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


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• 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

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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

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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.

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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.

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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


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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)

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.

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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).

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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.

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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.

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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.

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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.

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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

48


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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

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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
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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

79


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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

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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

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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.

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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



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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.

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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

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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 
-------
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.

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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

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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.

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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

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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

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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


-------
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


-------
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


-------
Appendix B

Commercial Hazardous Waste Management Facilities

130


-------
[Page intentionally left blank.]

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


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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


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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


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Appendix C
CAP Management Categories

158


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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

163


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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;

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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).

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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

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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.)

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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).

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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".

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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

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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

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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.

184


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185


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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

ARD069748192

CLEAN HARBORS EL DORADO

ARD067748192

ARD069748192

CLEAN HARBORS EL DORADO

ARD069478192

ARD069748192

CLEAN HARBORS EL DORADO

ARD069742192

ARD069748192

CLEAN HARBORS EL DORADO

ARD069748102

ARD069748192

CLEAN HARBORS EL DORADO

ARD069748182

ARD069748192

CLEAN HARBORS EL DORADO

ARD069748193

ARD069748192

CLEAN HARBORS EL DORADO

ARD069748195

ARD069748192

CLEAN HARBORS EL DORADO

ARD069748197

ARD069748192

CLEAN HARBORS EL DORADO

ARD069748992

ARD069748192

CLEAN HARBORS EL DORADO

ARD069749192

ARD069748192

CLEAN HARBORS EL DORADO

ARD069774819

ARD069748192

CLEAN HARBORS EL DORADO

ARD069784192

ARD069748192

CLEAN HARBORS EL DORADO

ARD091057870

ARD981057870

RINECO CHEMICAL INDUSTRIES, INC.

ARD098105787

ARD981057870

RINECO CHEMICAL INDUSTRIES, INC.

ARD697481962

ARD069748192

CLEAN HARBORS EL DORADO

ARD901057870

ARD981057870

RINECO CHEMICAL INDUSTRIES, INC.

ARD961057870

ARD981057870

RINECO CHEMICAL INDUSTRIES, INC.

ARD980105787

ARD981057870

RINECO CHEMICAL INDUSTRIES, INC.

188


-------
REPORTED_RECEIVER_ID

ASSUMED_RECEIVER_ID

ASSUMED_RECEIVER_NAME

ARD980157870

ARD981057870

RINECO CHEMICAL INDUSTRIES, INC.

ARD981057570

ARD981057870

RINECO CHEMICAL INDUSTRIES, INC.

ARD981057670

ARD981057870

RINECO CHEMICAL INDUSTRIES, INC.

ARD981057780

ARD981057870

RINECO CHEMICAL INDUSTRIES, INC.

ARD98105787

ARD981057870

RINECO CHEMICAL INDUSTRIES, INC.

ARD981057871

ARD981057870

RINECO CHEMICAL INDUSTRIES, INC.

ARD981057874

ARD981057870

RINECO CHEMICAL INDUSTRIES, INC.

ARD981057970

ARD981057870

RINECO CHEMICAL INDUSTRIES, INC.

ARD981058870

ARD981057870

RINECO CHEMICAL INDUSTRIES, INC.

ARD981067870

ARD981057870

RINECO CHEMICAL INDUSTRIES, INC.

ARD981512170

ARD981512270

ASH GROVE CEMENT COMPANY

ARO069748192

ARD069748192

CLEAN HARBORS EL DORADO

AZD000337360

AZ0000337360

VEOLIA ES TECHNICAL SOLUTIONS, L.L.C.

AZD098073550

AZD980735500

WORLD RESOURCES COMPANY

AZD908735500

AZD980735500

WORLD RESOURCES COMPANY

AZD980725500

AZD980735500

WORLD RESOURCES COMPANY

AZD980733500

AZD980735500

WORLD RESOURCES COMPANY

AZD980895332

AZD980695332

GANNON & SCOTT PHOENIX, INC

AZD98735500

AZD980735500

WORLD RESOURCES COMPANY

AZ0000337360

AZ0000337360

VEOLIA ES TECHNICAL SOLUTIONS, L.L.C.

AZR050010685

AZT050010685

HVF PRECIOUS METALS

AZT05010685

AZT050010685

HVF PRECIOUS METALS

AZT060010685

AZT050010685

HVF PRECIOUS METALS

CAD000646117

CAT000646117

CHEMICAL WASTE MANAGEMENT, INC.

CAD005302903

CAD008302903

VEOLIA ES TECHNICAL SOLUTIONS, L.L.C.

CAD006252406

CAD008252406

PACIFIC RESOURCE RECOVERY

CAD008252405

CAD008252406

PACIFIC RESOURCE RECOVERY

CAD008262405

CAD008252405

PACIFIC RESOURCE RECOVERY

CAD008374432

CAD008364432

RHO-CHEM LLC

CAD008488026

CAD008488025

PHIBRO-TECH INC.

CAD00848825

CAD008488025

PHIBRO-TECH INC.

CAD008848802

CAD008488025

PHIBRO-TECH INC.

CAD068488025

CAD008488025

PHIBRO-TECH INC.

CAD080013352

CAT080013352

DEMENNO KERDOON

CAD082252405

CAD008252405

PACIFIC RESOURCE RECOVERY

CAD950675276

CAD980675276

CLEAN HARBORS BUTTONWILLOW, LLC

CAD962062797

CAD982052797

J&B ENTERPRISES

CAD980067276

CAD980675276

CLEAN HARBORS BUTTONWILLOW, LLC

CAD980067526

CAD980675276

CLEAN HARBORS BUTTONWILLOW, LLC

CAD980657276

CAD980675276

CLEAN HARBORS BUTTONWILLOW, LLC

CAD980857276

CAD980675276

CLEAN HARBORS BUTTONWILLOW, LLC

CAD980875276

CAD980675276

CLEAN HARBORS BUTTONWILLOW, LLC

CAD982062797

CAD982052797

J&B ENTERPRISES

CAD982952797

CAD982052797

J&B ENTERPRISES

CAR008252405

CAD008252405

PACIFIC RESOURCE RECOVERY

CAT008302903

CAD008302903

VEOLIA ES TECHNICAL SOLUTIONS, L.L.C.

CTD000804488

CTD000604488

CLEAN HARBORS OF CT INC

CTD002593867

CTD002593887

BRIDGEPORT UNITED RECYCLING

FLD000207449

FL0000207449

VEOLIA ES TECHNICAL SOLUTIONS, L.L.C.

IDD073114554

IDD073114654

US ECOLOGY IDAHO INC SITE B

189


-------
REPORTED_RECEIVER_ID

ASSUMED_RECEIVER_ID

ASSUMED_RECEIVER_NAME

IDL000666206

ILD000666206

ENVIRITE OF ILLINOIS INC

IDL088642424

ILD098642424

VEOLIA ES TECHNICAL SOLUTIONS

ILD000666203

ILD000666206

ENVIRITE OF ILLINOIS INC

ILD000666208

ILD000666206

ENVIRITE OF ILLINOIS INC

ILD005067630

ILD005087630

SIMS RECYCLING SOLUTIONS INC

ILD008087630

ILD005087630

SIMS RECYCLING SOLUTIONS INC

ILD008642424

ILD098642424

VEOLIA ES TECHNICAL SOLUTIONS

ILD009864242

ILD098642424

VEOLIA ES TECHNICAL SOLUTIONS

ILD038642424

ILD098642424

VEOLIA ES TECHNICAL SOLUTIONS

ILD088642424

ILD098642424

VEOLIA ES TECHNICAL SOLUTIONS

ILD088648424

ILD098642424

VEOLIA ES TECHNICAL SOLUTIONS

ILD096642424

ILD098642424

VEOLIA ES TECHNICAL SOLUTIONS

ILD098624241

ILD098642424

VEOLIA ES TECHNICAL SOLUTIONS

ILD098624424

ILD098642424

VEOLIA ES TECHNICAL SOLUTIONS

ILD098641424

ILD098642424

VEOLIA ES TECHNICAL SOLUTIONS

ILD098842424

ILD098642424

VEOLIA ES TECHNICAL SOLUTIONS

ILD099842424

ILD098642424

VEOLIA ES TECHNICAL SOLUTIONS

ILD380613913

ILD980613913

SAFETY KLEEN SYSTEMS INC

ILD900613913

ILD980613913

SAFETY KLEEN SYSTEMS INC

ILD963613913

ILD980613913

SAFETY KLEEN SYSTEMS INC

ILD980613513

ILD980613913

SAFETY KLEEN SYSTEMS INC

ILD980613915

ILD980613913

SAFETY KLEEN SYSTEMS INC

ILD988613913

ILD980613913

SAFETY KLEEN SYSTEMS INC

ILD098642424

ILD098642424

VEOLIA ES TECHNICAL SOLUTIONS

IN0000351386

IN0000351387

LIGHTING RESOURCES INC

INC000646943

IND000646943

TRADEBE TREATMENT & RECYCLING LLC

INC00064943

IND000646943

TRADEBE TREATMENT & RECYCLING LLC

IND000046943

IND000646943

TRADEBE TREATMENT & RECYCLING LLC

IND000064694

IND000646943

TRADEBE TREATMENT & RECYCLING LLC

IND000351387

IN0000351387

LIGHTING RESOURCES INC

IND000419212

IND006419212

LONE STAR GREENCASTLE WDF

IND000545943

IND000646943

TRADEBE TREATMENT & RECYCLING LLC

IND000546943

IND000646943

TRADEBE TREATMENT & RECYCLING LLC

IND000616943

IND000646943

TRADEBE TREATMENT & RECYCLING LLC

IND000642943

IND000646943

TRADEBE TREATMENT & RECYCLING LLC

IND000645943

IND000646943

TRADEBE TREATMENT & RECYCLING LLC

IND000646843

IND000646943

TRADEBE TREATMENT & RECYCLING LLC

IND000646941

IND000646943

TRADEBE TREATMENT & RECYCLING LLC

IND000646942

IND000646943

TRADEBE TREATMENT & RECYCLING LLC

IND000646947

IND000646943

TRADEBE TREATMENT & RECYCLING LLC

IND000648943

IND000646943

TRADEBE TREATMENT & RECYCLING LLC

IND000846943

IND000646943

TRADEBE TREATMENT & RECYCLING LLC

IND000949943

IND000646943

TRADEBE TREATMENT & RECYCLING LLC

IND005419212

IND006419212

GREENCASTLE WDF FACILITY

IND006081542

IND005081542

ESSROC CEMENT CORPORATION

IND006410212

IND006419212

GREENCASTLE WDF FACILITY

IND006418212

IND006419212

GREENCASTLE WDF FACILITY

IND008419212

IND006419212

GREENCASTLE WDF FACILITY

IND932190012

IND093219012

HERITAGE ENVIRONMENTAL SERVICES LLC

INDOOQ646943

IND000646943

GREENCASTLE WDF FACILITY

190


-------
REPORTED_RECEIVER_ID

ASSUMED_RECEIVER_ID

ASSUMED_RECEIVER_NAME

IN0000351387

IN0000351387

LIGHTING RESOURCES INC

IN0005081542

IND005081542

ESSROC CEMENT CORPORATION

KS0980633259

KSD980633259

SYSTECH ENVIRONMENTAL CORP

KSD090633259

KSD980633259

SYSTECH ENVIRONMENTAL CORP

KSD980063325

KSD980633259

SYSTECH ENVIRONMENTAL CORP

KSD980533259

KSD980633259

SYSTECH ENVIRONMENTAL CORP

KSD980633258

KSD980633259

SYSTECH ENVIRONMENTAL CORP

KSD980633269

KSD980633259

SYSTECH ENVIRONMENTAL CORP

KSD980653259

KSD980633259

SYSTECH ENVIRONMENTAL CORP

KSD980663259

KSD980633259

SYSTECH ENVIRONMENTAL CORP

KSD980833259

KSD980633259

SYSTECH ENVIRONMENTAL CORP

KSD990633259

KSD980633259

SYSTECH ENVIRONMENTAL CORP

KSD998063325

KSD980633259

SYSTECH ENVIRONMENTAL CORP

KY053348108

KYD053348108

SAFETY-KLEEN SYSTEMS, INC.

KYD033348108

KYD053348108

SAFETY-KLEEN SYSTEMS, INC.

KYD033348188

KYD053348108

SAFETY-KLEEN SYSTEMS, INC.

KYD050348108

KYD053348108

SAFETY-KLEEN SYSTEMS, INC.

KYD053340108

KYD053348108

SAFETY-KLEEN SYSTEMS, INC.

KYD053348105

KYD053348108

SAFETY-KLEEN SYSTEMS, INC.

KYD053348106

KYD053348108

SAFETY-KLEEN SYSTEMS, INC.

KYD053348180

KYD053348108

SAFETY-KLEEN SYSTEMS, INC.

KYD053349108

KYD053348108

SAFETY-KLEEN SYSTEMS, INC.

KYD063348106

KYD053348108

SAFETY-KLEEN SYSTEMS, INC.

KYD98073196

KYD985073196

AES ENVIRONMENTAL, LLC

KYD985073195

KYD985073196

AES ENVIRONMENTAL, LLC

KYD985507196

KYD985073196

AES ENVIRONMENTAL, LLC

KYP053348108

KYD053348108

SAFETY-KLEEN SYSTEMS, INC.

LAD000077201

LAD000777201

CHEMICAL WASTE MANAGEMENT

LAD000147277

LA0000147272

CWM TRANSPORTATION

MAD038322250

MAD039322250

CLEAN HARBORS ENVIRONMENTAL SERVICES INC

Ml 0980991588

MID980991566

EQ DETROIT INC

MID000615298

MID980615298

PETRO-CHEM PROCESSING GROUP OF NORTRU LLC

MID000724031

MID000724831

MICHIGAN DISPOSAL INC

MID000724331

MID000724831

MICHIGAN DISPOSAL INC

MID000724631

MID000724831

MICHIGAN DISPOSAL INC

MID000724813

MID000724831

MICHIGAN DISPOSAL INC

MID000724834

MID000724831

MICHIGAN DISPOSAL INC

MID000724835

MID000724831

MICHIGAN DISPOSAL INC

MID053338801

MID005338801

GAGE PRODUCTS CO

MID074259566

MID074259565

DYNECOL INC

MID074259568

MID074259565

DYNECOL INC

MID074269565

MID074259565

DYNECOL INC

MID380991566

MID980991566

EQ DETROIT INC

MID880615298

MID980615298

PETRO-CHEM PROCESSING GROUP OF NORTRU LLC

MID900991566

MID980991566

EQ DETROIT INC

MID930991566

MID980991566

EQ DETROIT INC

MID960991566

MID980991566

EQ DETROIT INC

MID980515208

MID980615298

PETRO-CHEM PROCESSING GROUP OF NORTRU LLC

MID980615238

MID980615298

PETRO-CHEM PROCESSING GROUP OF NORTRU LLC

MID980615275

MID980615298

PETRO-CHEM PROCESSING GROUP OF NORTRU LLC

191


-------
REPORTED_RECEIVER_ID

ASSUMED_RECEIVER_ID

ASSUMED_RECEIVER_NAME

MID980615928

MID980615298

PETRO-CHEM PROCESSING GROUP OF NORTRU LLC

MID980815296

MID980615298

PETRO-CHEM PROCESSING GROUP OF NORTRU LLC

MID980891566

MID980991566

EQ DETROIT INC

MID980981566

MID980991566

EQ DETROIT INC

MID980981586

MID980991566

EQ DETROIT INC

MID980991565

MID980991566

EQ DETROIT INC

MID980991568

MID980991566

EQ DETROIT INC

MID980991586

MID980991566

EQ DETROIT INC

MID980991665

MID980991566

EQ DETROIT INC

MID990991566

MID980991566

EQ DETROIT INC

MID00 0724831

MID000724831

MICHIGAN DISPOSAL INC

MND098109847

MND981098478

SIEMENS INDUSTRY, INC.

MND961098478

MND981098478

SIEMENS INDUSTRY, INC.

MND981006478

MND981098478

SIEMENS INDUSTRY, INC.

MND981008478

MND981098478

SIEMENS INDUSTRY, INC.

MND984098478

MND981098478

SIEMENS INDUSTRY, INC.

MNR981098478

MND981098478

SIEMENS INDUSTRY, INC.

MOD000610765

MOD000610766

SOLVENT RECOVERY LLC

MOD054016286

MOD054018288

GREEN AMERICA RECYCLING LLC

MOD054016288

MOD054018288

GREEN AMERICA RECYCLING, LLC

MOD054018238

MOD054018288

GREEN AMERICA RECYCLING LLC

MOD054018268

MOD054018288

GREEN AMERICA RECYCLING LLC

M0D059299989

MOD059200089

BUICK RESOURCE RECYCLING FACILITY LLC

MSD007655876

MSD077655876

HOLCIM (US) INC/GEOCYCLE LLC

NCD095118210

NCD095119210

METALLIX REFINING INC.

NDJ002200046

NJD002200046

CYCLECHEM INC

NED981072351

NED981723513

CLEAN HARBORS ENVIRONMENTAL SERVICES, INC.

NED981172513

NED981723513

CLEAN HARBORS ENVIRONMENTAL SERVICES, INC.

NED981723351

NED981723513

CLEAN HARBORS ENVIRONMENTAL SERVICES, INC.

NED981723512

NED981723513

CLEAN HARBORS ENVIRONMENTAL SERVICES, INC.

NED981723523

NED981723513

CLEAN HARBORS ENVIRONMENTAL SERVICES, INC.

NJD000245544

NJD002454544

VEOLIA ES TECHNICAL SOLUTIONS LLC

NJD001454544

NJD002454544

VEOLIA ES TECHNICAL SOLUTIONS LLC

NJD002358730

NJD002385730

DUPONT CHAMBERS WORKS

NJD002365730

NJD002385730

DUPONT CHAMBERS WORKS

NJD002454644

NJD002454544

VEOLIA ES TECHNICAL SOLUTIONS LLC

NJD003454544

NJD002454544

VEOLIA ES TECHNICAL SOLUTIONS LLC

NJD022454544

NJD002454544

VEOLIA ES TECHNICAL SOLUTIONS LLC

NJO002454544

NJD002454544

VEOLIA ES TECHNICAL SOLUTIONS LLC

NJR002385730

NJD002385730

DUPONT CHAMBERS WORKS

NVD330010000

NVT330010000

US ECOLOGY NEVADA

NVT300010000

NVT330010000

US ECOLOGY NEVADA

NVT330001000

NVT330010000

US ECOLOGY NEVADA

NVT33001000

NVT330010000

US ECOLOGY NEVADA

NVT330010100

NVT330010000

US ECOLOGY NEVADA

NVT330030000

NVT330010000

US ECOLOGY NEVADA

NVT330110000

NVT330010000

US ECOLOGY NEVADA

NVY330010000

NVT330010000

US ECOLOGY NEVADA

NYD098075641

NYD980756415

STABLEX CANADA INC

NYD980758415

NYD980756415

STABLEX CANADA INC

192


-------
REPORTED_RECEIVER_ID

ASSUMED_RECEIVER_ID

ASSUMED_RECEIVER_NAME

OH0048415665

OHD048415665

ROSS INCINERATION SERVICES INC

OH083377010

OHD083377010

ENVIRONMENTAL ENTERPRISES INC

OHD000724123

OHD000724153

CLEAN HARBORS OF CLEVELAND

OHD001926470

OHD001926740

HUKILL CHEMICAL CORP

OHD00192740

OHD001926740

HUKILL CHEMICAL CORP

OHD00724153

OHD000724153

CLEAN HARBORS OF CLEVELAND

OHD020273810

OHD020273819

VICKERY ENVIRONMENTAL INC

OHD045242706

OHD045243706

ENVIROSAFE SERVICES OF OHIO INC

OHD048415655

OHD048415665

ROSS INCINERATION SERVICES INC

OHD048415664

OHD048415665

ROSS INCINERATION SERVICES INC

OHD048415865

OHD048415665

ROSS INCINERATION SERVICES INC

OHD048441566

OHD048415665

ROSS INCINERATION SERVICES INC

OHD066060608

OHD066060609

CHEMTRON CORP

OHD08337010

OHD083377010

ENVIRONMENTAL ENTERPRISES INC

OHD090587364

OHD980587364

CLEAN HARBORS RECYCLING SERVICES OF OHIO LLC

OHD090897656

OHD980897656

CHEMICAL SOLVENTS INC

OHD091926740

OHD001926740

HUKILL CHEMICAL CORP

OHD092945293

OHD093945293

VEOLIA ES TECHNICAL SOLUTIONS LLC

OHD148415665

OHD048415665

ROSS INCINERATION SERVICES INC

OHD650613641

OHD980613541

HERITAGE-WTI INC

OHD960513541

OHD980613541

HERITAGE-WTI INC

OHD960613541

OHD980613541

HERITAGE-WTI INC

OHD980061354

OHD980613541

HERITAGE-WTI INC

OHD980163641

OHD980613541

HERITAGE-WTI INC

OHD980513541

OHD980613541

HERITAGE-WTI INC

OHD980613451

OHD980613541

HERITAGE-WTI INC

OHD980613641

OHD980613541

HERITAGE-WTI INC

OHD980687384

OHD980587364

CLEAN HARBORS RECYCLING SERVICES OF OHIO LLC

OHD980813541

OHD980613541

HERITAGE-WTI INC

OHD990613541

OHD980613541

HERITAGE-WTI INC

OHF083377010

OHD083377010

ENVIRONMENTAL ENTERPRISES INC

OHO980613541

OHD980613541

HERITAGE-WTI INC

OKD065436376

OKD065438376

CLEAN HARBORS LONE MOUNTAIN LLC

OKD065437376

OKD065438376

CLEAN HARBORS LONE MOUNTAIN LLC

OKD085438376

OKD065438376

CLEAN HARBORS LONE MOUNTAIN LLC

OKD967097151

OKD987097151

TRICAT INC

ORD089452853

ORD089452353

CHEMICAL WASTE MANAGEMENT OF THE NW

PA0987270725

PAD987270725

SIEMENS INDUSTRY INC

PAD002305887

PAD002395887

HORSEHEAD CORP

PAD002359558

PAD002389559

KEYSTONE CEMENT CO

PAD002385887

PAD002395887

HORSEHEAD CORP

PAD002395287

PAD002395887

HORSEHEAD CORP

PAD002395687

PAD002395887

HORSEHEAD CORP

PAD002395867

PAD002395887

HORSEHEAD CORP

PAD002395897

PAD002395887

HORSEHEAD CORP

PAD002395987

PAD002395887

HORSEHEAD CORP

PAD002396837

PAD002395887

HORSEHEAD CORP

PAD002396887

PAD002395887

HORSEHEAD CORP

PAD002593837

PAD002395887

HORSEHEAD CORP

PAD005690592

PAD085690592

REPUBLIC ENVIRONMENTAL SYSTEMS (PA) LLC

193


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REPORTED_RECEIVER_ID

ASSUMED_RECEIVER_ID

ASSUMED_RECEIVER_NAME

PAD007395887

PAD002395887

HORSEHEAD CORP

PAD010054045

PAD010154045

ENVIRITE OF PENNSYLVANIA INC

PAD010540045

PAD010154045

ENVIRITE OF PENNSYLVANIA INC

PAD065690592

PAD085690592

REPUBLIC ENVIRONMENTAL SYSTEMS (PA) LLC

PAD085890592

PAD085690592

REPUBLIC ENVIRONMENTAL SYSTEMS (PA) LLC

PAD091038227

PAD981038227

WORLD RESOURCES CO

PAD87561015

PAD087561015

INMETCO

PAD881038227

PAD981038227

WORLD RESOURCES CO

PAD967270725

PAD987270725

SIEMENS INDUSTRY INC

PAD981038277

PAD981038227

WORLD RESOURCES CO

RID981866104

RID981886104

GANNON AND SCOTT INC.

RID050322130

RID050322130

KELLEY METALS CORP

SC0036275626

SCD036275626

GIANT RESOURCE RECOVERY SUMTER INC

SC981866007

SCD981866007

BASF CORP

SCA036275626

SCD036275626

GIANT RESOURCE RECOVERY SUMTER INC

SCD023627562

SCD036275626

GIANT RESOURCE RECOVERY SUMTER INC

SCD036273626

SCD036275626

GIANT RESOURCE RECOVERY SUMTER INC

SCD036275656

SCD036275626

GIANT RESOURCE RECOVERY SUMTER INC

SCD036575626

SCD036275626

GIANT RESOURCE RECOVERY SUMTER INC

SCD362756626

SCD036275626

GIANT RESOURCE RECOVERY SUMTER INC

SCD036275626

SCD036275626

GIANT RESOURCE RECOVERY SUMTER INC

SDC036275626

SCD036275626

GIANT RESOURCE RECOVERY SUMTER INC

TND000077218

TND000772186

TRADEBE TREATMENT & RECYCLING OF TENNESSEE, LLC

TND000722186

TND000772186

TRADEBE TREATMENT & RECYCLING OF TENNESSEE, LLC

TND000772156

TND000772186

TRADEBE TREATMENT & RECYCLING OF TENNESSEE, LLC

TND000772166

TND000772186

TRADEBE TREATMENT & RECYCLING OF TENNESSEE, LLC

TND000772168

TND000772186

TRADEBE TREATMENT & RECYCLING OF TENNESSEE, LLC

TND00077218

TND000772186

TRADEBE TREATMENT & RECYCLING OF TENNESSEE, LLC

TND007721860

TND000772186

TRADEBE TREATMENT & RECYCLING OF TENNESSEE, LLC

TND646612

TND000646612

HERAEUS PRECIOUS METALS NORTH AMERICA, LLC

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

196


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197


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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.

198


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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.

200


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201


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Appendix F
1993 Guidance

202


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203


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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



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f I ¦wi imm KArt tl w t

NmMWI (1 f«T« M»»* IwwvlM

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