may be approved on a case-by-case
basis only. HTS will accept these in kiln ready charges only aid must be
processed upon receipt
o Materials considered to be shock sensmve must be approved on a case-by-case
basis only. These types of materials must only be approved if the material has
been stabilized m some way as to make them safe to receive, process, and
incinerate
o HTS may receive temperature sensitive materials. Any wastestream with a
control temper ature of less than 100 degrees F. must be received on a refrigerated
van or with sufficient dry ice to maintain the temperature during transport to
below the control temperature These materials must be received in kiln ready
char ges only and be processed upon receipt
o Unusually toxic or reactive materials must be evaluated for receipt on a case-by-
case basis only. These materials must only be approved if the hazards associated
with the toxicity or reactivity can be sufficiently mitigated by the packaging and
handling requirements in place around these waste streams
114
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[Page intentionally left blank.]
115
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Commercial Hazardous Waste Specialty Operations Facilities
116
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[Page intentionally left blank.]
117
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Waste Control Specialists
From: Scott Kirk
Sent: Friday, December 05, 2014 4:56 PM
To: Harris, Joseph
Cc: Rodriguez, Maribelle
Subject: RE: Request for Information
Earl - WCS' RCRA Landfill currently ("as-built") has a capacity of 1,600,000 ft3. We can further expand
the landfill to increase the capacity an additional 41,700,000 ft3. I hope this the information we
discussed this week helps. Let me know if you have any questions.
J. Scott Kirk, CHP, CRSO
Vice President, Licensing and Regulatory Affairs
Waste Control Specialists LLC
From: Harris, Joseph
Sent: Wednesday, December 03, 2014 2:28 PM
To: Rodriguez, Maribelle
Subject: Waste Control Specialists
I just had a quick call with Scott Kirk of Waste Control Specialists. WCS views some of our
questions as business sensitive and will submit responses for those that aren't. He will try to do
so by tomorrow. He clarified that WCS has 4 disposal operations at the Texas facility:
1. Atomic Energy Act (AEA) 11(e)(2) by-product material (i.e., RW or radioactive waste) landfill
2. Federal waste landfill for MW and RW from USDOE only; has a Part B permit
3. Texas Compact disposal facility (commercial RW, no HW or MW)
4. RCRA Subtitle C landfill that receives commercial and DOE MW and HW. To be accepted
for disposal, waste must be below exempt radiation levels as specified by Texas. He
clarified that a customer doesn't need to be a radioactive waste customer to ship
HW. Anyone can ship HW.
He confirmed that the 2011 HWR's tons of landfilled waste is correct. He said that it includes
both MW and HW. I asked him to break out these respective quantities in his response if
possible.
118
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Questions on Landfill Capacity for
EnergySolutions
(EPA ID UTD982598898)
1. What types of wastes is the facility permitted to accept for landfill disposal?
The facility is permitted to accept mixed wastes. All wastes must be radioactive; Class A.
2. Is the facility permitted to accept dioxin and elemental mercury wastes?
Yes, the facility is permitted to accept dioxin (F020), mercury, and PCB wastes, as long as they
have a radioactive component.
3. Are there any wastes that the facility cannot accept?
Non-radioactive wastes, wastes hotter than Class A, and explosive wastes.
4. What is the currently permitted and available capacity at the facility (in tons, if
possible; if not, ask for conversion factor)?
The currently permitted capacity is 1,353,004 cubic yards. The remaining permitted capacity is
349,569 cubic yards, which includes some capacity that has not been constructed. The facility
plans to construct this additional capacity within the next 2 years.
To convert to tons, the average conversion factor to be used is 120 pounds/cubic foot.
5. When does the permit need to be renewed? Does the facility plan to renew the permit
successively over the next 20 years?
The facility is currently going through the permit renewal process. The facility is currently
waiting for final approval. The permit renewal cycle is 10 years.
Over 95% sure that the facility will renew the permit after 10 years.
6. How much additional capacity would be available under the new permit?
Not planning to add more capacity at the moment, unless the market indicates they have to.
The facility added about 15% capacity about 2 years ago. They believe that the remaining
permitted capacity will last for at least 5 years.
7. What is the available capacity in the currently lined and operating cells that have a
permit (in tons, if possible; if not, ask for conversion factor)?
The currently available capacity is about 164,000 cubic yards.
119
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8. What is the remaining life of the currently lined and operating cells that have a
permit?
The currently available capacity might last another 2 years or more.
9. How does the addition of soil to each layer of waste and the quantity of non-
hazardous waste accepted at the facility (and stabilization materials) affect the
remaining available capacity? Are these factors taken into account in the available
capacity estimate provided?
The facility compacts waste and then puts the waste in the landfill. If disposing of debris, then
the facility adds soil to help with compaction. About 75% of the available capacity is for waste
and the remaining 25% is for fill-type material (e.g., soil, concrete).
10. What is the average density of your disposed materials?
About 120 pounds/cubic foot.
11. Are there any plans to expand the landfill capacity at the facility? If so, what is the
timeframe?
Of the 349,569 cubic yards of remaining permitted capacity, there are about 185,000 cubic
yards that still need to be constructed. There are plans to construct this capacity within the next
year or two.
12. Do you have a projection on the amount/volume of waste to be accepted over the
coming 20 years? Next year?
Amount disposed in landfill in 2012 was about 2,000 tons; in 2013, about 3,550 tons; and,
through September 2014, 962 tons.
The facility expects to accept about 2,000 tons/year over the next 20 years.
13. Do you see a straight-line on the quantity of wastes to be received over next 20
years? Growth rate?
Straight line; 2,000 tons per year over the next 20 years.
120
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Questions on Incineration Capacity for
Reynolds Metals Company Gum Springs Plant
(EPA ID ARD006354161)
Instructions: Please provide responses to the questions below. The first set of questions asks
about the annual quantity of wastes and materials that you incinerate. The second set asks
about your current and future incineration capacity. Provide responses in the blank space
below each question or on a separate sheet of paper. We will use your input to estimate the
quantity of hazardous waste to be incinerated at your facility and your facility's permitted and
available incineration capacity over the next 20 years. For your assistance, attached is some
RCRAInfo permit module data on your incinerators.
Annual Quantity of Incinerated Wastes and Materials
1. Total Annual Incinerated Quantity: What is the total quantity of all wastes and
materials incinerated by your facility in a typical calendar year? This should include all
federal and state-only hazardous waste, non-hazardous waste, and all other materials.
These wastes and materials are further addressed in Questions 2 through 5.
Response: 120,000 tons/yr
2. Of the total annual incinerated quantity of wastes and materials in Question 1, what
percentage is comprised of federally regulated hazardous waste?
Response: 100%
3. If you also incinerated state-only hazardous wastes, what percent of your total annual
incinerated quantity as provided in Question 1 do they represent approximately (e.g.,
5%, 10%, negligible)?
Response: 0%
4. Besides federal and state hazardous waste, 1) what types of non-hazardous wastes
does your facility incinerate and 2) what percent of your total annual incinerated
quantity (as provided in Question 1) do they represent approximately? This could
include, for example, TSCA waste, municipal waste, medical waste, and other non-
hazardous waste
Response: 0%
5. Besides the wastes described above, 1) what materials do you incinerate that use up
capacity and 2) what percentage of total annual incinerated quantity (as provided in
Question 1) do they represent approximately?
Response: 0%
121
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6. For purposes of analysis, we assume that your total annual incinerated quantity in
Question 1 consists entirely of the federal hazardous wastes in Question 2, state-only
hazardous wastes in Question 3, the non-hazardous wastes in Question 4, and the
materials in Question 5. Please ensure that your estimates in Questions 2 thru 5
approximate (mathematically) the total annual incinerated quantity in Question 1. If
they do not, please clarify why not.
7. Do you expect your total annual incinerated quantity (as provided in Question 1) to
remain steady, grow or decline over the next 20 years?
Response: Grow
If it will grow or decline, at what annual rate?
Response: Due to recent regulatory permit modification activity to allow for
incineration of an additional waste feed (high water content waste) with additional
associated waste codes and plans to construct additional tanks/feed system to process
the waste, we expect to increase treatment by approximately 10%/yr for the next 2 yrs.
8. How will the demand for incineration capacity at your facility be affected by the recent
U.S. Court of Appeals decision to vacate the "comparable fuels rule," which provides an
exclusion from RCRA hazardous waste regulations for certain fuels derived from
hazardous waste?
Response: Potentially increase demand for capacity
9. Are there any hazardous wastes that the facility cannot accept (e.g., pumpable (liquid)
or non-pumpable (solid) waste)? If so, please describe.
Incinerator Capacity
10. What is the currently permitted and available incineration capacity at the facility in tons
(if not provided in tons, please provide the unit of measure and conversion factor for
tons)? This includes all permitted capacity in operation, under construction, not yet
built, etc.
Response:
120,000 tons/yr of listed waste code K088 (spent potliner from aluminum smelting
process;
21,900 tons/yr (2 kilns, permitted feed is 5 gal/min/kiln) of onsite generated landfill
leachate and decontamination water waste code D002, K088 & F039);
42,000 tons/yr (2 kilns, permitted feed is 10 gal/min/kiln) of high water content waste -
see attached listing of acceptable waste codes.
11. What is the maximum operating capacity of the facility's incinerators (if different from
the amount in Question 10)?
Response: Same as above
122
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12. Do you plan on increasing/decreasing the currently permitted and available incineration
capacity under your current permit and, if so, by how much and when?
Response: Potentially increase pending future investigations to identify waste streams
compatible with facility's unique incineration system. Amount or when not determined
at this time.
13. When does the facility's RCRA permit need to be renewed?
Response: June 2020
Do you intend to increase/decrease your incineration capacity under your permit
renewal and, if so, by how much? [This should be additive to the amounts in Questions
10 thru 12.]
Response: None anticipated at this time.
14. Are there any plans to increase/decrease the incineration capacity at the facility beyond
the amounts in the current permit and next renewal? If so, what is the timeframe and
how much? [This should be additive to the amounts in Questions 10 thru 13.]
Response: None anticipated at this time.
15. Does the facility plan to continue incineration operations over the next 20 years?
Response: Yes
16. Are there any limitations on your incinerator's operation due to operational or permit
requirements (e.g., metals, CO emissions, Btu values, water content)?
Response: Significant number of constituent concentration feedrate limits associated
with potential air emissions.
17. Do you foresee any significant problems or delays in renewing your permits or
expanding your capacity under RCRA or CAA?
Response: None anticipated at this time.
123
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ATTACHMENT: RCRAINFO PERMIT MODULE DATA FOR
REYNOLDS METALS COMPANY GUM SPRINGS PLANT
RCRAInfo Permit Module on Incinerator Capacity - September 16, 2014
Unit Name
Capacity
Capacity
UOM
Capacity
Type
INCIN
60
T/Hr
Permitted
124
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ACCEPTABLE WASTE CODES
D001
F001
K001
K051
K132
U001
U047
U093
U140
U185
U239
D002
F002
K002
K052
K136
U002
U048
U094
U141
U186
U240
D004
F003
K003
K060
K141
U003
U049
U095
U142
U187
U243
D005
F004
K004
K061
K142
U004
U050
U096
U143
U188
U244
D006
F005
K005
K062
K143
U005
U051
U097
U144
U189
U246
D007
F006
K006
K069
K144
U006
U052
U098
U145
U190
U247
D008
F007
K007
K071
K145
U007
U053
U099
U146
U191
U248
D009
F008
K008
K073
K147
U008
U055
U101
U147
U192
U249
D010
F009
K009
K083
K148
U009
U056
U102
U148
U193
U271
D011
F010
K010
K084
K149
U010
U057
U103
U149
U194
U278
D012
F011
K011
K085
K150
U011
U058
U105
U150
U196
U279
D013
F012
K013
K086
K151
U012
U059
U106
U197
U280
D014
F019
K014
K087
U014
U060
U107
U152
U200
U328
D015
F024
K015
K088
U015
U061
U108
U153
U201
U353
D016
F025
K016
K093
U016
U062
U109
U154
U202
U359
D017
F032
K017
K094
U017
U063
U110
U155
U203
U364
D018
F034
K018
K095
U018
U064
U111
U156
U204
U367
D019
F035
K019
K096
K169
U019
U066
U112
U157
U205
U372
D020
F037
K020
K097
K170
U020
U067
U113
U158
U206
U373
D021
F038
K021
K098
K171
U021
U068
U114
U159
U207
U387
D022
F039
K022
K100
K172
U022
U069
U115
U160
U208
U389
D023
K023
K101
K175
U023
U070
U116
U161
U209
U394
D024
K024
K102
K176
U024
U071
U117
U162
U210
U395
D025
K025
K103
K177
U025
U072
U118
U163
U211
U404
D026
K026
K104
U026
U073
U119
U164
U213
U409
D027
K027
K105
U027
U074
U120
U165
U214
U410
D028
K028
K106
U028
U075
U121
U166
U215
U411
D029
K029
K107
U029
U076
U122
U167
U216
D030
K030
K108
U030
U077
U123
U168
U217
D031
K031
K109
U031
U078
U124
U169
U218
D032
K033
K110
U032
U079
U125
U170
U219
D033
K034
K111
U033
U080
U126
U171
U220
D034
K035
K112
U034
U081
U127
U172
U221
D035
K036
K113
U035
U082
U128
U173
U222
D036
K037
K114
U036
U083
U129
U174
U223
D037
K039
K115
U037
U084
U130
U176
U225
D038
K040
K116
U038
U085
U131
U177
U226
D039
K041
K117
U039
U086
U132
U178
U227
D040
K042
K118
U041
U087
U133
U179
U228
D041
K043
K123
U042
U088
U134
U180
U234
D042
K046
K124
U043
U089
U135
U181
U235
D043
K048
K125
U044
U090
U136
U182
U236
K049
K126
U045
U091
U137
U183
U237
K050
K131
U046
U092
U138
U184
U238
125
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Questions on Incineration Capacity for
EBV Explosives Environmental Co.
(EPA ID MOD985798164)
Instructions: Please provide responses to the questions below. The first set of questions asks
about the annual quantity of wastes and materials that you incinerate. The second set asks
about your current and future incineration capacity. Provide responses in the blank space
below each question or on a separate sheet of paper. We will use your input to estimate the
quantity of hazardous waste to be incinerated at your facility and your facility's permitted and
available incineration capacity over the next 20 years. For your assistance, attached is some
RCRAInfo permit module data on your incinerators.
Annual Quantity of Incinerated Wastes and Materials
1. Total Annual Incinerated Quantity: What is the total quantity of all wastes and
materials incinerated by your facility in a typical calendar year? This should include all
federal and state-only hazardous waste, non-hazardous waste, and all other materials.
These wastes and materials are further addressed in Questions 2 through 4.
6,169 tons in 2013
2. Based on the 2011 Hazardous Waste Report, your facility incinerated 1,715 tons of
hazardous waste (reported on Form WR). This is our best estimate of the total quantity
of federally regulated hazardous wastes incinerated. If you also incinerated state-only
hazardous wastes, what percent of your total annual incinerated quantity (as provided
in Question 1) do they represent approximately (e.g., 5%, 10%, negligible)?
0%
3. Besides hazardous waste, 1) what types of non-hazardous wastes does your facility
incinerate and 2) what percent of your total annual incinerated quantity (as provided in
Question 1) do they represent approximately? This could include, for example, TSCA
waste, municipal waste, medical waste, and other non-hazardous waste.
<2% other non-hazardous wastes
4. Besides the wastes described above, 1) what materials (i.e., non-wastes) do you
incinerate that use up capacity and 2) what percentage of total annual incinerated
quantity (as provided in Question 1) do they represent approximately?
<5% other non-wastes
5. For purposes of analysis, we assume that your total annual incinerated quantity in
Question 1 consists entirely of the hazardous wastes described in Question 2, the non-
hazardous wastes in Question 3, and the materials in Question 4. Please ensure that
your estimates in Questions 2 thru 4 approximate (mathematically) the total annual
incinerated quantity in Question 1. If they do not, please clarify why not.
126
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6. Do you expect your total annual incinerated quantity (as provided in Question 1) to
remain steady, grow or decline over the next 20 years? If it will grow or decline, at what
annual rate?
Unknown - totally dependent on ammunition demil contracts from the US Army
7. How will the demand for incineration capacity at your facility be affected by the recent
U.S. Court of Appeals decision to vacate the "comparable fuels rule," which provides an
exclusion from RCRA hazardous waste regulations for certain fuels derived from
hazardous waste?
No affect
8. Are there any hazardous wastes that the facility cannot accept (e.g., pumpable (liquid)
or non-pumpable (solid) waste)? If so, please describe.
We only accept explosive related wastes and only in containers & 55 gal drum or smaller
Incinerator Capacity
9. What is the currently permitted and available incineration capacity at the facility in tons
(if not provided in tons, please provide the unit of measure and conversion factor for
tons)? This includes all permitted capacity in operation, under construction, not yet
built, etc.
3,055 Ibs/hr X 7,800 hours = 11,900 tons in RKI
10,000 lbs/batch X 6 batchs/day X 365 days/yr = 10,950tons in CBF
10. What is the maximum operating capacity of the facility's incinerators (if different from
the amount in Question 9)?
7,500 tons for RKI & 5,000 tons for CBF
11. Do you plan on increasing/decreasing the currently permitted and available incineration
capacity under your current permit and, if so, by how much and when?
No
12. When does the facility's RCRA permit need to be renewed? Do you intend to
increase/decrease your incineration capacity under your permit renewal and, if so, by
how much? [This should be additive to the amounts in Questions 9 thru 11.]
Renewal submitted Oct 2012
13. Are there any plans to increase/decrease the incineration capacity at the facility beyond
the amounts in the current permit and next renewal? If so, what is the timeframe and
how much? [This should be additive to the amounts in Questions 9 thru 12.]
No
14. Does the facility plan to continue incineration operations over the next 20 years?
Yes
127
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15. Are there any limitations on your incinerator's operation due to operational or permit
requirements (e.g., metals, CO emissions, Btu values, water content)?
Yes
16. Do you foresee any significant problems or delays in renewing your permits or
expanding your capacity under RCRA or CAA?
No
128
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ATTACHMENT: RCRAINFO PERMIT MODULE DATA FOR
EBV Explosives Environmental Co.
RCRAInfo Permit Module on Incinerator Capacity - September 16, 2014
Unit Name
Capacity
Capacity
UOM
Capacity
Type
CAR BOTTOM FURNACE
10,005
LB/Hr
Permitted
ROTARY KILN
2,454
LB/Hr
Permitted
129
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Appendix B
Commercial Hazardous Waste Management Facilities
130
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131
-------
Commercial Hazardous Waste Management
Facilities
This appendix lists all facilities that managed RCRA hazardous
waste commercially. The list is based on 2011 BR data that
were updated by the states because some facilities opened or
closed between-2011 and 2014. These facilities comprise the
capacity for the 2014 national capacity assessment. The list
includes Subtitle C permitted and interim status facilities, and
RCRA-exempt facilities. Four facilities on the list are
considered having specialty management operations because
the permits designate capacity for specific wastes by form,
waste code, waste types, etc. The capacity analyses for the
RECOVERY
Metals Recovery
H010 Metals recovery including retorting, smelting, chemical, etc.
Solvents Recovery
H020 Solvents recovery (distillation, extraction, etc.)
Inorganics Recovery
H039 Other recovery or reclamation for reuse including acid regeneration, organics
recovery, etc. (specify in comments)
Energy Recovery
H050 Energy recovery at this site - used as fuel (includes on-site fuel blending before
energy
recovery; report only this code)
TREATMENT
Fuel Blending
H061 Fuel blending prior to energy recovery at another site (waste generated either
on-site or received from off-site)
Incineration
H040 Incineration - thermal destruction other than use as a fuel (includes any
preparation prior to
burning)
Wastewater Treatment
132
specialty operations are presented in Appendix E. The type of
management at each facility is identified by CAP management
category. Each CAP management category is comprised of a
number of waste management technologies that are generally
interchangeable for managing broad types of wastes (e.g.,
organics, inorganics including metals, and wastewaters),
based on treatment performance. The CAP management
categories are comprised of the following management
method codes, as defined in the U.S. Environmental
Protection Agency's 2011 Hazardous Waste Report,
Instructions and Forms, EPA Form 8700-13 A/B, pp. 71-72,
December 2011 (available at:
http://www.epa.gov/osw/inforesources/data/br11/br2011 rpt.pdf
H071 Chemical reduction with or without precipitation (includes any preparation or
final processes for consolidation of residuals)
H073 Cyanide destruction with or without precipitation (includes any preparation or
final processes for consolidation of residuals)
H075 Chemical oxidation (includes any preparation or final processes for
consolidation of residuals)
H076 Wet air oxidation (includes any preparation or final processes for consolidation
of residuals)
H077 other chemical precipitation with or without pre-treatment (includes processes
for consolidation of residuals)
H081 Biological treatment with or without precipitation (includes any preparation or
final processes for consolidation of residuals)
H082 Adsorption (as the major component of treatment)
H083 Air or steam stripping (as the major component of treatment)
H103 Absorption (as the major component of treatment)
H121 Neutralization only (no other treatment)
H122 Evaporation (as the major component oftreatment; not reportable as H071-
H083)
H123 Settling or clarification (as the major component oftreatment; not reportable as
H071-H083)
H124 Phase separation (as the major component oftreatment; not reportable as
H071-H083)
H129 Other treatment (specify in comments; not reportable as H071-H124)
-------
Sludge Treatment/ Stabilization/Encapsulation
H101 Sludge treatment and/or dewatering (as the major component of treatment; not
H071-H075, H077, or H082)
H111 Stabilization or chemical fixation prior to disposal at another site (as the major
component of treatment; not H071-H075, H077, or H082)
H1. _ Macro-encapsulation prior to disposal at another site (as the major component
of treatment; not reportable as H071-H075, H077, or H082)
DISPOSAL
Land Treatment or Application
H131 Land treatment or application (to include any prior treatment and/or
stabilization)
Landfill
H132 Landfill or surface impoundment that will be closed as landfill (to include prior
treatment
and/or stabilization)
133
Deepwell or Underground Injection
H134 Deepwell or underground injection (with or without treatment; this waste was
counted as hazardous waste)
Transfer/Storage
H141 The site receiving this waste stored/bulked and transferred the waste with no
treatment or recovery (H010-H129), fuel blending (H061), or disposal (H131-
H135) at that receiving site
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
EPA Region 1
CTD000604488
CLEAN HARBORS OF CT
INC
X
X
CTD002593887
BRIDGEPORT UNITED
RECYCLING
X
X
CTD021816889
UNITED OIL RECOVERY
INC
X
X
CTD058509712
DYNO NOBEL INC
X
MA5000004713
VEOLIA ES TECHNICAL
SOLUTIONS LLC
X
MAD019371079
GENERAL CHEMICAL
CORPORATION
X
MAD039322250
CLEAN HARBORS
ENVIRONMENTAL
SERVICES INC
X
MAD047075734
TRIUMVIRATE
ENVIRONMENTAL
MERRIMACK INC
X
X
X
MAD052629979
GLINES & RHODES INC
X
MAD053452637
CLEAN HARBORS OF
BRAINTREE
X
X
X
X
MAD060095569
SAFETY KLEEN
SYSTEMS INC
X
MAD062179890
ENVIRONMENTAL
COMPLIANCE
CORPORATION
X
MAD088978143
SAFETY-KLEEN
SYSTEMS INC
X
MAD096287354
SAFETY-KLEEN
SYSTEMS INC
X
MAD980915755
COMPLETE RECYCLING
SOLUTIONS LLC
X
MAR000008375
ECOLOGY RECOVERY
SYSTEM INC
X
MED019051069
ENPRO SERVICES OF
MAINE, INC.
X
X
NHD510177926
COLT REFINING INC
X
134
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
RID040098352
NORTHLAND
ENVIRONMENTAL LLC
X
X
X
X
RID050322130
KELLEY METALS CORP
X
RID059735761
ADVANCED CHEMICAL
COMPANY
X
RID084802842
SAFETY-KLEEN SYTEMS
INC
X
X
X
X
RID095978995
GEIB REFINING CORP
X
RID980906986
21ST CENTURY
ENVIRONMENTAL MGMT
INC
X
RID981886104
GANNON AND SCOTT
INC.
X
VTD000791699
SAFETY-KLEEN
SYSYEMS, INC
X
EPA Region 2
NJD000768101
SAFETY KLEEN
SYSTEMS INC
X
NJD002182897
SAFETY-KLEEN
SYSTEMS INC
X
X
X
X
NJD002200046
CYCLECHEM INC
X
X
X
X
X
NJD002454544
VEOLIA ES TECHNICAL
SOLUTIONS LLC
X
X
X
X
NJD011370525
G & S MOTOR
EQUIPMENT CO
X
NJD980536593
VEOLIA ES TECHNICAL
SOLUTIONS LLC
X
NJD980755367
JOHNSON MATTHEY INC
X
NJD982270506
SAFETY KLEEN
SYSTEMS INC
X
NJD991291105
CLEAN EARTH OF
NORTH JERSEY
X
X
X
X
X
X
NYD000688630
NEXEO SOLUTIONS
TONAWANDA
X
NYD002082519
AMES GOLDSMITH CORP
X
NYD002113736
TULIP CORPORATION
X
135
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
NYD013277454
SOLVENTS &
PETROLEUM SERVICE
INC
X
X
NYD030485288
REVERE SMELTING &
REFINING
CORPORATION
X
NYD049253719
ASHLAND DISTRIBUTION
CO
X
NYD049836679
CWM CHEMICAL
SERVICES LLC
X
X
X
X
NYD067919340
SABIN METAL CORP
X
X
NYD077444263
TRIUMVIRATE
ENVIRONMENTAL
X
NYD080469935
NORLITE LLC
X
NYD082785429
CHEMICAL POLLUTION
CONTROL
X
NYD980592497
EASTMAN KODAK
COMPANY
X
NYD980753784
SAFETY - KLEEN
SYSTEMS INC
X
NYD981556541
SAFETY-KLEEN
SYSTEMS INC
X
NYD982743312
SAFETY-KLEEN
SYSTEMS INC
X
NYD986872869
SAFETY-KLEEN
SYSTEMS INC
X
NYR000129015
AMERICAN LAMP
RECYCLING LLC
X
PRD090399718
SAFETY-KLEEN
ENVIROSYSTEMS CO OF
PR INC
X
X
EPA Region 3
MDD980555189
CLEAN HARBORS OF
BALTIMORE INC.
X
X
X
X
X
MDR000518423
ACM TECHNOLOGIES
INC
X
PA0000453084
BETHLEHEM
APPARATUS CO INC
X
136
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
PAD000736942
CALGON CARBON CORP
X
X
PAD000738823
SAFETY-KLEEN
SYSTEMS INC
X
PAD000738849
SAFETY-KLEEN
SYSTEMS INC
X
PAD002330165
EAST PENN
MANUFACTURING CO
INC
X
PAD002365849
ABINGTON RELDAN
METALS LLC
X
PAD002389559
KEYSTONE CEMENT CO
X
PAD002390961
BETHLEHEM
APPARATUS CO INC
X
PAD002395887
HORSEHEAD CORP
X
PAD004835146
MAX ENVIRONMENTAL -
YUKON FACILITY
X
X
PAD010154045
ENVIRITE OF
PENNSYLVANIA INC
X
X
X
X
PAD067098822
CYCLECHEM INC
X
X
PAD085690592
REPUBLIC
ENVIRONMENTAL
SYSTEMS (PA) LLC
X
X
X
X
PAD086673407
SAFETY-KLEEN
SYSTEMS INC
X
PAD087561015
INMETCO
X
PAD089352983
COOKSON
ELECTRONICS
X
PAD981038227
WORLD RESOURCES CO
X
PAD981736143
SAFETY KLEEN
SYSTEMS INC
X
PAD981737109
SAFETY-KLEEN
SYSTEMS INC
X
PAD981945157
VEOLIA ES TECHNICAL
SOLUTIONS
X
PAD982576258
SAFETY-KLEEN
SYSTEMS INC
X
137
-------
Commercial Hazardous Waste Management Facilities
RECOVERY
TREATMENT
DISPOSAL
EPA ID
Facility Name
TRANSFER/
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
STORAGE
PAD987266715
SAFETY-KLEEN
SYSTEMS INC
X
PAD9872 70725
SIEMENS INDUSTRY INC
X
PAD987367216
AERC.COM INC
X
PAD990753089
EXIDE TECHNOLOGIES
X
PAR000518225
ECOFLO INC
X
PAR000521294
ABINGTON RELDAN
METALS LLC
X
PAR000522763
CD & E REFINING LLC
X
PAR000528026
CD & E REFINING LLC
X
VAD000737346
SAFETY-KLEEN
SYSTEMS, INC
X
VAD000737361
SAFETY-KLEEN
SYSTEMS, INC
X
VAD105838874
KMX CHEMICAL CORP.
X
VAD981043011
SAFETY-KLEEN
SYSTEMS, INC
X
VAR000503656
BLUE RIDGE SOLVENTS
& COATINGS, INC.
X
WVD076826015
HUNTINGTON ALLOYS
CORPORATION
X
WVD981034101
SAFETY-KLEEN
SYSTEMS INC
X
WVR000500801
VEOLIA ES TECHNICAL
SOLUTIONS
X
EPA Region 4
ALD000622464
CHEMICAL WASTE
MANAGEMENT
X
X
X
X
ALD046481032
SANDERS LEAD
COMPANY, INC
X
ALD070513767
GIANT RESOURCE
RECOVERY- ATTALLA,
INC.
X
X
ALD094476793
ALLWORTH, LLC
X
X
138
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
ALD980837959
MULTIMETCO INC
X
ALD981020894
EWS ALABAMA INC.
X
X
ALD981475304
KW PLASTICS
X
ALR000042754
STEEL DUST
RECYCLING, LLC
X
ALR000047167
M3 RESOURCES USA
LLC
X
FL0000207449
VEOLIA ES TECHNICAL
SOLUTIONS, L.L.C.
X
FL0000702985
STERICYCLE SPECIALTY
WASTE SOLUTIONS INC
X
FLD004092839
ENVIROFOCUS
TECHNOLOGIES
X
FLD980559728
TRIUMVIRATE
ENVIRONMENTAL INC
X
FLD980711071
PERMA-FIX OF FLORIDA,
INC.
X
X
FLD980729610
CLEAN HARBORS
FLORIDA
X
X
X
FLD980847214
SAFETY - KLEEN
SYSTEMS INC
X
FLD981932494
EQ FLORIDA, INC.
X
X
FLD982133159
SAFETY - KLEEN
SYSTEMS INC
X
FLD984262782
AERC.COM, INC.
X
X
GAD000776781
SAFETY-KLEEN
SYSTEMS, INC
X
GAD093380814
PERMA-FIX OF SOUTH
GEORGIA
X
X
X
X
GAD980709257
SAFETY-KLEEN
SYSTEMS, INC.
X
GAD980842777
SAFETY-KLEEN
SYSTEMS, INC.
X
GAD981265424
SAFETY-KLEEN
SYSTEMS, INC
X
KYD005009923
CALGON CARBON
CORPORATION
X
X
139
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
KYD053348108
SAFETY-KLEEN
SYSTEMS, INC.
X
X
X
X
KYD981027469
SAFETY-KLEEN
SYSTEMS, INC
X
KYD985073196
AES ENVIRONMENTAL,
LLC
X
X
X
MSD077655876
HOLCIM (US)
INC/GEOCYCLE LLC
X
X
NCD000648451
CLEAN HARBORS
REIDSVILLE, LLC
X
NCD000776740
SAFETY-KLEEN
SYSTEMS, INC
X
NCD049773245
DETREX CORPORATION
X
X
X
NCD061263315
NEXEO SOLUTIONS, LLC
X
NCD077840148
SAFETY-KLEEN
SYSTEMS, INC
X
NCD079060059
SAFETY-KLEEN
SYSTEMS, INC
X
NCD095119210
METALLIX REFINING INC.
X
NCD121700777
DART ACQUISITIONS,
LLC
X
X
NCD980842132
ECOFLO.INC.
X
X
X
X
X
NCD980846935
SAFETY-KLEEN
SYSTEMS, INC
X
NCD986166338
VEOLIA ES TECHNICAL
SOLUTIONS, LLC
X
NCS000000545
EDEN CUSTOM
PROCESSING
X
NCS000001221
VEOLIA ES TECHNICAL
SOLUTIONS LLC
X
NCS000001677
PSC
X
SCD003351699
GIANT CEMENT
COMPANY
X
SCD003368891
HOLCIM US INC
GEOCYCLE LLC
X
X
X
SCD036275626
GIANT RESOURCE
RECOVERY SUMTER INC
X
X
X
140
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
SCD077995488
SAFETY KLEEN
SYSTEMS INC
LEXINGTON
X
SCD981866007
BASF CORP
X
SCR000771618
HORSEHEAD
RECYCLING
X
TND000614321
SAFETY-KLEEN (GS) INC.
X
TND000646612
HERAEUS PRECIOUS
METALS, NORTH
AMERICA
X
TND000772186
TRADEBE TREATMENT &
RECYCLING OF
TENNESSEE, LLC
X
X
TND980847024
EXCEL TSD INC
X
X
TND981920119
VLS - ARMOR LLC
X
TND982109142
DIVERSIFIED SCIENTIFIC
SERVICES INC. (DSSI)
X
X
X
TND982144099
HORSEHEAD
CORPORATION
X
TND982157570
DURATEK SERVICES,
INC., AN
ENERGYSOLUTIONS
COMPANY
X
TNR000005397
EAST TENNESSEE
MATERIALS & ENERGY
CORPORATION
X
X
TNR000022277
MASTERMELT AMERICA,
LLC
X
TNR000023234
SOUTHEAST RECYCLING
TECHNOLOGIES, INC.
X
TNR000031203
STERICYCLE SPECIALTY
WASTE SOLUTIONS INC
X
EPA Region 5
ILD000666206
ENVIRITE OF ILLINOIS
INC
X
X
X
ILD000805812
PEORIA DISPOSAL
COMPANY
X
141
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
ILD000805911
SAFETY-KLEEN
SYSTEMS INC
X
ILD005087630
SIMS RECYCLING
SOLUTIONS INC
X
ILD005121439
SIPI METALS CORP
X
ILD005450697
CLEAN HARBORS RSC
LLC
X
X
ILDO10284248
CID RECYCLING &
DISPOSAL FAC
X
ILD040891368
HORSEHEAD CORP
X
ILD064418353
BEAVER OIL CO INC
X
X
X
ILD098642424
VEOLIA ES TECHNICAL
SOLUTIONS
X
X
X
ILD980613913
SAFETY KLEEN
SYSTEMS INC
X
X
X
X
X
X
ILD981088388
SAFETY-KLEEN
SYSTEMS INC
X
ILD981097819
SAFETY-KLEEN
SYSTEMS INC
X
IN0000351387
LIGHTING RESOURCES
INC
X
IND000199653
QUEMETCO, INC.
X
IND000646943
TRADEBE TREATMENT &
RECYCLING LLC
X
X
X
IND000717959
EXIDE TECHNOLOGIES
X
IND000780403
RECLAIMED ENERGY
DIV., SUPERIOR OIL CO.,
INC.
X
X
X
IND005081542
ESSROC CEMENT
CORPORATION
X
IND006419212
LONE STAR
GREENCASTLE WDF
X
IND085616837
PARTS CLEANING
TECHNOLOGIES LLC
X
IND093219012
HERITAGE
ENVIRONMENTAL
SERVICES LLC
X
X
X
X
X
142
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
IND980503890
HERITAGE
ENVIRONMENTAL
SERVICES LLC
X
INR000110197
STERICYCLE, INC.
X
MID000724831
MICHIGAN DISPOSAL INC
X
X
X
X
X
X
MID005338801
GAGE PRODUCTS CO
X
MID029631686
VESCO OIL CORP
X
MID048090633
WAYNE DISPOSAL INC
X
X
MID060975844
EQ RESOURCE
RECOVERY INC
X
MID074259565
DYNECOL INC
X
X
X
MID091605972
DETREX CORP
X
MID092947928
DRUG AND
LABORATORY DISPOSAL
INC
X
MID980615298
PETRO-CHEM
PROCESSING GROUP OF
NORTRU LLC
X
X
X
X
MID980991566
EQ DETROIT INC
X
X
X
X
MID985568021
CHEMICAL ANALYTICS
INC
X
MIR000047092
VESCO OIL
CORPORATION
X
MND000686709
NEXEO SOLUTIONS, LLC
X
MND006148092
GOPHER RESOURCE
CORPORATION
X
MND980615736
UNIVAR USA, INC.
X
MND980996805
ENIVRO-CHEM, INC.
X
X
MND981097884
SAFETY-KLEEN
SYSTEMS, INC. (EAGAN,
MN)
X
MND981098478
SIEMENS INDUSTRY,
INC.
X
X
X
143
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
MND981101314
MAGUIRE & STRICKLAND
REFINING
X
MND981953045
SAFETY-KLEEN
SYSTEMS, INC. (BLAINE,
MN)
X
MND985746262
MERCURY
TECHNOLOGIES OF MN
INC
X
MND985767656
J.R.'S APPLIANCE
DISPOSAL, INC.
X
MNR000078675
RETROFIT COMPANIES
INC - LITTLE CANADA
X
MNR000107037
GREEN LIGHTS
RECYCLING, INC.
X
OHD000724153
CLEAN HARBORS OF
CLEVELAND
X
OHD000816629
SPRING GROVE
RESOURCE RECOVERY
INC
X
X
X
OHD001926740
HUKILL CHEMICAL CORP
X
X
X
X
OHD004274031
CLEAN WATER
X
X
OHD005048947
SYSTECH
ENVIRONMENTAL CORP
X
OHD020273819
VICKERY
ENVIRONMENTAL INC
X
OHD045243706
ENVIROSAFE SERVICES
OF OHIO INC
X
X
OHD048415665
ROSS INCINERATION
SERVICES INC
X
X
OHD066060609
CHEMTRON CORP
X
X
X
X
OHD071654958
TOXCOINC
X
X
X
OHD074700311
NEXEO SOLUTIONS, LLC
X
OHD083377010
ENVIRONMENTAL
ENTERPRISES INC
X
X
X
X
X
X
OHD093945293
VEOLIA ES TECHNICAL
SOLUTIONS LLC
X
X
X
OHD980568992
ENVIRITE OF OHIO INC
X
X
X
X
144
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
OHD980587364
CLEAN HARBORS
RECYCLING SERVICES
OF OHIO LLC
X
X
X
OHD980613541
HERITAGE -WTI, INC
X
X
OHD980793384
RESERVE
ENVIRONMENTAL
X
OHD980821862
KLOR KLEEN
X
OHD980897656
CHEMICAL SOLVENTS
INC
X
X
X
OHD987048733
LAFARGE
CORPORATION
X
OHR000034025
LAMPS INC DBA
ENVIRONMENTAL
RECYCLING
X
X
OHR000109819
USA LAMP & BALLAST
RECYCLING INC
X
Wl0000934174
AURA II INC
X
WID000808824
HYDRITE CHEMICAL CO
X
X
WID003967148
VEOLIA ES TECHNICAL
SOLUTIONS LLC
X
X
X
X
WID023350192
BRENNTAG GREAT
LAKES LLC
X
X
X
WID980996615
DYNAMIC RECYCLING
X
WID981097769
SAFETY-KLEEN
SYSTEMS INC
X
WID981187297
SAFETY-KLEEN
SYSTEMS INC
X
WID988566543
VEOLIA ES TECHNICAL
SOLUTIONS LLC
X
X
X
WID988580056
BADGER DISPOSAL OF
Wl INC
X
X
X
X
WID990829475
WRR ENVIRONMENTAL
SERVICES CO INC
X
X
X
X
WIR000000356
WM MERCURY WASTE
INC
X
X
EPA Region 6
145
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
ARD006354161*
REYNOLDS METALS CO.
X
Nonwastewater
capacity for
K088
ARD059636456
FRIT INDUSTRIES, INC.
X
ARD069748192
CLEAN HARBORS EL
DORADO
X
X
X
X
ARD981057870
RINECO CHEMICAL
INDUSTRIES, INC.
X
X
X
X
ARD981512270
ASH GROVE CEMENT
COMPANY
X
X
LA0000365668
LAMP RECYCLERS OF
LOUISIANA, INC., DBA
LAMP ENVIRONMENTAL
INDUSTRIES
X
LAD000777201
CHEMICAL WASTE
MANAGEMENT LAKE
CHARLES
X
X
X
LAD008086506
EAGLE US 2
X
LAD008161234
ECO SERVICES
X
X
LAD008175390
CORNERSTONE
CHEMICAL COMPANY
X
LAD980622161
CATALYST RECOVERY
OF LA, LLC
X
X
LAD981055791
CLEAN HARBORS
COLFAX, LLC
X
LAD981059017
CLEAN HARBORS BATON
ROUGE LLC
X
LAR000042226
SHELL NORCO
CHEMICAL PLANT-WEST
SITE
X
LAR000070177
TRADEBE TREATMENT &
RECYCLING LLC
X
LAR000073197
STERICYCLE SPECIAL
WASTE SOLN INC
X
NM0000590240
STERICYCLE
SPECIALITY WASTE
SOLUTIONS INC
X
146
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
NMD000333211
WESTERN REFINING
SOUTHWEST INC -
GALLUP REFINERY
X
X
NMD000804294
SAFETY-KLEEN
SYSTEMS, INC
X
NMD980698849
SAFETY-KLEEN
SYSTEMS, INC
X
OKD000402396
EQ OKLAHOMA
X
X
X
X
X
OKD000763821
SAFETY-KLEEN
SYSTEMS, INC
X
OKD064558703
TULSA CEMENT LLC
D/B/A CENTRAL PLAINS
COM
X
OKD065438376
CLEAN HARBORS LONE
MOUNTAIN LLC
X
X
X
OKD980878474
SAFETY-KLEEN
SYSTEMS, INC
X
OKD982293334
ENVIRONMENTAL
MANAGEMENT, INC.
X
OKD987097151
TRICAT INC
X
TXD000719518
TM DEER PARK
SERVICES
X
X
X
X
TXD000729400
SAFETY-KLEEN
SYSTEMS SAN ANTONIO
X
X
TXD000747378
SAFETY-KLEEN
SYSTEMS
X
X
X
TXD000747402
SAFETY-KLEEN
SYSTEMS CORPUS
CHRISTI BRANCH
X
X
X
TXD000838896
VEOLIA ES TECHNICAL
SOLUTIONS
X
X
X
TXDO01700806
ASCEND CHOCOLATE
BAYOU PLANT
X
TXD006451090
EXIDE FRISCO BATTERY
RECYCLING PLANT
X
TXD008099079
RHODIA
X
TXD010791184
LONESTAR ECOLOGY
X
147
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
TXD010803203
SAFETY-KLEEN
MISSOURI CITY 6 073 02
X
X
X
TXD046844700
CHEMICAL
RECLAMATION
SERVICES AVALON
FACILITY
X
X
X
TXD052649027
DISPOSAL PROPERTIES
LLC
X
TXD055135388
SET ENVIRONMENTAL
X
X
TXD055141378
CLEAN HARBORS DEER
PARK
X
X
X
TXD062287883
SAFETY KLEEN ABILENE
6 002 01
X
X
X
TXD069452340
US ECOLOGY TEXAS INC
X
X
X
X
TXD072181381
BLANCHARD REFINING
LAND TREATMENT
FACILITY
TXD074195678
GULF CHEMICAL &
METALLURGICAL
FREEPORT
X
X
TXD074196338
ELTEX CHEMICAL
X
X
TXD077603371
SAFETY-KLEEN
SYSTEMS DENTON
RECYCLE CENTER
X
X
X
X
X
X
TXD083145656
SAFETY-KLEEN
SYSTEMS
X
X
TXD097673149
VOPAK LOGISTICS
SERVICES USA DEER
PARK
X
X
TXD102599339
PSC RECOVERY
SYSTEMS
X
TXD106829963
EURECAT US
X
X
TXD980745095
NEXEO SOLUTIONS
GARLAND
X
TXD980748461
STOLTHAVEN HOUSTON
SUBSIDIARY OF STOLT
NIELSON SA
X
148
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
TXD980876015
SAFETY-KLEEN WACO
X
X
X
TXD981052061
SAFETY KLEEN
SYSTEMS IRVING
X
X
X
TXD981053416
SAFETY KLEEN
SYSTEMS FORT WORTH
X
X
X
X
TXD981053770
DURATHERM SAN LEON
X
X
TXD981056690
SAFETY-KLEEN
SYSTEMS MIDLAND
X
X
X
TXD981514383
ALPHA OMEGA
RECYCLING
X
X
TXD982290140
CLEAN HARBORS
LAPORTE
X
X
TXD982560294
NSSI RECOVERY
SERVICES
X
X
TXD988001251
VEOLIA ES TECHNICAL
SOLUTIONS LLC
X
TXD988021259
NOVA MOLECULAR
TECHNOLOGIES
X
TXD9880888464*
WASTE CONTROL
SPECIALISTS
Mixed
wastes
TXR000000034
CONECSUS TEJAS
FACILITY
X
TXR000001016
TM CORPUS CHRISTI
SERVICES
X
X
X
TXR000025841
EFFECTIVE
ENVIRONMENTAL
X
TXR000051508
EFFECTIVE
ENVIRONMENTAL
X
TXR000056192
TECHEMET LLP
X
TXR000058263
STERICYCLE PHARR
X
TXR000069344
STERICYCLE SPECIALTY
WASTE SOLUTIONS
X
TXR000079044
PHILIP
RECLAMATIONSERVICES
HOUSTON INC
X
TXR000079350
ZODIAC ENTERPRISES
LLC
X
149
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
TXR000079856
TRADEBE TREATMENT
AND RECYCLING
X
EPA Region 7
IAD022365480
NORTHLAND PRODUCTS
CO
X
IAD098027592
SAFETY-KLEEN
(DAVENPORT)
X
IAD981718000
SAFETY-KLEEN (DES
MOINES)
X
KSD000809723
SAFETY-KLEEN
SYSTEMS INC
X
KSD031203318
ASH GROVE CEMENT
COMPANY
X
KSD057889313
NEXEO SOLUTIONS
X
KSD980633259
SYSTECH
ENVIRONMENTAL CORP
X
X
KSD980686844
SAFETY-KLEEN
SYSTEMS INC
X
KSD981506025
CLEAN HARBORS
ENVIRONMENTAL
SERVICES CLACKAMAS
X
X
KSR000510172
TRADEBE TREATMENT
AND RECYCLING, LLC
X
MOD000610766
SOLVENT RECOVERY
LLC
X
X
X
MOD000669051
SAFETY KLEEN
SYSTEMS INC
X
MOD000669069
SAFETY KLEEN
SYSTEMS INC
X
MOD029719200
DYNO NOBEL INC
X
MOD054018288
GREEN AMERICA
RECYCLING, LLC
X
X
X
MOD059200089
BUICK RESOURCE
RECYCLING FACILITY
LLC
X
X
MOD077887909
EXPERT MANAGEMENT
INC
X
MOD095486312
SAFETY KLEEN
SYSTEMS INC
X
150
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
MOD980971626
SAFETY KLEEN
SYSTEMS INC
X
MOD980973564
SAFETY KLEEN
SYSTEMS INC
X
MOD981123391
WASTE EXPRESS
X
X
X
MOD981127319
LONE STAR INDUSTRIES
X
X
MOD981505555
HERITAGE
ENVIRONMENTAL
SERVICES LLC
X
X
X
MOD985798164*
EVB EXPLOSIVES
ENVIRONMENTAL
COMPANY
Explosive
wastes
MOR000505958
TRI-RINSE INC
X
MOR000523969
ARCH ENTERPRISES INC
X
NED053316535
SAFETY-KLEEN
SYSTEMS, INC.
X
NED981495724
SAFETY-KLEEN
SYSTEMS, INC.
X
NED981723513
CLEAN HARBORS
ENVIRONMENTAL
SERVICES
X
X
EPA Region S
COD000716621
SAFETY-KLEEN
SYSTEMS INC -
ENGLEWOOD
X
COD000716639
SAFETY-KLEEN
SYSTEMS INC - PUEBLO
X
COD980591184
VEOLIA ES TECHNICAL
SOLUTIONS LLC
X
X
X
X
X
COD991300484
CLEAN HARBORS DEER
TRAIL LLC
X
X
X
X
COR000210401
SILVER ANVIL
ENGINEERING CORP
X
COR000224014
STERICYCLE SPECIALTY
WASTE SOLUTIONS INC
(SSWSI)
X
MTD982590739
EMERALD SERVICES INC
GREAT FALLS
X
151
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
NDD000716738
SAFETY-KLEEN
SYSTEMS, INC. - FARGO
X
NDD980957070
SAFETY KLEEN
SYSTEMS, INC.
(BISMARK)
X
NDD982591794
WASTE RECOVERY
SERVICES, INC.
X
X
NDR000003111
SABIN METAL WEST
CORP
X
SDD000716696
SAFETY-KLEEN
SYSTEMS, INC. (SIOUX
FALLS SD)
X
UTD001705029
ATK LAUNCH SYSTEMS
INC.
X
UTD048406144
NEXEO SOLUTIONS, LLC
-CLEARFIELD, UT
X
UTD980957088
SAFETY-KLEEN
SYSTEMS
X
UTD981552177
CLEAN HARBORS
ARAGONITE LLC
X
X
UTD982595795
CLEAN HARBORS CLIVE,
LLC
X
UTD982598898*
ENERGY
SOLUTIONS,LLC
Mixed
Wastes
UTD988074274
STERICYCLE WOODS
CROSS
X
UTD991301748
CLEAN HARBORS
GRASSY MOUNTAIN,
LLC.
X
X
X
UTR000007138
VEOLIA ES TECHNICAL
SOLUTIONS
X
EPA Region 9
AZ0000337360
VEOLIA ES TECHNICAL
SOLUTIONS, L.L.C.
X
X
AZD049318009
CLEAN HARBORS
ARIZONA, LLC
X
X
X
AZD060624251
FREEPORT-MCMORAN
MIAMI INC.
X
AZD081705402
HERITAGE
ENVIRONMENTAL
SERVICES, LLC
X
152
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
AZD089304216
UNIVAR USA INC
X
AZD980695332
GANNON & SCOTT
PHOENIX, INC
X
AZD980735500
WORLD RESOURCES
COMPANY
X
AZD981969504
SAFETY-KLEEN
SYSTEMS, INC.
X
AZD982434185
WM LAMPTRACKER, INC
X
AZD982441263
SIEMENS WATER
TECHNOLOGIES CORP
X
AZT050010685
HVF PRECIOUS METALS
X
X
CA0000084517
SAFETY-KLEEN
SYSTEMS, INC
X
CAD000633164
CLEAN HARBORS
WESTMORLAND, LLC
X
CAD003963592
ECS REFINING
X
X
CAD008252405
PACIFIC RESOURCE
RECOVERY
X
X
X
CAD008302903
VEOLIA ES TECHNICAL
SOLUTIONS, L.L.C.
X
X
X
X
X
X
CAD008364432
RHO-CHEM LLC
X
X
X
CAD008488025
PHIBRO-TECH INC.
X
X
X
CAD009466392
ECOLOGY CONTROL
INDUSTRIES, INC.
X
CAD021774559
AB&I FOUNDRY
X
CAD028409019
CROSBY & OVERTON
X
X
CAD044429835
CLEAN HARBORS
WILMINGTON, LLC
X
CAD050806850
CLEAN HARBORS LOS
ANGELES FACILITY
X
CAD059494310
CLEAN HARBORS SAN
JOSE, LLC
X
X
X
X
X
CAD060398229
HERAEUS METAL
PROCESSING, LLC
X
X
153
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
CAD066113465
SAFETY-KLEEN
SYSTEMS, INC
X
CAD066233966
QUEMETCO, INC
X
X
CAD069124717
XSTRATA RECYCLING,
INC.
X
CAD088504881
KINSBURSKY BROTHERS
SUPPLY INC.
X
X
CAD097030993
SIEMENS INDUSTRY,
INC.
X
X
X
CAD097854541
EXIDE TECHNOLOGIES
INCORPORATED
X
X
CAD099452708
INDUSTRIAL SERVICE
OIL COMPANY, INC.
X
CAD108040858
TSM RECOVERY &
RECYCLING CO INC
X
CAD980585293
INDUSTRIAL WASTE
UTILIZATION
X
CAD980675276
CLEAN HARBORS
BUTTONWILLOW, LLC
X
X
X
CAD980813950
CRANES WASTE OIL, INC
X
CAD980884183
GEM RANCHO CORDOVA
LLC
X
CAD980887418
EVERGREEN OIL, INC.
X
X
X
X
CAD980888598
WIT SALES AND
REFINING
X
CAD981402522
COMMODITY RESOURCE
AND ENVIRONMENT
X
CAD982052797
J&B ENTERPRISES
X
X
CAD982338923
VEOLIA ES TECHNICAL
SOLUTIONS
X
CAD982411993
AERC.COM, INC.
X
X
X
CAD982435026
KW PLASTICS OF
CALIFORNIA
X
CAD982439895
CLEAN HARBORS
ENVIRONMENTAL
SERVICES PORT OF
REDWOOD CITY RAIL
X
154
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
CAD982444481
FILTERRECYCLING
SERVICES, INC.
X
X
X
X
X
X
CAD983649880
PSC ENV SVCS OF
POMONA LP
X
CAL000024110
P KAY METAL, INC.
X
CAL000098454
ATLAS PRECIOUS
METALS, INC.
X
CAL000110141
DAVID H. FELL AND
COMPANY,INC.
X
CAR000149575
ALPERT& ALPERT IRON
& METAL, INC.
X
CAR000155887
U.S. CIRCUIT, INC.
X
CAR000156125
LIGHTING RESOURCES,
LLC
X
CAR000188201
ENVIRONMENTAL
RECOVERY SERVICES
INC
X
CAT000613893
SAFETY-KLEEN
SYSTEMS, INC
X
CAT000613927
SAFETY-KLEEN
SYSTEMS, INC
X
CAT000613976
SAFETY-KLEEN
SYSTEMS, INC
X
CAT000646117
CHEMICAL WASTE
MANAGEMENT, INC.
X
X
X
CAT080013352
DEMENNO KERDOON
X
X
CAT080014079
VEOLIA ES TECHNICAL
SOLUTIONS, L.L.C.
X
CAT080033681
D/K ENVIRONMENTAL
X
HIR000141895
BURLINGTON
ENVIRONMENTAL, LLC
X
NVD980895338
21ST CENTURY
ENVIRONMENTAL
MANAGEMENT OF
NEVADA, LLC
X
X
X
X
NVR000043927
ITRONICS
METALLURGICAL INC
X
155
-------
Commercial Hazardous Waste Management Facilities
EPA ID
Facility Name
RECOVERY
TREATMENT
DISPOSAL
TRANSFER/
STORAGE
Metals
Recovery
Solvents
Recovery
Inorganics
Recovery
Energy
Recovery
Fuel
Blending
Incineration
Wastewater
Treatment
Stabilization/
Sludge
T reatment/
Encapsulation
Landfill
Deepwell/
Underground
Injection
NVR000066837
SAFETY KLEEN
SYSTEMS INC
X
NVR000080655
BANGO OIL, LLC; BANGO
FACILITY
X
X
NVT330010000
US ECOLOGY NEVADA
X
X
X
EPA Region 10
IDD073114654
US ECOLOGY IDAHO INC
SITE B
X
X
X
ORD089452353
CHEMICAL WASTE
MANAGEMENT OF THE
NORTHWEST
X
X
X
X
ORD981766124
SAFETY KLEEN
SYSTEMS INC 7-148-01
X
X
WAD020257945
BURLINGTON
ENVIRONMENTAL LLC
TACOMA
X
X
X
WAD980976906
HALLMARK REFINING
CORP
X
WAD981769110
EMERALD SERVICES INC
ALEXANDER AVE
X
X
WAD991281767
BURLINGTON
ENVIRONMENTAL LLC
KENT
X
X
X
X
X
WAH000026371
ECOLIGHTS
NORTHWEST
X
WAR000010355
PERMA FIX NORTHWEST
RICHLAND INC
X
X
These are facilities with hazardous waste management units that are permitted to manage specific waste codes, types of wastes, forms of
wastes, etc. The analyses for specialty operations is presented in Appendix E.
156
-------
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157
-------
Appendix C
CAP Management Categories
158
-------
[Page intentionally left blank.]
159
-------
CAP Management Categories
For each of the CAP management categories, the main technologies used for each category are
described, including the types of waste recovered, treated, or disposed. Each CAP
management category is comprised of a number of waste management technologies that are
generally interchangeable for managing broad types of wastes based on treatment
performance.
METALS RECOVERY
Metals recovery technologies are designed to separate desired metals from other constituents
of hazardous wastes. The most common technologies, which are described below, are high-
temperature metals recovery, retorting, secondary smelting, ion exchange, and acid leaching.
High-temperature metals recovery is used to treat hazardous wastes that contain metals such
as cadmium, chromium, lead, nickel, and zinc compounds. Metals are separated from the
waste at high temperatures through a thermochemical-process using carbon, limestone, and
silica as the chemical agents. The constituents being recovered from the waste are heated so
that they melt and/or volatilize and can be recovered in metallic or oxide form from process
vapors or from a molten bath. The high temperature metals recovery process typically consists
of a mixing unit, a high temperature processing unit, a product collection system, and a residual
treatment system. Other volatile metals, such as arsenic or antimony, may be difficult to
separate from the desired metal products and may adversely affect the ability to reuse the
recovered materials. Slag, the primary residual from the process, is sometimes cooled in a
quench tank and reused either directly or after further processing, or, if the material has no
recoverable value, it is land disposed after necessary treatment.
Retorting is similar to high-temperature metals recovery in that it provides for recovery of
metals from wastes primarily by volatilization and subsequent collection and condensation of the
volatilized components. It is used primarily to remove elemental mercury, as well as mercury
present in the oxide, hydroxide, and sulfide forms from hazardous wastes.
Secondary smelting also is very similar to high-temperature metals recovery; but is generally
used for processes that recover lead from hazardous wastes. In this process, waste passes
through a smelting furnace where the lead is concentrated into a bullion and separated from
slag in molten form.
Ion exchange is primarily used to treat aqueous hazardous wastes with dissolved metals.
These wastes also might contain nonmetallic anions such as halides, sulfates, nitrates, and
cyanides, and water soluble ionic organic compounds. In ion exchange metals recovery,
hazardous metal ions are removed and replaced by nonhazardous ions.
Acid leaching is used to treat hazardous wastes in solid or slurry form that either contain metal
constituents that are soluble in a strong acid solution or can be converted by reaction with a
strong acid to a soluble form. The acid leaching process is most effective with wastes that have
high levels (over 1,000 parts per million) of metal constituents.3 Leachate from acid leaching
generally requires further processing (e.g., ion exchange) to recover metals from the solution.
3 Treatment Technology Background Document, January 1991, EPA, Office of Solid Waste, page 184.
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ORGANICS RECOVERY
Organics recovery technologies are used to separate liquid organic wastes, primarily spent
solvents (both halogenated and nonhalogenated), for full or partial recovery. The most common
technologies, described below, are distillation and solvent extraction. Other technologies
include waste oil recovery and non-solvents organic recovery.
Distillation is a thermal treatment technology applicable to the treatment of wastes containing
organics that are volatile enough to be removed by the application of heat. Constituents that
are not volatilized may be reused or incinerated, as appropriate. Distillation is the process of
separating volatile materials using evaporation followed by condensation. The liquids to be
separated must have different volatilities and the degree of separation of these liquids is limited
by the difference in their volatilities. Distillation for recovery can be limited by the presence of
either volatile or thermally reactive suspended solids.
Important distillation technologies are:
• Fractionation. This technology uses tray columns or packed towers equipped with a
reboiler, condenser, and an accumulator. The process is not applicable for liquids with high
viscosity at high temperature, liquids with a high concentration of solids, polyurethanes, and
inorganics. In general, the process is used where recovery of multiple constituents is
desired and the waste contains minimal amounts of suspended solids. This process
achieves a high product purity.
• Steam Stripping. This process is essentially fractionation with steam as heat source. It is
typically applied to wastes with less than 1 percent volatile organics.4
• Batch Distillation. This technology uses a steam-jacketed vessel, a condenser, and a
product receiver. Pressurized steam is usually the source of heat.
• Thin Film Evaporation. This technology uses a steam-jacketed cylindrical vessel and
condenser, where the material trickles down the inside cylinder walls in thin streams, and a
distribution device that spreads the film over the heated surface. It can be used to treat
highly concentrated organic wastes that contain low concentrations of suspended solids.
Solvent extraction is used to treat wastes with a broad range of total organic content, such as
certain oil refinery wastes. Constituents are removed from the waste by mixing it with a solvent
that will preferentially dissolve the constituents of concern. The selection of a solvent depends
on its solubility with the organic compounds to be removed and the other constituents in the
waste. The waste and solvent must be physically immiscible so that after mixing the two
immiscible phases can be physically separated by gravity. The process can be either batch or
continuous. The simplest, least effective solvent extraction unit is a single-stage system (mixer-
setter system). Other types of solvent extraction systems include multistage contact extraction
(basically a series of single-stage units), countercurrent multi-stage extraction columns, and
centrifugal contactors.
4 Treatment Technology Background Document, January 1991, EPA, Office of Solid Waste, page 135.
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INORGANICS RECOVERY
Acid regeneration is the primary technology for inorganics recovery and is used to recover
mainly halogen and sulfuric acids. These acids are recovered by halogen acid furnaces and
sulfur recovery furnaces, respectively. Halogen acid furnaces typically process chlorinated and
brominated secondary waste streams, with 20 to 70 percent halogen content by weight, to
produce either hydrogen chlorine or hydrogen bromine.5 Sulfur recovery furnaces are used by
sulfuric acid plants to process used sulfuric acid and other sulfur-containing wastes. Typical
acid contaminants include organics, inorganics, and water. The contaminated acids and other
halogen- or sulfur-containing compounds are thermally decomposed at elevated temperatures
and the desired halogen or sulfur compounds captured from the exhaust gases, such as by
passing the gases through converted catalyst beds.
ENERGY RECOVERY
Energy recovery systems burn hazardous waste for its fuel value. The capacity to burn liquids
as fuel dominates at a national level, as sludges and solids are not often burn for recovery.
Types of energy recovery systems are discussed below.
• Industrial kilns. Cement and lightweight aggregate kilns can burn liquid hazardous wastes
for their heat value. (A few cement kilns also burn small containers of viscous or solid
hazardous waste fuels.) Typically, cement kilns blend the wastes with fossil fuels while
aggregate kilns burn 100 percent liquid wastes.
• Industrial boilers. Some industrial boilers can use limited amounts and types of hazardous
wastes as supplements to fossil fuels. The wastes are commonly blended before using as
fuel.
FUEL BLENDING
Fuel blending is the process of blending hazardous waste streams together, generally in tanks,
to obtain a fuel that meets the specifications of fuel burners (e.g., energy recovery systems).
Fuel blending is not a stand-alone treatment technology; the resulting fuels are subsequently
burned, either on or off site, by combustion systems.
INCINERATION
Incineration uses controlled, high-temperature combustion processes to break down the organic
compounds in a hazardous waste. The incineration of hazardous waste must be performed in
accordance with the incinerator design and emissions regulations in 40 CFR Part 264, Subpart
O or 40 CFR Part 265, Subpart O. Incinerators can burn pumpable waste (liquids and gases),
nonpumpable waste (solids and sludges), or both. Several types of incinerators are discussed
below.
Liquid Injection Incinerators. These incinerators are used widely for destruction of liquid
organic wastes. They operate by spraying the waste mixed with air into a chamber where flame
oxidation occurs.
5 56 FR 7140.
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Rotary Kilns. Rotary kilns can treat most types of solids, liquids, and gases. They consist of a
long inclined tube where the waste is placed and rotated slowly as heat is applied. The process
is intended for solids, but liquids and gases can be mixed with the solids.
Fluidized-bed Incinerators. Air is blown through a granular bed (usually sand) until the
particles are suspended and move and mix like a fluid. The heated particles come in contact
with the wastes to be incinerated and improve the heat transfer. This type of incineration is
ideal for sludge and slurries.
Other types of incinerators include two-stage and fixed hearth.
The ash produced from the incineration of hazardous waste also may be hazardous, and
therefore must be further treated by stabilization before disposed in a landfill.
WASTEWATER TREATMENT
This CAP management category covers a broad range of treatment technologies and treats the
largest volume of hazardous waste of any CAP management category. Wastes that are treated
in this category either undergo further treatment (under this or other CAP management
categories) or are sent for disposal. Many of these technologies are used together in one
treatment system (e.g., chrome reduction followed by chemical precipitation). The discussion of
these technologies is organized by the principal type of waste treated: aqueous inorganic,
aqueous organic, aqueous inorganic and organic sludge, and other.
Aqueous Inorganic Treatment
• Chrome reduction (hexavalent) is applicable to wastes containing hexavalent chromium
wastes, including plating solutions. The process uses a chemical reaction with a reducing
agent, such as sulfur dioxide or sodium bisulfite, to reduce chromium from a hexavalent to a
trivalent state, so that the chromium can be more easily precipitated. The reduced
chromium compounds are precipitated from the solution by raising the pH and the resulting
insoluble form of chromium is allowed to settle from the solution.
• Cyanide destruction is applicable to wastes containing high concentrations of cyanide,
such as concentrated spent plating solutions. This technology is often applied as
pretreatment prior to chemical oxidation. The waste is subject to electronic reaction with
dissolved oxygen in an aqueous solution and broken down into carbon dioxide, nitrogen,
and ammonia. The procedure is conducted at elevated temperature, depends on the
conductivity of waste, and occurs in a closed cell.
• Chemical oxidation changes the chemical form of hazardous material through a chemical
reaction with an oxidizing agent that produces carbon dioxide, water, salts, and simple
organic acids. Principal chemical oxidants include hypochlorite, chlorine gas, chlorine
dioxide, hydrogen peroxide, ozone, and potassium permanganate. This technology is used
to treat wastes containing organics, sulfide wastes, and certain cyanide and metal wastes.
• Chemical precipitation is used to treat wastewaters containing metals and other inorganic
substances such as fluoride. The process removes these metals and inorganics from
solution in the form of insoluble solid precipitate by adding a precipitating agent (e.g., lime,
caustic (NaOH), sodium sulfide). The solids that form are then separated from the
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wastewater by settling, clarification, and/or polishing filtration. Pretreatment may be required
for some wastewaters, such as those that contain chromium or cyanide.
• Ion exchange is used to treat hazardous wastewaters with metals that are present as
soluble ionic species; nonmetallic anions such as halides, sulfates, nitrates, and cyanides;
and water soluble ionic organic compounds. Typically, the waste constituents are removed
when a waste solution is percolated through a granular bed of the ion exchanger in which
ions from the waste are exchanged with those in the ion exchanger.
• Reverse osmosis involves a dilute solution and concentrated solution separated by a semi-
permeable membrane. When high pressure is added to the concentrated side, the solution
flows through the membrane to the more dilute side, collecting waste constituents that are
unable to pass through the membrane.
Aqueous Organic Treatment
• Biological treatment processes are used to decompose hazardous organic substances
with microorganisms. These processes require stable operating conditions and usually take
place in tanks or lagoons. The most common type is aerobic biological treatment, including
activated sludge treatment. This method treats wastewaters with low levels of
nonhalogenated organics and certain halogenated organics.
• Carbon adsorption is used to treat aqueous organic wastewaters with high molecular
weights and boiling points and low solubility and polarity, chlorinated hydrocarbons, and
aromatics (e.g., phenol). The wastewater is passed through activated carbon beds which
attract and hold (adsorb) the organic waste constituents (and possibly inorganics and
metals), removing them from the water.
• Air stripping is a process used to treat aqueous organic waste with relatively high volatility
and low water solubility. The volatile contaminants are evaporated into the air and captured
for subsequent treatment.
• Steam stripping is used to treat aqueous organic wastes contaminated with chlorinated
hydrocarbons, aromatics, ketones, and/or alcohols. This technology can treat less volatile
and more soluble wastes than air stripping, and can handle a wide concentration range.
First, steam is used to evaporate volatile organics. The evaporated organics are then
captured, condensed, and reused or further treated.
Aqueous Inorganic/Organic Treatment
• Wet air oxidation is used to treat aqueous waste streams with less than five percent
organics, pesticides wastes, and wastewaters containing sulfur, cyanide, or phenolic
compounds. It is not recommended for treating aromatic halogenated organics, inorganics,
or large volumes of waste. The aqueous solution is heated in the presence of compressed
air and dissolved or finely divided organics are oxidized. These oxidized products usually
remain in the liquids phase. These liquids can then be further treated or sent for disposal.
An important advantage of wet air oxidation is that it accepts waste with organic
concentrations ranging between those considered ideal for biological treatment or for
incineration.
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Other Wastewaters Treatment
• Neutralization is used to treat waste acids and alkalies (bases) in order to eliminate or
reduce their reactivity and corrosiveness. In this process, an excess of acidic ions (H+) is
balanced with an excess of base ions (OH) to form a neutral solution.
• Evaporation is physical separation of a liquid from a dissolved or suspended solid by
adding energy to volatilize the liquid. It can be applied to any mixture of liquids and
nonvolatile solids. The liquid should volatilize at a reasonable temperature.
• There are many types of settling/clarification processes. One type is sedimentation,
which is a gravity-settling process that allows heavier solids to separate from fluid by
collecting at bottom of a containment vessel such, as settling ponds or a circular clarifier.
Additional treatment is needed for the liquid and separated sludge.
• Flocculation is the addition of a chemical to a waste to enhance sedimentation and
centrifugation; primarily for inorganic precipitation.
• Phase separation refers to processes such as emulsion breaking and filtration. Emulsion
breaking uses gravitational force to separate liquids with sufficiently different densities, such
as oil and water. This process is enhanced by adding certain acids. Filtration is the process
of separating and removing suspended solids from a liquid by passing the liquid through a
porous medium (see sludge dewatering). Polishing filtration, applied to wastewaters
containing relatively low concentrations of acids, is used after chemical precipitation and
settling/clarification of wastewaters containing inorganic precipitates to remove additional
particles, such as those that are difficult to settle because of their shape or density.
SLUDGE TREATMENT
• Sludge dewatering (sludge filtration) is used for wastes with high concentrations of
suspended solids (generally higher than 1 percent). Sludges can be dewatered to 20 to 50
percent solids. The solid particles are separated from the waste through a filter that permits
fluid flow but retains the particles. For this technology, waste can be pumped through a
porous filter, drawn by vacuum through a cloth filter, or gravity-drained and mechanically
pressured through two continuous fabric belts.
• Solvent extraction is used to treat wastes with a broad range of total organic content such
as certain oil refinery waste. Constituents are removed from the waste by mixing it with a
solvent that will preferentially dissolve the constituents of concern. The waste and solvent
must be physically immiscible so that after mixing the two immiscible phases can be
physically separated by gravity.
Other sludge treatment methods include addition of excess lime or caustic to increase the
alkalinity of the waste and absorption/adsorption processed to remove liquid from the sludge.
STABILIZATION/CHEMICAL FIXATION
Stabilization and chemical fixation refer to treatment processes that chemically or physically
immobilize the hazardous constituents in a waste by binding the hazardous constituents into a
solid mass. The resulting product has a low permeability that resists leaching.
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Stabilization is used to treat wastes containing leachable metals and having a high filterable
solids content, low organic carbon content, and low oil and grease content. The leachable
metals in a waste are immobilized following the addition of stabilizing agents and other
chemicals, and the resulting lattice structure and/or chemical bonds bind the metals to the solid
matrix and thereby limit the amount of metal constituents that can be leached. The process
normally requires a weighing device, a mixing unit (typically commercial concrete mixers), and a
curing vessel or pad. Advantages of stabilization include inexpensive and plentiful raw
materials and minimal pretreatment requirements. The main disadvantage is that the large
volumes of additives required greatly increase the waste volume to be disposed. The main
stabilization technologies are:
• Lime-Based Pozzolan Process. This technology treats sludges and contaminated soils by
adding large amounts of siliceous (silica) materials combined with a setting agent such as
lime, forming a dewatered stabilized solidified product. Contaminants can include metals,
waste oils, and solvents. Materials such as borates, sulfates, and carbohydrates interfere
with the process.
• Portland Cement Pozzolan Process. This technology is similar to the lime-based
pozzolan process except that the waste is mixed with portland cement. The process is
effective for metal cations, latex, and solid plastic wastes. Large amounts of dissolved
sulfate salts or metallic anions (such as arsenate and borates) can interfere with
solidification. Organic material, lignite, silt, or clay in the wastes will increase setting time.
• Sorption. This technology, suitable for organics and inorganics, is commonly used to treat
metal sludges removed from aqueous waste streams. Contaminants are bound up in
pozzolan-type matrices by physical or chemical sorption, yielding a stabilized, easier to
handle material. After treatment, the material is permeable and contains a high
concentration of contaminants at its surface; consequently, contaminants may leach.
Two types of high temperature stabilization include vitrification and high temperature
calcination. The vitrification process involves dissolving the waste at high temperatures into
glass or glasslike matrix. It is applicable to nonwastewaters containing arsenic (usually in form
of arsenate salts), other characteristic toxic metal constituents that are relatively nonvolatile at
operating temperature of the process, and certain wastes containing organometallic
compounds. The process is not applicable to volatile metallic compounds or wastes containing
high levels of constituents that will interfere with the vitrification process such as chlorides and
halogen salts. High temperature calcination, applicable to inorganic wastes that do not contain
volatile constituents, involves merely heating the material at high temperatures. The waste is
sometimes blended with lime before heating. The process removes water from the waste,
converts hydroxides to oxides, and converts the waste into a coherent mass, reducing surface
area to minimum.
Fixation processes are applicable to liquid, semi-liquid, or solid wastes that may leach
hazardous constituents. The processes can effectively treat a variety of hazardous wastes
containing heavy metals, such as sludges from electroplating operations, ion-exchange resins
from water demineralization, spent activated carbon, pesticides, nickel-cadmium battery sludge,
and pigment production sludge. The process involves grinding a dewatered waste, mixing the
resulting particles with a hardening resin, placing the mixture in a mold, and heating the material
until it fuses. The product is hard, solid block with reduced leachability potential, improved
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handling, and minimal volume increase (unlike conventional stabilization techniques). The most
serious drawback is uncertainty about long-term effectiveness.
In the main fixation technologies, asphalt-based and thermoplastic encapsulation, the
dewatered waste is mixed within either an asphalt bitumen, paraffin, or polyethylene matrix.
These technologies are applicable to hazardous wastes that are complex and difficult to treat,
but should not be used for waste with high-water content, strongly oxidizing contaminants,
anhydrous inorganic salts, tetraborates, iron and aluminum salts, or volatile organics.
Another stabilization/fixation technology is polymerization. This technology has been applied
to spills and used catalysts. To convert a monomer or a low-order polymer of a particular
compound to a larger polymer. Larger polymers generally have greater chemical, physical, and
biological stability. The process is used to treat organics, including aromatics, aliphatics, and
oxygenated monomers such as styrene, vinyl chloride, isoprene, and acrylonitrile.
These technologies expand the volume of hazardous wastes to be disposed. The
stabilization/fixation of characteristic hazardous waste often generates residuals that are not
characteristically hazardous and therefore can be disposed of in Subtitle D landfills.
LAND TREATMENT OR APPLICATION
Wastes disposed by land treatment/farming must meet Land Disposal Restrictions (LDR)
treatment standards and land treatment facilities must meet minimum technology standards.6
This disposal method is only used at on-site and captive facilities; it is not used commercially
and the national assessment does not include projections for this CAP management category.
Land treatment/farming is used to dispose of biodegradable hazardous wastes by depositing the
wastes on or near the soil surface, mixing the wastes with the soil using conventional plow
techniques, and allowing the wastes to be naturally decomposed by microbes such as algae
and bacteria. The hazardous wastes, including organic liquid wastes and sludges, often require
pretreatment before disposal to reduce or eliminate their hazardous attributes. The
effectiveness of waste degradation is affected by many factors including the density and
makeup of the microbe populations, which vary with soil depth and geographic location, and the
care given to the waste after being deposited. The regulatory standards for this technology
require the owner or operator to establish a program to ensure that hazardous constituents
placed within the facility's treatment zone are degraded, transformed, or mobilized within that
zone.7
LANDFILL
The landfill category includes landfill and surface impoundment disposal. Waste disposed in a
landfill is placed on or beneath the surface of the ground and covered with soil or other material,
to isolate the wastes from the environment. Landfills are required to have double liners,
leachate-collection systems, and ground-water monitoring programs. Wastes not permitted to
be disposed in landfills include bulk or non-containerized liquid nonhazardous and hazardous
waste, or free liquids containing hazardous waste. In addition, wastes such as acids must be
segregated to prevent reactions with other wastes or waste constituents.
6 40 CFR 264.271.
7 40 CFR 264.271.
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A surface impoundment is a natural topographic depression; man-made excavation, or diked
area, such as a pond, pit, or lagoon that can be used for disposal if the closure requirements for
a landfill are followed. Surface impoundments are open on the surface and are designed to
accumulate organic and inorganic liquid wastes, sludges, and slurries. Surface impoundments
are required to have double liners, leachate collection systems, and routine inspections.8
Under the RCRA LDR Program, hazardous wastes generally cannot be disposed in landfills or
surface impoundments until after the waste has been properly treated. Thus, disposal facilities
receive treatment residuals, such as incinerator ash or stabilized wastes.9
DEEPWELL/UNDERGROUND INJECTION
Deepwell/underground injection is the disposal of hazardous wastewaters by injection into
underground rock formations. Wastes are injected through bored, drilled, or driven wells, or
through dug wells where the depth of the well is greater than its largest surface dimension. The
disposal method relies on hydrogeological principles of the movement of liquids in layers of
deep underground rock; the most desirable injection zone has sedimentary rocks with sufficient
permeability, thickness, depth, and areal extent. Underground injection is most suitable for
wastewaters that are low in volume and high in concentration, difficult and costly to treat by
surface methods, biologically inactive, noncorrosive, free of suspended solids, and unlikely to
react adversely with the rock strata or the fluid used to pressurize the wells. Much of the waste
is pretreated to remove suspended solids or adjust the pH. As noted for the landfill CAP
management category, hazardous wastes generally cannot be disposed in underground
injection wells unless the applicable LDR treatment standards are met.10 Capacity amounts are
determined by permit. Note that many of the wastewater treatment technologies are technically
capable of also treating the wastes being disposed through deepwell and underground injection.
TRANSFER/STORAGE
This CAP management category captures those hazardous wastes that are shipped off site to
transfer/storage facilities which store the waste for short periods of time, sometimes bulking the
waste with other shipments, and then shipping the waste to hazardous waste management
facilities. The hazardous waste must be stored for less than 90 days, or the transfer/storage
facility becomes subject to the standards and permitting requirements for hazardous waste
management facilities. If the waste is stored more than 10 days (but less than 90 days), the
transfer/storage facility is subject to the storage requirements of RCRA Subtitle C. If the waste
is stored 10 days or less, the facility is subject only to transporter regulations.11 Transporters
that mix hazardous wastes with different U.S. Department of Transportation (DOT) shipping
descriptions in the same container are classified as generators and must comply with the
relevant RCRA Subtitle C regulations.
8 40 CFR 268.4.
9 40 CFR 268.40.
10 40 CFR 148.1.
11 40 CFR 268.50.
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Appendix D
Methodology for Estimating Hazardous Waste Demand
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Methodology for Estimating Hazardous Waste Demand
This appendix briefly describes the methodology used by the U.S. Environmental Protection
Agency (EPA) to estimate hazardous waste demand for the 2014 national capacity assessment.
To develop the data to assess hazardous waste management demand at a national level, EPA
referred to the Guidance for Capacity Assurance Planning document dated May 1993 (also
referred to as the 1993 Guidance; available at http://infohouse.p2ric.org/ref/23/22567.pdf). This
document provides instructions for developing six data tables that provide state-specific
information, using the Hazardous Waste Report (also known as the Biennial Report or BR) as
the primary source of data. The tables include demand for on-site management, captive facility
management (management of wastes from facilities under the same ownership), and
commercial facility management.
The instructions in the 1993 Guidance are based on the 1991 BR forms. Since then, the BR
forms have changed drastically. For example, the Process System (PS) Form of the BR was
the primary source of information on a facility's commercial status and commercial capacity
availability, among other data. However, in accordance with EPA's efforts to reduce the
recordkeeping and reporting burden on the regulated community, EPA streamlined the federal
data collection forms for the 1997 BR cycle by eliminating the PS Form. Then, in 2001, there
was a significant change to the management method codes used to compete the BR forms
because of the Waste Information Needs/Information Needs for Making Environmental
Decisions (WIN/INFORMED) Initiative. Thus, EPA had to make some adjustments to account
for the data currently collected from hazardous waste generator and managers using the BR
forms. In addition, due in part to increased knowledge of hazardous waste management, an
ability to analyze trends, improvements in data software and hardware capabilities, EPA was
able to develop estimates for cleanup wastes based on BR data instead of the complex
calculations used 20 years ago for the CAP program. These technical updates or adjustments
to the methodology described in the 1993 Guidance are reflected in the 2014 assessment.
1. Hazardous Waste Generated and Managed Onsite
1.1. Key Data Sources
In performing the analysis, EPA used the following key data source:
• 2011 Biennial Report, Generation and Management (GM) Form, Section 2 (On-site
Generation and Management), i.e., GM Onsite Form. Data current as of
September 20, 2014.
1.2. Methodology
Following are the steps EPA undertook to estimate the quantities of hazardous waste generated
and managed on site for each of the Capacity Assurance Plan (CAP) management categories:
• Step 1: Compile data on hazardous waste generated and managed onsite. EPA
referred to GM Onsite Forms in order to compile the following data for each waste stream:
- Reporting year;
- RCRA identification number of generating facility;
- Name of generating facility;
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- Page and subpage number;
- Source code;
- Source code description;
- Form code;
- Form code description;
- EPA hazardous waste codes representing the waste;
- Waste description; and
- Quantity of hazardous waste generated and managed on site (in tons).
• Step 2: Separate mixed/low-level/radioactive wastes. To identify these wastes, EPA
conducted a word search on the waste description using the words/phrases: "radioactive,"
"mixed low level," "TRU," "mixed waste," "WIPP," and "transuranic." In addition, EPA
identified wastes sent to the following facilities:
RECEIVERJD
RECEIVER_NAME
NM4890139088
USDOE WASTE ISOLATION PILOT PLANT
NV3890090001
US DOE NNSA/NFO
NVD048946016
US ECOLOGY INC RADIOACTIVE WASTE SITE
TXD988088464
WASTE CONTROL SPECIALISTS
UTD982598898
ENERGYSOLUTIONS LLC
WA7890008967
US DEPT OF ENERGY HANFORD FACILITY
• Step 3: Separate wastes managed by facilities with specialty operations for explosive
wastes and spent potliners from primary aluminum reduction (i.e., K088 wastes). To
identify these wastes, EPA identified wastes sent to the following facilities:
RECEIVERJD
RECEIVER_NAME
ARD006354161
REYNOLDS METALS COMPANY
ARD980867873
ESTERLINE ARMTEC COUNTERMEASURES COMPANY
FL2800016121
CAPE CANAVERAL AFS
IAR000005876
ADVANCED ENVIRONMENTAL TECHNOLOGY
MND081138604
ALLIANT TECHSYSTEMS PROVING GROUNDS
MOD985798164
EBV EXPLOSIVES ENVIRONMENTAL COMPANY
NV5210090010
NEW BOMB FACILITY (HAWTHORNE ARMY DEPOT)
TXD987988318
SCHLUMBERGER WELL SERVICES PERFORATING AND
TESTING
UT0570090001
UTAH TEST AND TRAINING RANGE
UT3170027277
ATK LAUNCH SYSTEMS INC. - NIROP
UTD009081357
ATK LAUNCH SYSTEMS INC. - PROMONTORY
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• Step 4: Assign waste quantities to appropriate CAP Management Categories. EPA
used the BR management method codes and the definitions of the CAP management
categories in Attachment 1 at the end of this appendix to assign waste quantities to CAP
management categories.
• Step 5: Reassign quantities of wastes reported as on-site management in commercial
units. EPA used available information on the type of commercial hazardous waste
management services provided by a facility, and separated quantities of wastes managed in
commercial units by commercial hazardous waste management facilities. These wastes
were not considered as on-site management but reassigned and included in Table III
"Management of Hazardous Waste at Commercial Facilities."
• Step 6: Determine total quantities managed onsite for each CAP management
category. EPA summed the waste quantities by CAP management category.
2. Management of Hazardous Waste at Captive Facilities
2.1. Key Data Sources
In performing the analysis, EPA used the following key data sources:
• 2011 Biennial Report, Generation and Management (GM) Form, Section 3 (Off-Site
Shipment of Hazardous Waste), i.e., GM Offsite Form. Data current as of
September 20, 2014.
• RCRAInfo, Permit Module. Data current as of September 9-December 5, 2014.
• Hazardous waste handlers' web sites. Data current as of September 9-December 5, 2014.
2.2. Methodology
Following are the steps EPA undertook to estimate the quantities of hazardous waste managed
at captive facilities for each of the CAP management categories:
• Step 1: Develop list of captive facilities. For each CAP management category, EPA
developed a list of captive facilities. Captive facilities are facilities owned by the same
company as the generator but are at a different physical location. Their capacity can only
be used by generators under the same ownership or by generators with whom the facility
has an agreement to manage their waste. The list of captive facilities was developed based
on information obtained from RCRAInfo's Permit Module or from hazardous waste handlers'
web sites. Wastes sent to facilities that are not included in the list of captive facilities for a
particular CAP management category were not included in the analysis of demand on
captive management units.
• Step 2: Compile data on hazardous waste shipped offsite for management. EPA
referred to GM Offsite Forms in order to compile the following data for each waste stream:
- Reporting year;
- RCRA identification number of generating facility (i.e., shipper ID);
- Name of generating facility (i.e., shipper name);
- Page and subpage number;
174
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- Source code;
- Source code description;
- Form code;
- Form code description;
- EPA hazardous waste codes representing the waste;
- Waste description;
- Quantity of hazardous waste shipped (in tons);
- RCRA identification number of management facility (i.e., receiver ID); and
- Name of management facility (i.e., receiver name).
• Step 3: Separate mixed/low-level/radioactive wastes. To identify these wastes, EPA
conducted a word search on the waste description using the words/phrases: "radioactive,"
"mixed low level," "TRU," "mixed waste," "WIPP," and "transuranic." In addition, EPA
identified wastes sent to the following facilities:
RECEIVERJD
RECEIVER_NAME
NM4890139088
USDOE WASTE ISOLATION PILOT PLANT
NV3890090001
US DOE NNSA/NFO
NVD048946016
US ECOLOGY INC RADIOACTIVE WASTE SITE
TXD988088464
WASTE CONTROL SPECIALISTS
UTD982598898
ENERGYSOLUTIONS LLC
WA7890008967
US DEPT OF ENERGY HANFORD FACILITY
• Step 4: Separate wastes from specialty operations for explosive wastes and spent
potliners from primary aluminum reduction (i.e., K088 wastes). To identify these
wastes, EPA identified wastes sent to the following facilities:
RECEIVERJD
RECEIVER_NAME
ARD006354161
REYNOLDS METALS COMPANY
ARD980867873
ESTERLINE ARMTEC COUNTERMEASURES COMPANY
FL2800016121
CAPE CANAVERAL AFS
IAR000005876
ADVANCED ENVIRONMENTAL TECHNOLOGY
MND081138604
ALLIANT TECHSYSTEMS PROVING GROUNDS
MOD985798164
EBV EXPLOSIVES ENVIRONMENTAL COMPANY
NV5210090010
NEW BOMB FACILITY (HAWTHORNE ARMY DEPOT)
TXD987988318
SCHLUMBERGER WELL SERVICES PERFORATING AND
TESTING
UT0570090001
UTAH TEST AND TRAINING RANGE
UT3170027277
ATK LAUNCH SYSTEMS INC. - NIROP
UTD009081357
ATK LAUNCH SYSTEMS INC. - PROMONTORY
• Step 5: Separate wastes received from transfer/storage facilities. EPA identified
wastes received from transfer/storage facilities for further off-site treatment or disposal by
referring to the BR source code. In particular, EPA identified wastes represented by Source
Code G61 (i.e., hazardous waste received from off-site for storage/bulking and transfer off-
site for treatment or disposal).
175
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• Step 6: Determine total quantities managed at captive facilities for each CAP
management category. EPA summed the waste quantities by CAP management category.
3. Management of Hazardous Waste at Commercial Facilities
3.1. Key Data Sources
In performing the analysis, EPA used the following key data sources:
• 2011 Biennial Report, Generation and Management (GM) Form, Section 3 (Off-Site
Shipment of Hazardous Waste), i.e., GM Offsite Form. Data current as of
September 20, 2014.
• 2009 Biennial Report, Generation and Management (GM) Form, Section 3 (Off-Site
Shipment of Hazardous Waste), i.e., GM Offsite Form. Data current as of
September 29, 2014.
• RCRAInfo, Permit Module. Data current as of September 9-December 5, 2014.
• Hazardous waste handlers' web sites. Data current as of September 9-December 5, 2014.
3.2. Methodology
Following are the steps EPA undertook to estimate the quantities of hazardous waste managed
at commercial facilities for each of the CAP management categories. The steps described
below were conducted separately for 2011 and 2009 BR data.
• Step 1: Develop list of commercial management facilities. For each CAP management
category, EPA developed a list of commercial management facilities. This list was
developed based on information obtained from RCRAInfo's Permit Module, BR data, and
hazardous waste handlers' internet web sites. Wastes sent for commercial management at
facilities not included in the list of commercial facilities for a particular CAP management
category were not included in the analysis of demand on commercial management units.
• Step 2: Compile data on hazardous waste shipped offsite for management. EPA
referred to GM Offsite Forms in order to compile the following data for each waste stream:
- Reporting year;
- RCRA identification number of generating facility (i.e., shipper ID);
- Name of generating facility (i.e., shipper name);
- Page and subpage number;
- Source code;
- Source code description;
- Form code;
- Form code description;
- EPA hazardous waste codes representing the waste;
- Waste description;
- Quantity of hazardous waste shipped (in tons);
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- RCRA identification number of management facility (i.e., receiver ID); and
- Name of management facility (i.e., receiver name).
• Step 3: Correct obvious data errors. EPA identified and corrected obvious data errors,
including:
- Invalid RCRA identification numbers (i.e., typos in RCRA identification numbers).
Information on these identification numbers is provided in Attachment 2 at the end of this
appendix.
- Unit conversion errors. EPA identified and corrected one unit conversion error in the
GM Form data of the 2011 BR. Millenium Laboratories (RCRA identification number
CAL000328896) reported the generation of 20.50 tons (41,000 pounds) of organic
solvents. However, for this same waste stream, the facility reported that 20,400,000.10
tons (40,800,000,200 pounds) were shipped off site for management. To resolve this
issue, EPA revised the quantity shipped off site for management to 20.50 tons.
• Step 4: Separate mixed/low-level/radioactive wastes. To identify these wastes, EPA
conducted a word search on the waste description using the words/phrases: "radioactive,"
"mixed low level," "TRU," "mixed waste," "WIPP," and "transuranic." In addition, EPA
identified wastes sent to the following facilities:
RECEIVERJD
RECEIVER_NAME
NM4890139088
USDOE WASTE ISOLATION PILOT PLANT
NV3890090001
US DOE NNSA/NFO
NVD048946016
US ECOLOGY INC RADIOACTIVE WASTE SITE
TXD988088464
WASTE CONTROL SPECIALISTS
UTD982598898
ENERGYSOLUTIONS LLC
WA7890008967
US DEPT OF ENERGY HANFORD FACILITY
• Step 5: Separate explosive wastes managed using specialty operations for explosive
wastes and spent potliners from primary aluminum reduction (i.e., K088 wastes). To
identify these wastes, EPA identified wastes sent to the following facilities:
RECEIVERJD
RECEIVER_NAME
ARD006354161
REYNOLDS METALS COMPANY
ARD980867873
ESTERLINE ARMTEC COUNTERMEASURES COMPANY
FL2800016121
CAPE CANAVERAL AFS
IAR000005876
ADVANCED ENVIRONMENTAL TECHNOLOGY
MND081138604
ALLIANT TECHSYSTEMS PROVING GROUNDS
MOD985798164
EBV EXPLOSIVES ENVIRONMENTAL COMPANY
NV5210090010
NEW BOMB FACILITY (HAWTHORNE ARMY DEPOT)
TXD987988318
SCHLUMBERGER WELL SERVICES PERFORATING AND
TESTING
UT0570090001
UTAH TEST AND TRAINING RANGE
UT3170027277
ATK LAUNCH SYSTEMS INC. - NIROP
UTD009081357
ATK LAUNCH SYSTEMS INC. - PROMONTORY
177
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• Step 6: Separate wastes received from transfer/storage facilities. EPA identified
wastes received from transfer/storage facilities for further off-site treatment or disposal by
referring to the BR source code. In particular, EPA identified wastes represented by Source
Code G61 (i.e., hazardous waste received from off-site for storage/bulking and transfer off-
site for treatment or disposal).
• Step 7: Separate waste received from foreign countries. EPA identified wastes received
from foreign countries by referring to the BR source code. In particular, EPA identified
wastes represented by the following Source Code Group:
- Waste Not Physically Generated Onsite (i.e., Source Codes G63 through G75)
These wastes were analyzed separately.
• Step 8: Include quantities of wastes managed on site by facilities with commercial
units. EPA used available information on the type of commercial hazardous waste
management services provided by a facility, and included quantities of wastes managed in
commercial units by commercial hazardous waste management facilities.
• Step 9: Assign waste quantities to appropriate CAP Management Categories. EPA
used the BR management method codes and the definitions of the CAP management
categories in Attachment 1 at the end of this appendix to assign waste quantities to CAP
management categories.
• Step 10: Categorize wastes based on waste generation activity (i.e., process wastes
and cleanup wastes). For purposes of this analysis, EPA categorized waste streams
based on the type of process or activity from which the hazardous waste was generated. In
particular, EPA categorized waste streams as "process waste" or "cleanup waste." The
approach relies on source codes reported by facilities in their BR. Process wastes are those
represented by the following Source Code Groups:
- Wastes from Ongoing Production and Service Processes (i.e., Source Codes G01
through G09)
- Other Intermittent Events or Processes (i.e., Source Codes G11 through G19)
- Pollution Control and Waste Management Process Residuals (i.e., Source Codes G21
through G27)
- Spills and Accidental Releases (i.e., Source Codes G31 through G39)
Cleanup wastes are those represented by the following Source Code Group:
- Remediation of Past Contamination (i.e., Source Codes G41 through G49)
• Step 11: Determine total quantities managed at commercial facilities for each CAP
management category. EPA summed the waste quantities by CAP management category
and waste generation activity category.
• Step 12: Estimate average quantities for cleanup wastes. For cleanup wastes, EPA
took the average of the 2011 and 2009 waste quantities developed under Step 11. This
step was taken as a conservative approach in order to account for variations in the
generation of these one-time wastes. (Note: For process wastes, EPA used the waste
quantities for 2011.)
178
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4. Hazardous Waste Demand from Small Quantity Generators/Conditionally
Exempt Small Quantity Generators (SQGs/CESQGs) and Transfer/Storage
Facilities
4.1. Key Data Sources
In performing the analysis, EPA used the following key data sources:
• 2011 Biennial Report, Generation and Management (GM) Form, Section 3 (Off-Site
Shipment of Hazardous Waste), i.e., GM Offsite Form. Data current as of
September 20, 2014.
• 2011 Biennial Report, Waste Received from Off-Site (WR) Form. Data current as of
September 20, 2014.
• RCRAInfo, Permit Module. Data current as of September 9-December 5, 2014.
• Hazardous waste handlers' web sites. Data current as of September 9-December 5, 2014.
4.2. Methodology
Following are the steps EPA undertook to estimate hazardous waste demand from
SQGs/CESQGs and transfer/storage facilities for each of the CAP management categories:
• Step 1: Develop list of commercial management facilities. For each CAP management
category, EPA developed a list of commercial facilities. This list was developed based on
information obtained from RCRAInfo's Permit Module, BR data, and hazardous waste
handlers' web sites. Wastes sent to facilities that are not included in the list of commercial
facilities for a particular CAP management category were not included in the analysis of
demand on commercial management units.
• Step 2: Create list of facilities that shipped their hazardous waste directly to a
commercial hazardous waste management facility. EPA created a list of RCRA
identification numbers for facilities that, in their GM Offsite Forms, reported shipping wastes
directly to commercial hazardous waste management facilities.
• Step 3: Compile data on hazardous waste received from offsite for management.
EPA referred to WR Forms in order to compile the following data for each waste stream:
- Reporting year;
- RCRA identification number of management facility (i.e., receiver ID);
- Name of management facility (i.e., receiver name);
- Page and subpage number;
- Form code;
- Form code description;
- EPA hazardous waste codes representing the waste;
- Waste description;
- Quantity of hazardous waste received (in tons);
- RCRA identification number of shipping facility (i.e., shipper ID); and
- Name of shipping facility (i.e., shipper name).
179
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• Step 4: Identify facilities that shipped their wastes directly to commercial hazardous
waste management facilities. In the WR Form data, EPA compared the RCRA
identification number of the shippers to the list of RCRA identification numbers developed
under Step 2 (i.e., facilities that shipped their hazardous waste directly to a commercial
hazardous waste management facility). EPA then excluded WR Form data for cases in
which the RCRA identification number of the shipper is in the list of RCRA identification
numbers developed under Step 2. By doing this, EPA eliminated WR Form data for facilities
that shipped their wastes directly to commercial hazardous waste management facilities and
reported their wastes in a GM Offsite Form.
• Step 5: Separate mixed/low-level/radioactive wastes. To identify these wastes, EPA
conducted a word search on the waste description using the words/phrases: "radioactive,"
"mixed low level," "TRU," "mixed waste," "WIPP," and "transuranic." In addition, EPA
identified wastes sent to the following facilities:
RECEIVERJD
RECEIVER_NAME
NM4890139088
USDOE WASTE ISOLATION PILOT PLANT
NV3890090001
US DOE NNSA/NFO
NVD048946016
US ECOLOGY INC RADIOACTIVE WASTE SITE
TXD988088464
WASTE CONTROL SPECIALISTS
UTD982598898
ENERGYSOLUTIONS LLC
WA7890008967
US DEPT OF ENERGY HANFORD FACILITY
• Step 6: Separate explosive wastes managed by specialty operations for explosive
wastes and spent potliners from primary aluminum reduction (i.e., K088 wastes). To
identify these wastes, EPA identified wastes sent to the following facilities:
RECEIVERJD
RECEIVER_NAME
ARD006354161
REYNOLDS METALS COMPANY
ARD980867873
ESTERLINE ARMTEC COUNTERMEASURES COMPANY
FL2800016121
CAPE CANAVERAL AFS
IAR000005876
ADVANCED ENVIRONMENTAL TECHNOLOGY
MND081138604
ALLIANT TECHSYSTEMS PROVING GROUNDS
MOD985798164
EBV EXPLOSIVES ENVIRONMENTAL COMPANY
NV5210090010
NEW BOMB FACILITY (HAWTHORNE ARMY DEPOT)
TXD987988318
SCHLUMBERGER WELL SERVICES PERFORATING AND
TESTING
UT0570090001
UTAH TEST AND TRAINING RANGE
UT3170027277
ATK LAUNCH SYSTEMS INC. - NIROP
UTD009081357
ATK LAUNCH SYSTEMS INC. - PROMONTORY
• Step 7: Separate waste received from foreign countries. To identify wastes received
from foreign countries, EPA used the first two letters of the RCRA identification number of
the shipper. In particular, EPA identified RCRA identification numbers that begin with "FC".
180
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• Step 8: Assign waste quantities to appropriate CAP Management Categories. EPA
used the BR management method codes and the definitions of the CAP management
categories in Attachment 1 at the end of this appendix to assign waste quantities to CAP
management categories.
• Step 9: Determine quantities managed on site for each CAP management category.
EPA summed the waste quantities by CAP management category.
5. Hazardous Waste Demand from Waste Imported from Foreign Countries
5.1. Key Data Sources
In performing the analysis, EPA used the following key data sources:
• 2011 Biennial Report, Generation and Management (GM) Form, Section 3 (Off-Site
Shipment of Hazardous Waste), i.e., GM Offsite Form. Data current as of
September 20, 2014.
• 2011 Biennial Report, Waste Received from Off-Site (WR) Form. Data current as of
September 20, 2014.
• RCRAInfo, Permit Module. Data current as of September 9-December 5, 2014.
• Hazardous waste handlers' web sites. Data current as of September 9-December 5, 2014.
5.2. Methodology
Following are the steps EPA undertook to estimate the quantities of hazardous waste received
from foreign countries for each of the CAP management categories:
• Step 1: Develop list of commercial facilities. For each CAP management category, EPA
developed a list of commercial facilities. This list was developed based on information
obtained from RCRAInfo's Permit Module or from hazardous waste handlers' web sites.
Wastes sent to facilities that are not included in the list of commercial facilities for a
particular CAP management category were not included in the analysis of demand on
commercial management units.
GM Offsite Form Data
• Step 2: Compile data on hazardous waste shipped offsite for management. EPA
referred to GM Offsite Forms in order to compile the following data for each waste stream:
- Reporting year;
- RCRA identification number of generating facility (i.e., shipper ID);
- Name of generating facility (i.e., shipper name);
- Page and subpage number;
- Source code;
- Source code description;
- Form code;
- Form code description;
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- EPA hazardous waste codes representing the waste;
- Waste description;
- Quantity of hazardous waste shipped (in tons);
- RCRA identification number of management facility (i.e., receiver ID); and
- Name of management facility (i.e., receiver name).
• Step 3: Separate mixed/low-level/radioactive wastes. To identify these wastes, EPA
conducted a word search on the waste description using the words/phrases: "radioactive,"
"mixed low level," "TRU," "mixed waste," "WIPP," and "transuranic." In addition, EPA
identified wastes sent to the following facilities:
RECEIVERJD
RECEIVER_NAME
NM4890139088
USDOE WASTE ISOLATION PILOT PLANT
NV3890090001
US DOE NNSA/NFO
NVD048946016
US ECOLOGY INC RADIOACTIVE WASTE SITE
TXD988088464
WASTE CONTROL SPECIALISTS
UTD982598898
ENERGYSOLUTIONS LLC
WA7890008967
US DEPT OF ENERGY HANFORD FACILITY
• Step 4: Separate wastes from specialty operations for explosive wastes and spent
potliners from primary aluminum reduction (i.e., K088 wastes). To identify these
wastes, EPA identified wastes sent to the following facilities:
RECEIVERJD
RECEIVER_NAME
ARD006354161
REYNOLDS METALS COMPANY
ARD980867873
ESTERLINE ARMTEC COUNTERMEASURES COMPANY
FL2800016121
CAPE CANAVERAL AFS
IAR000005876
ADVANCED ENVIRONMENTAL TECHNOLOGY
MND081138604
ALLIANT TECHSYSTEMS PROVING GROUNDS
MOD985798164
EBV EXPLOSIVES ENVIRONMENTAL COMPANY
NV5210090010
NEW BOMB FACILITY (HAWTHORNE ARMY DEPOT)
TXD987988318
SCHLUMBERGER WELL SERVICES PERFORATING AND
TESTING
UT0570090001
UTAH TEST AND TRAINING RANGE
UT3170027277
ATK LAUNCH SYSTEMS INC. - NIROP
UTD009081357
ATK LAUNCH SYSTEMS INC. - PROMONTORY
• Step 5: Identify waste received from foreign countries. EPA identified wastes received
from foreign countries by referring to the BR source code. In particular, EPA identified
wastes represented by the following Source Code Group:
- Waste Not Physically Generated Onsite (i.e., Source Codes G63 through G75)
• Step 6: Assign waste quantities to appropriate CAP Management Categories. EPA
used the BR management method codes and the definitions of the CAP management
182
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categories in Attachment 1 at the end of this appendix to assign waste quantities to CAP
management categories.
• Step 7; Determine quantities received from foreign countries for each CAP
management category. EPA summed the waste quantities by CAP management category.
WR Form Data
• Step 8: Compile data on hazardous waste received from off site for management.
EPA referred to WR Forms in order to compile the following data for each waste stream:
- Reporting year;
- RCRA identification number of management facility (i.e., receiver ID);
- Name of management facility (i.e., receiver name);
- Page and subpage number;
- Form code;
- Form code description;
- EPA hazardous waste codes representing the waste;
- Waste description;
- Quantity of hazardous waste received (in tons);
- RCRA identification number of shipping facility (i.e., shipper ID); and
- Name of shipping facility (i.e., shipper name).
• Step 9: Separate mixed/low-level/radioactive wastes. To identify these wastes, EPA
conducted a word search on the waste description using the words/phrases: "radioactive,"
"mixed low level," "TRU," "mixed waste," "WIPP," and "transuranic." In addition, EPA
identified wastes sent to the following facilities:
RECEIVERJD
RECEIVER_NAME
NM4890139088
USDOE WASTE ISOLATION PILOT PLANT
NV3890090001
US DOE NNSA/NFO
NVD048946016
US ECOLOGY INC RADIOACTIVE WASTE SITE
TXD988088464
WASTE CONTROL SPECIALISTS
UTD982598898
ENERGYSOLUTIONS LLC
WA7890008967
US DEPT OF ENERGY HANFORD FACILITY
• Step 10: Separate wastes from specialty operations for explosive wastes and spent
potliners from primary aluminum reduction (i.e., K088 wastes). To identify these
wastes, EPA identified wastes sent to the following facilities:
RECEIVERJD
RECEIVER_NAME
ARD006354161
REYNOLDS METALS COMPANY
ARD980867873
ESTERLINE ARMTEC COUNTERMEASURES COMPANY
FL2800016121
CAPE CANAVERAL AFS
IAR000005876
ADVANCED ENVIRONMENTAL TECHNOLOGY
MND081138604
ALLIANT TECHSYSTEMS PROVING GROUNDS
MOD985798164
EBV EXPLOSIVES ENVIRONMENTAL COMPANY
183
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RECEIVERJD
RECEIVER_NAME
NV5210090010
NEW BOMB FACILITY (HAWTHORNE ARMY DEPOT)
TXD987988318
SCHLUMBERGER WELL SERVICES PERFORATING AND
TESTING
UT0570090001
UTAH TEST AND TRAINING RANGE
UT3170027277
ATK LAUNCH SYSTEMS INC. - NIROP
UTD009081357
ATK LAUNCH SYSTEMS INC. - PROMONTORY
• Step 11: Identify waste received from foreign countries. To identify wastes received
from foreign countries, EPA used the first two letters of the RCRA identification number of
the shipper. In particular, EPA identified RCRA identification numbers that begin with "FC."
• Step 12: Assign waste quantities to appropriate CAP Management Categories. EPA
used the BR management method codes and the definitions of the CAP management
categories in Attachment 1 at the end of this appendix to assign waste quantities to CAP
management categories.
• Step 13: Determine quantities received from foreign countries for each CAP
management category. EPA summed the waste quantities by CAP management category.
GM Offsite and WR Form Data
• Step 14: Determine total quantities received from foreign countries for each CAP
management category. EPA summed the waste quantities from GM Offsite Forms
(Step 7) and WR Forms (Step 13) to calculate the total quantities received from foreign
countries by CAP management category.
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Attachment 1
CAP Management Categories
For purposes of this analysis, the U.S. Environmental Protection Agency (EPA) categorized
Biennial Report (BR) management method codes into Capacity Assurance Plan (CAP)
management categories based on the similarities in their design, operation, or wastes treated.
The CAP management categories are described in the table below, and were used in assessing
Subtitle C hazardous waste demand. The CAP management categories are consistent with the
management categories in the Biennial Report Analytical Methodologies approved by the
RCRAInfo Change Management Process (CMP) on April 22, 2013.
CAP Management Category
2011 BR Management Method Code and Description
RECOVERY
Metals Recovery
H010
Metals recovery including retorting, smelting, chemical,
etc.
Solvents Recovery
H020
Solvents recovery (distillation, extraction, etc.)
Inorganics Recovery
H039
Other recovery or reclamation for reuse including acid
regeneration, organics recovery, etc. (specify in
comments)
Energy Recovery
H050
Energy recovery at this site - used as fuel (includes on-
site fuel blending before energy recovery; report only
this code)
TREATMENT
Fuel Blending
H061
Fuel blending prior to energy recovery at another site
(waste generated either on-site or received from off-
site)
Incineration
H040
Incineration - thermal destruction other than use as a
fuel (includes any preparation prior to burning)
H071
Chemical reduction with or without precipitation
(includes any preparation or final processes for
consolidation of residuals)
H073
Cyanide destruction with or without precipitation
(includes any preparation or final processes for
consolidation of residuals)
Wastewater Treatment
H075
Chemical oxidation (includes any preparation or final
processes for consolidation of residuals)
H076
Wet air oxidation (includes any preparation or final
processes for consolidation of residuals)
H077
Other chemical precipitation with or without pre-
treatment (includes processes for consolidation of
residuals)
186
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CAP Management Category
2011 BR Management Method Code and Description
Wastewater Treatment
(continued)
H081
Biological treatment with or without precipitation
(includes any preparation or final processes for
consolidation of residuals)
H082
Adsorption (as the major component of treatment)
H083
Air or steam stripping (as the major component of
treatment)
H103
Absorption (as the major component of treatment)
H121
Neutralization only (no other treatment)
H122
Evaporation (as the major component of treatment; not
reportable as H071-H083)
H123
Settling or clarification (as the major component of
treatment; not reportable as H071-H083)
H124
Phase separation (as the major component of
treatment; not reportable as H071-H083)
H129
Other treatment (specify in comments; not reportable
as H071-H124)
Sludge Treatment/
Stabilization/Encapsulation
H101
Sludge treatment and/or dewatering (as the major
component of treatment; not H071-H075, H077, or
H082)
H111
Stabilization or chemical fixation prior to disposal at
another site (as the major component of treatment; not
H071-H075, H077, or H082)
H112
Macro-encapsulation prior to disposal at another site
(as the major component of treatment; not reportable
as H071-H075, H077, or H082)
DISPOSAL
Land Treatment or Application
H131
Land treatment or application (to include any prior
treatment and/or stabilization)
Landfill
H132
Landfill or surface impoundment that will be closed as
landfill (to include prior treatment and/or stabilization)
Deepwell or Underground Injection
H134
Deepwell or underground injection (with or without
treatment; this waste was counted as hazardous
waste)
Transfer/Storage
H141
The site receiving this waste stored/bulked and
transferred the waste with no treatment or recovery
(H010-H129), fuel blending (H061), ordisposal (H131-
H135) at that receiving site
187
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Attachment 2
CAP Management Categories
In conducting the national capacity assessment, the U.S. Environmental Protection Agency
(EPA) identified RCRA identification numbers reported for off-site handlers in Generation and
Management (GM) Forms of the 2011 Biennial Report (BR) that did not meet the conventional
RCRA identification number criteria: (1) first two characters represent a state abbreviation;
(2) third character is a letter or number, and (3) last nine characters are numbers. These RCRA
identification numbers, shown in the table below, were considered to be invalid and the Agency
made an effort to identify the correct RCRA identification number using readily available data
sources (e.g., RCRAInfo's Handler Module).
REPORTED_RECEIVER_ID
ASSUMED_RECEIVER_ID
ASSUMED_RECEIVER_NAME
ALD000062246
ALD000622464
CHEMICAL WASTE MANAGEMENT
ALD000622462
ALD000622464
CHEMICAL WASTE MANAGEMENT
ALD000622624
ALD000622464
CHEMICAL WASTE MANAGEMENT
ALD067513767
ALD070513767
GIANT RESOURCE RECOVERY-ATTALLA, INC.
ALD070513376
ALD070513767
GIANT RESOURCE RECOVERY-ATTALLA, INC.
ALD070513761
ALD070513767
GIANT RESOURCE RECOVERY-ATTALLA, INC.
ALD070513762
ALD070513767
GIANT RESOURCE RECOVERY-ATTALLA, INC.
ALD705513767
ALD070513767
GIANT RESOURCE RECOVERY-ATTALLA, INC.
ALD961020694
ALD981020894
EWS ALABAMA INC.
ALD981020892
ALD981020894
EWS ALABAMA INC.
ALD981070894
ALD981020894
EWS ALABAMA INC.
AR0069748192
ARD069748192
CLEAN HARBORS EL DORADO
AR981057870
ARD981057870
RINECO CHEMICAL INDUSTRIES, INC.
ARD009748192
ARD069748192
CLEAN HARBORS EL DORADO
ARD049748192
ARD069748192
CLEAN HARBORS EL DORADO
ARD058178192
ARD069748192
CLEAN HARBORS EL DORADO
ARD059748192
ARD069748192
CLEAN HARBORS EL DORADO
ARD066748192
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TNR00022277
TNR000022277
MASTERMELT AMERICA, LLC
TNR000772186
TND000772186
TRADEBE TREATMENT & RECYCLING OF TENNESSEE, LLC
TX0981514383
TXD981514383
ALPHA OMEGA RECYCLING
TXD000388896
TXD000838896
VEOLIA ES TECHNICAL SOLUTIONS
TXD000638896
TXD000838896
VEOLIA ES TECHNICAL SOLUTIONS
TXD000838396
TXD000838896
VEOLIA ES TECHNICAL SOLUTIONS
TXD000838696
TXD000838896
VEOLIA ES TECHNICAL SOLUTIONS
TXD000838806
TXD000838896
VEOLIA ES TECHNICAL SOLUTIONS
TXD000838893
TXD000838896
VEOLIA ES TECHNICAL SOLUTIONS
TXD000838898
TXD000838896
VEOLIA ES TECHNICAL SOLUTIONS
TXD000898896
TXD000838896
VEOLIA ES TECHNICAL SOLUTIONS
TXD007603371
TXD077603371
SAFETY-KLEEN SYSTEMS DENTON RECYCLE CENTER
TXD055141368
TXD055141378
CLEAN HARBORS DEER PARK
TXD055141376
TXD055141378
CLEAN HARBORS DEER PARK
TXD05514378
TXD055141378
CLEAN HARBORS DEER PARK
TXD055147318
TXD055141378
CLEAN HARBORS DEER PARK
TXD076603371
TXD077603371
SAFETY-KLEEN SYSTEMS DENTON RECYCLE CENTER
TXD982280149
TXD982290140
CLEAN HARBORS LAPORTE
TXD00 0838896
TXD000838896
VEOLIA ES TECHNICAL SOLUTIONS
TXR077603371
TXD077603371
SAFETY-KLEEN SYSTEMS DENTON RECYCLE CENTER
194
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REPORTED_RECEIVER_ID
ASSUMED_RECEIVER_ID
ASSUMED_RECEIVER_NAME
UTD081552177
UTD981552177
CLEAN HARBORS ARAGONITE, LLC
UTD098155216
UTD981552177
CLEAN HARBORS ARAGONITE, LLC
UTD098155217
UTD981552177
CLEAN HARBORS ARAGONITE, LLC
UTD891552117
UTD981552177
CLEAN HARBORS ARAGONITE, LLC
UTD951552177
UTD981552177
CLEAN HARBORS ARAGONITE, LLC
UTD961552177
UTD981552177
CLEAN HARBORS ARAGONITE, LLC
UTD968155217
UTD981552177
CLEAN HARBORS ARAGONITE, LLC
UTD981155177
UTD981552177
CLEAN HARBORS ARAGONITE, LLC
UTD981532177
UTD981552177
CLEAN HARBORS ARAGONITE, LLC
UTD981552117
UTD981552177
CLEAN HARBORS ARAGONITE, LLC
UTD981552171
UTD981552177
CLEAN HARBORS ARAGONITE, LLC
UTD981582177
UTD981552177
CLEAN HARBORS ARAGONITE, LLC
UTD981K55217
UTD981552177
CLEAN HARBORS ARAGONITE, LLC
UTD982552177
UTD981552177
CLEAN HARBORS ARAGONITE, LLC
UTD982598878
UTD982598898
ENERGYSOLUTIONS LLC
UTD998155217
UTD981552177
CLEAN HARBORS ARAGONITE, LLC
UTG981552177
UTD981552177
CLEAN HARBORS ARAGONITE, LLC
WAD991821767
WAD991281767
BURLINGTON ENVIRONMENTAL LLC KENT
WID003067148
WID003967148
VEOLIA ES TECHNICAL SOLUTIONS LLC
WID388566543
WID988566543
VEOLIA ES TECHNICAL SOLUTIONS LLC
WID788566543
WID988566543
VEOLIA ES TECHNICAL SOLUTIONS LLC
WID980829475
WID990829475
WRR ENVIRONMENTAL SERVICES CO INC
WID988566643
WID988566543
VEOLIA ES TECHNICAL SOLUTIONS LLC
WID988580058
WID988580056
BADGER DISPOSAL OF Wl INC
WID988666543
WID988566543
VEOLIA ES TECHNICAL SOLUTIONS LLC
WID989566543
WID988566543
VEOLIA ES TECHNICAL SOLUTIONS LLC
WID998580056
WID988580056
BADGER DISPOSAL OF Wl INC
WIDOQ3967148
WID003967148
VEOLIA ES TECHNICAL SOLUTIONS LLC
195
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Appendix E
Demand and Capacity at
Commercial Hazardous Waste Specialty Operations Facilities
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Demand and Capacity at
Commercial Hazardous Waste Specialty Operations Facilities
Some commercial hazardous waste management facilities have units specifically designed for
the unique management required by certain wastes. These units typically are permitted to meet
the exact specifications of the unique waste stream, and are not available for management of all
waste types.
This appendix provides information on commercial hazardous waste specialty operations
facilities designed for the management of mixed RCRA wastes, explosives wastes, or spent
potliners from primary aluminum reduction (i.e., EPA listed K088 wastes).
1. Facilities Designed for the Management of Mixed RCRA Wastes
Based on data reported in the Hazardous Waste Report (also known as the Biennial Report or
BR) and obtained through limited consultations with commercial management facilities, each
year, about 2,600 tons of wastes are managed at the two commercial landfill facilities listed
below, which are designed primarily for the management of mixed wastes. This quantity of
waste translates into 65,000 tons over a 25-year period (i.e., 2,600 tons/year x 25 years).
RCRA Identification Number
Facility Name
TXD988088464
WASTE CONTROL SPECIALISTS
UTD982598898
ENERGYSOLUTIONS LLC
EPA estimates an additional annual demand for commercial capacity of 620 tons from Small
Quantity Generators/Conditionally Exempt Small Quantity Generators (SQGs/CESQGs) and
transfer/storage facilities (refer to Appendix D for the methodology used to derive this estimate),
which translates into a demand of 15,500 tons over a 25-year period. Thus, the demand from
mixed wastes is estimated to be 80,500 tons (i.e., 65,000 tons + 15,500 tons) over a 25-year
period (i.e., through the year 2039).
For purposes of this analysis, EPA assumes that the total currently permitted and available
landfill capacity for mixed wastes is 566,302 tons. This estimate is based on permitted and
available capacity for one of the two mixed waste landfills because one facility did not provide
current information on remaining permitted capacity. (Refer to Appendix A for information
obtained through consultations.)
Based on the above information, EPA determined that there is sufficient capacity to manage
mixed wastes.
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2. Facilities Designed for the Management of Explosive Wastes
Based on data reported in Section 3 of Generation and Management (GM) Forms of the BR
(i.e., GM Offsite Forms) and information obtained through limited consultations with commercial
management facilities, each year, about 8,500 tons of explosive wastes are managed at the
commercial hazardous waste management facilities listed below.12 All of these facilities have
permitted Subpart X units (i.e., open burning/open detonation units [X01 units] or thermal units
[X03 units]).
RCRA Identification Number
Facility Name
IAR000005876
ADVANCED ENVIRONMENTAL TECHNOLOGY
MOD985798164
EBV EXPLOSIVES ENVIRONMENTAL COMPANY
TXD987988318
SCHLUMBERGER WELL SERVICES PERFORATING AND TESTING
UT3170027277
ATK LAUNCH SYSTEMS INC. - NIROP
UTD009081357
ATK LAUNCH SYSTEMS INC. - PROMONTORY
EPA estimates an additional demand for commercial capacity of 36 tons from SQGs/CESQGs
and transfer/storage facilities (refer to Appendix D for the methodology used to derive this
estimate), and a demand of 430 tons from non-RCRA industrial wastes13. Thus, the demand
from explosive wastes is estimated to be about 9,000 tons per year.
Most of the demand from explosive wastes (about 73%) is managed by one facility: EBV
Explosives Environmental Company. This facility has one commercial unit currently operating
that has been designed exclusively for the treatment of explosive wastes. Based on
consultation with the EBV Explosives Environmental Company, the facility has a capacity of
22,850 tons per year for the treatment of explosive wastes (refer to Appendix A).
Based on the above information, EPA determined that there is sufficient capacity to manage
explosive wastes.
3. Facilities Designed for the Management of Spent Potliners from Primary
Aluminum Reduction
Based on data reported in GM Offsite Forms of the BR, about 24,000 tons of K088 waste were
shipped off site for incineration at U.S. commercial hazardous waste management facilities in
2011. In addition, EPA estimates that about 1,300 tons were shipped to foreign countries for
incineration. Thus, the incineration demand from K088 waste is estimated to be 25,300 tons per
year.
Most of the incineration demand from K088 waste (about 47%) is managed by one facility:
Reynolds Metals Company Gum Springs Plant (RCRA identification number ARD006354161).
12 Based on GM Offsite Form data, about 2,400 tons of explosive wastes were shipped off site for management in
2011. About 73 percent of the total quantity of waste reported in GM Offsite Forms was managed by the EBV
Explosives Environmental Company. Note, however, that, during consultation, this facility indicated that they
manage about 6,169 tons of explosive wastes per year (refer to Appendix A). In estimating demand from explosive
wastes, EPA assumed that 6,169 tons accounted for 73 percent of the total amount of explosive wastes.
13 Based on consultations, it is estimated that non-RCRA industrial wastes account for 5 percent of total demand
(i.e., [process waste] + [SQG/CESQand transfer/storage facilities]).
199
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This facility has one commercial incinerator that treats primarily K088 waste from Reynolds
Metals Company plants as well as from non-Reynolds Metals Company sources. Based on
consultation with the Reynolds Metals Company, the incinerator at the Gum Springs Plant has a
capacity of 120,000 tons per year (refer to Appendix A).
Based on the above information, EPA determined that there is sufficient capacity to manage
K088 waste.
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Appendix F
1993 Guidance
202
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[Insert document, which is available in PDF format only
(httpi/Zinfohouse. p2ric.org/ref/23/22567.pdf).
The document's cover is provided as a reference.]
OSW£» Oinci**
90VC32
itoy - 99j
0o» Sons w» r • and
Ewycy Amporw
Guidance For Capacity
Assurance Planning
Capacity Planning Pursuant to
CERCLA§104(c)(9)
204
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205
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Appendix G
States' Comments on
1989 Capacity Assurance Planning Process
206
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207
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[Insert document, which is available in PDF format only.
The document's cover is provided as a reference.]
Hazardous Waste
Management in the States
A knifv rt/the * *yw>rv
f I ¦wi imm KArt tl w t
NmMWI (1 f«T« M»»* IwwvlM
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