1993 HAZAR OUS WASTE CAPACITY ASSURANCE PLAN FOR GEQRGI PHASE 1

Transcription

1 t h f I 3/J-&,F Pdf d 1993 HAZAR OUS WASTE CAPACITY ASSURANCE PLAN FOR GEQRGI PHASE 1 April 29, 1994

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3 I Introduction Section 104(c)(9) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) requires states to assure adequate capacity for the treatment and disposal of hazardous wastes that are reasonably expected to be generated within the state for 20 years. States must provide this assurance in the form of a Capacity Assurance Plan (CAP). If such an assurance is provided, the state will be eligible for remedial action funding. The objective of the 1993 CAP process is to assure national capacity for the treatment, storage, and/or disposal of hazardous waste. This process is divided into three phases. The first phase provides EPA with the data necessary to produce a national aggregation to determine whether there are any projected national capacity shortfalls. If no national shortfalls are identified, then all states will be eligible for remedial funding. However, if a national shortfall is identified in one or more of the management categories, each state that contributes to the shortfall should address the shortfall by providing EPA with a Phase 2 submission. Phase 2 submissions may contain information about interstate agreements, waste minimization, and/or management capacity that is permitted, but not yet operational. EPA will incorporate the Phase 2 submissions into the national aggregation. If after Phase 2, there are remaining national shortfalls, states that still contribute to the shortfall should provide EPA with a Phase 3 submission. Phase 3 submissions should contain information about interstate agreements, increased waste minimization efforts, and/or plans for future capacity, as well as the public participation activities undertaken while developing the state plan. A significant event occurred in 1992 that affects Georgia's previously submitted Capacity Assurance Plans: the Georgia Hazardous Waste Management Authority determined that a state-sponsored hazardous waste management facility was not economically viable or needed in Georgia at that time. The Authority based this decision on an analysis by its Facility Need and Evaluation Work Group. The analysis used a model based primarily on the 1989 biennial report and hazardous waste capacity information. In 1993, the model was retested using the 1991 biennial report and updated capacity information, and the conclusions were the same as the earlier assessment Phase 1 CAP Submittal The Georgia Environmental Protection Division's (EPD) Phase 1 submittal consists of baseyear (1991) data and projections of commercial RCRA Subtitle C hazardous waste capacity and demand from recurrent hazardous waste generated in-state. These data and projections were developed according to the procedures described in the EPA document Guidance For Capacity Assurance Planning using data collected during the 1991 Biennial Report cycle, the most current data available. Phase 1 of the 1993 CAP consists of six tables, which depict Georgia's existing hazardous waste management systems, projections, and a narrative, which describes the methodology used in creating 1

4 the data tables as well as a description of the waste minimization program in Georgia. The 1993 Phase 1 CAP submittal does not contain estimates of one-time waste data. EPA developed national one-time waste projections for each state and will aggregate these projections with state submitted recurrent waste projections. For the 1993 CAP, states are only required to report Subtitle C hazardous waste. For the baseyear tables (Tables 1 through 4), data is presented for on-site, captive, and commercial facilities, while only commercial facility data will be presented for the projection tables (Tables 5 and 6). Georgia is not reporting the generation or management of waste generated by small quantity generators, non-rcra Subtitle C waste that may use Subtitle C hazardous waste management capacity, waste disposed through discharge to sewers or publicly owned treatment works, waste disposed through direct discharge to surface waters under the National Pollutant Discharge Elimination System, mixed hazardous/radioactive wastes, or projections of one-time waste generation. CAP Management Categories States are to provide capacity-related information for 14 CAP Management Categories in the 1993 CAP. The CAP Management Categories are defined in terms of the 1991 Biennial Report System Type codes that correspond to specific types of waste management systems as reported on the Waste Generation and Management (GM), Waste Received From Off Site (WR), and Waste Treatment, Disposal, or Recycling Process Systems (PS) forms. Method Chosen for Reallocation of Wastes Shipped to Transfer/Storage Facilities Tracking wastes shipped to transfer/storage facilities is problematic. Transfer/storage facilities receive wastes from off-site and accumulate these wastes to be shipped to a treatment, disposal, or recycling facility. Typical problems encountered when tracking wastes shipped to transfer/storage facilities are double counting of wastes, counting wastes shipped to a transfer facility as imported or managed in-state when it was subsequently exported, counting wastes from small quantity generators, and determining the final management of waste shipped to transfer facilities. Appendix H of Using Tabletalk to Prepare CAP Tables provides three options for addressing these problems. The three options describe methods for reallocating shipments to transfer/storage facilities to the appropriate CAP Management Categories. States are instructed to reallocate wastes shipped to transfedstorage facilities to the appropriate CAP Management Categories. If wastes shipped to in-state transfer/storage facilities were subsequently exported, this is reported as an export. EPD chose Option 1, reallocating shipments based on distribution of CAP Management Categories to which transfer facilities shipped waste, as the method to reallocate these wastes. The proportion of wastes by CAP Management Category for each 2

5 transfedstorage facility is calculated by dividing the total waste in tons shipped to each management category that the facility shipped to by the total tons shipped by the transfer facility. The total shipped to each transfer facility by large quantity generators is then multiplied by the calculated proportions determined for that facility to determine the amount of waste to be reallocated to each CAP Management Category. This option was used for reallocating impoits, exports, and wastes generated and managed instate. Wastes that were imported to Georgia transferlstorage facilities, then subsequently exported are not included in the CAP tables. Baseyear Tables As directed by the Guidance Document, EPD prepared four baseyear tables which provide information on the quantity of hazardous waste exported, imported, and generated and managed in state. TABLE Hazardous Waste Generated and Managed On Site CAP Table 1 presents the demand for on-site management of hazardous waste by CAP Management Category. This table summarizes the amount of hazardous waste that is managed on site, meaning the management of hazardous wastes in systems not available for captive or commercial management. The data reported on Table 1 was derived from the GM forms of Georgia large quantity generators. The 467 tons disposed of on-site was reported by The William L. Bonnell Company. This occurred during the closure of its regulated units and was not the result of a continuous operation. Hazardous Wastewaters and Sludges Treatment account for more than 99% of the waste managed on site. 3

6 4 E Table 1: 1991 Hazardous Waste Generated and Managed On Site (tons) Metals Recovery Inorganics Recovery Organics Recovery 3, Energy Recovery - Liquids 42, Energy Recovery - Stabilization/Chemical Fixation Incineration - Liquids and Gases Incineration Sludges/Solids Fuel Blending 3, Hazardous Wastewaters 12,488, and Sludges Treatment Land TreatmentlFarming a Data may not be complete for these technologies because facilities are not required to report in the 1991 Biennial Report waste managed in exempt processes. 4

7 a TABLE Management of Hazardous Waste in Captive Systems CAP Table 2 summarizes the demand placed on Subtitle C captive management systems in 1991 and consists of three columns: (1) hazardous waste generated in state and exported to out of state captive systems; (2) hazardous waste generated in state and managed within the state in captive systems; and (3) hazardous waste imported from other states for management in captive systems. A captive facility manages waste only from off-site generators owned by the same company, and possibly waste generated on site. Additionally, Safety-Kleen facilities are considered to be captive because they only accept waste from a select clientele. All of the Safety-Kleen facilities in Georgia are transferktorage facilities solely. Exports The exports column of Table 2 is derived from data collected on generators' GM forms. The data extracted for this column are the quantity of waste shipped to out of state facilities that generators identified as captive and the system types the generator stated for management of the waste. Waste exported by transferktorage facilities is excluded to avoid double-counting. Added to this column are the reallocated quantities of wastes that were generated in Georgia, shipped to a Georgia transferktorage facility and subsequently exported. Waste Generated and Managed In State The waste generated and managed in state column also comes from the generators' GM forms. Wastes shipped from transfedstorage facilities are disregarded. The 5,366 tons in lnorganics Recovery was generated by Atlantic Steel and managed at Tri Chem. Tri Chem is limited by their permit to accept waste only from Atlantic Steel; therefore, Tri Chem's capacity is not commercially available. The 71 tons in Organics Recovery was generated by Printpack, Villa Rica and managed at Printpack, Atlanta. Imports The imports column of Table 2 describes the management of waste imported and managed in captive systems. All imports to captive transfedstorage facilities are subsequently exported; therefore, these amounts are not included in this table. Captive facilities importing waste for management are Printpack (Organics Recovery) and Delta (Fuel Blending and Hazardous Wastewaters/Sludges Treatment). A problem encountered while preparing the CAP was that many generators misreported the type of facility that took their waste (commercial or captive). As a result, the data reports generated from the 1991 Biennial Report had to be manipulated to reflect reality. No changes were made to the BRS system. To determine the correct status of Georgia facilities, EPD used state knowledge and looked at the Biennial Report forms of the treatment, storage, and disposal facilities (TSDs) that received waste from off-site. 5

8 ~~ StabiIization/Chemical Table 2: 1991 Management of Hazardous Waste in Captive Systems (tons) Metals Recovery lnoraanics Recoverv 5, Organics Recovery Energy Recovery - Liquids Energy Recovery SludgedSolids Fixat ion Incineration - Liquids and Gases Incineration Sludges/Solids Fuel Blending Hazardous Wastewaters and Sludges Treatment It Landfill I I I Deepwei Wnderground injection Land Treat ment/farm i ng 6

9 ! - I TABLE Management of Hazardous Waste in Commercial Systems CAP Table 3 summarizes the demand placed on Subtitle C commercial management systems in 1991 for: (1) recurrent wastes exported to commercial systems; (2) one-time wastes exported tokommercial systems; (3) recurrent wastes generated in Georgia and managed in Georgia in commercial systems; (4) one-time wastes generated in Georgia and managed in Georgia in commercial systems; and (5) wastes imported for management in commercial systems. A commercial facility manages waste from any generator, including off-site generators not under the same company ownership. This definition' includes limited commercial facilities, which manage wastes generated off-site by a limited number of facilities. ~ Exports The exports column of Table 3 reports the quantity of hazardous waste that Georgia exported to commercial systems by CAP Management Category. Several generators reported the system types Energy Recovery - Type Unknown, Incineration - Type Unknown, and Other Disposal. EPD considered the GM page of each generator who reported these system types to determine the correct CAP Management Category by looking at the form codes to determine if the waste form was liquid or solid. These unknowns were reallocated to the correct category based on the form. Additionally, some assumptions had to be made regarding lab packs. Chemicals and acute hazardous waste are assumed to be liquids. Debris and mixed hazardous wastes are assumed to be solids. These assumptions are made to reallocate wastes for the CAP only and for no other purpose. Also included as exports are wastes that were generated in Georgia, shipped to in-state transferktorage facilities, and subsequently exported. Waste Generated and Managed In State This column of Table 3 identifies the quantity of recurrent and one-time wastes that remained in Georgia for management in commercial systems. Waste generated in state and shipped to transfedstorage facilities was reallocated to the appropriate CAP Management Category. If the waste was subsequently exported, that quantity was added to exports. The Origin Code on the generators' GM forms was used to identify whether the waste was recurrent or one-time. Imports The imports column reports the quantity of hazardous waste that was imported to Georgia's commercial systems. The data in this column was derived from the receiving facilities' WR forms. Also included are imports received by transfedstorage facilities that have been reallocated to the appropriate CAP Management Categories for in-state commercial management. The table was created by following the EPA guidance. Some problems were discovered after running the reports needed to gather the data from the Biennial Reporting System (BRS). It was discovered that a significant number of generators inaccurately described the commercial status of the facilities to which they shipped waste 7

10 in addition to incorrectly describing the management system at the receiving facility. EPD looked up each shipment reported by the generator by checking the TSD facility's WR form to determine the correct system type for determining the CAP Management Category. New reports were created showing the correct commercial status and CAP Management Categories for both Table 2 and Table 3. The data were not corrected in the BRS because doing so would require each generator to submit corrected forms for

11 I P. Table 3: 1991 Management of Hazardous Waste in Commercial Systems (tons) Metals Recovery 8, lnorganics Recovery Organics Recovery 3, , , , Energy Recovery - 6, Liquids Energy Recovery - 3, Sludges/Solids Stabilization/Chemical I 3, I I I 0.02 I Fixation Incineration - Liquids and 8, Gases Incineration - 1, Sludges/Solids Fuel Blending 15, , , Hazardous Wastewaters 4, , , and Sludaes Treatment Landfill DeepwelVUnderground Injection Land Treatment/ Farming 10, , a imports cannot be divided into recurrent and one-time wastes due to limitations of information provided on Biennial Report WR forms. 9

12 TABLE 4 - Maximum Operational In-state Commercial Subtitle C Management Capacity (1991) CAP Table 4 was derived from the PS forms of facilities submitting Biennial Reports in This information was verified by EPD associates who have knowledge of the processes at these facilities and by obtaining the correct information from the Part B Permits. In some cases, facilities incorrectly reported the capacity amount. These capacities were corrected for Table 4, but not in the BRS database. The following facilities provided capacity for hazardous waste management in Georgia in 1991: Cateaotv Organics Recovery Stabilization/ Chemical Fixation Fuel Blending Hazardous Wastewaters and Sludges Treatment Facilitv Alternate Energy Resources Arivec Chemicals Chemical Conservation of GA MCF M & J Solvents OHM Tri-State Steel Drum Alternate En e rgy Resources Chemical Conservation of GA OHM Tri-State Steel Drum M & J Solvents Alternate Energy Resources ,000 15,000 2,200 1,340 6,600 31,140 1,792 64,671 66,463 52,800 21,451 5, ,637 20, ,318 32,500 32,500 10

13 Table 4: Maximum Operational In-state Commercial Subtitle C Management Capacity - End of 1991 (tons) Metals Recovery lnorganics Recovery Organics Recovery 31,140 Energy Recovery - Liquids Energy Recovery - Sludaes/Solids StabiIization/Chemical 66,463 Fixation Incineration - Liquids and Gases Incineration - Sludges/Solids Fuel Blending 270,318 Hazardous Wastewaters and 32,500 Sludaes Treatment * Transferhtorage is not considered to be capacity. 11

14 Projections States are required to estimate the demand for commercial Subtitle C hazardous waste management capacity for recurrent hazardous waste expected to be generated within their borders in 1993, 1999, and In addition, states are required to estimate the maximum commercial Subtitle C hazardous waste management capacity expected to be available within their borders in 1993, 1999, and For the 1993 CAP, states are not required to adjust their projections for the impacts of economic change. Table 5 - Demand for Commercial Hazardous Waste Management Capacity from Recurrent Waste Expected to be Generated in State' Baseline Demand Baseline demand includes RCRA Subtitle C hazardous waste generated in Georgia in 1991 plus treatment residuals generated from the management of hazardous waste in In estimating the baseline demand, the recurrent waste generated and managed in state in the baseyear (Table 3) is added to the recurrent waste exported in the baseyear (Table 3). This information is then adjusted for residuals (using the method described in section 3.2 of the guidance). This information is presented in the 'Baseline' column of Table 5. Reallocation of Exports to Transfedstorage Facilities Wastes generated in Georgia that were shipped out of state in the baseyear to transfedstorage facilities must be reallocated to CAP Management Categories for projection years. Georgia exported 1,592 tons to transfedstorage facilities in The steps taken to reallocate this amount are as follows: (1) determine the total quantity shipped to each transfer facility by large quantity generators; (2) determine the proportion of CAP Management Categories to which each transfedstorage facility shipped waste; and (3) calculate the quantities to be reallocated to each appropriate CAP Management Category. Georgia accessed other states' data on the EPA mainframe computer to determine the proportions for making these calculations. Regulatory Changes The CAP projections incorporate recent regulatory changes whose impacts are not reflected in the baseyear data. The only federal regulations that states should incorporate into future demand are the changes in the land disposal restrictions (LDRs). The 1991 Biennial Report data already accounts for treatment of hazardous wastes subject to LDRs that became effective prior to The 1991 data do not reflect the future management of First, Second, and Third Third wastes whose national capacity variances expired between January 1991 and May 1992 and petroleum refining wastes that were listed as hazardous effective in May 1991 and were restricted from land disposal as a result of the 12

15 , Phase 1 LDRs published on August 18,1992. The first step in adjusting for regulatory change is to separate waste quantities affected by recent LDR requirements from other projection data to avoid double counting. This approach assumes that only the waste streams that were disposed in 1991, rather than treated, will need to be redistributed to treatment categories for projections. The second step is to determine the quantity of these wastes generated in The third step is to identify the CAP Management Categories in which these wastes will be managed in future years and their demand on commercial capacity. The appropriate CAP Management Categories are decided for each waste by determining the best demonstrated available treatment standard as specified by EPA. Due to-the LDRs, 3,715 tons of landfilled waste (from the baseyear) needed to be reallocated to other categories: 397 tons were reallocated to Metals Recovery, 827 tons to Stabilization/Chemical Fixation, and 2,491 tons to Hazardous Wastewaters and Sludges Treatment. To adjust for the impact on landfill capacity, the quantity allocated to Stabilization is multiplied by 1.5 to estimate the generation of hazardous waste residuals from this treatment. To get a total demand for 1993, the reallocated waste quantities are added to the baseline. The reallocated quantities are subtracted from demand on landfill (except for the residuals from stabilization, which is added to landfill demand). The baseline demand, the reallocated quantities from exports to transferktorage facilities, and the reallocated quantities from the LDRs are added together to determine the projected demand for

16 Table 5: Demand for Commercial Hazardous Waste Management Capacity from Recurrent Waste Expected to be Generated In State (tons) Metals Recovery I norganics Recovery Organics Recovery Energy Recovery - Liquids Energy Recovery - Sludges/Solids 8,591 9,360 9,360 9, ai 4 ai 4 ai 4 6,624 6,650 6,650 6,650 6,378 6,392 6,392 6,392 3,419 3,755 3,755 3,755 I Stabilization/Chemical Fixation Incineration - Liquids and Gases Incineration - Sludges/Solids Fuel Blending Hazardous Wastewaters and Sludges Treatment Landfi II DeepwelI/Underground Injection 3,536 4,571 4,571 4,571 8,108 8,323 8,323 8,323 1,791 2,350 2,350 2,350 17,714 17,749 17,749 17,749 5,372 7,923 7,923 7,923 16,437 14,073 14,073 14,073 1,794 1,794 1,794 1,794 I 14

17 1 4 r,, Table 6 - Expected Maximum In-state Commercial Subtitle C Management Capacity Baseline capacity is the existing operational capacity located within Georgia's borders. The 1991 capacity figures from CAP Table 4 are reflected as baseline capacity in Table 6. Capacity lost since Arivec Chemicals closed during the fourth quarter of Arivec contributed 15,000 tons to Georgia's capacity in Organics Recovery. EPD subtracted 25% of Arivec's capacity from the baseline figure to compute the 1993 projection and Arivec's capacity is not reflected in projected capacity for Capacity gained after As of 1991, there were seven permitted commercial hazardous waste facilities in Georgia. The projected capacities presented on Table 6 for 1999 and are included based on the following assumptions: e If a permitted facility has requested a permit modification to increase its capacity, it ts assumed that it will be approved if all regulatory requirements, including financial assurance, have been satisfied and there has been little public interest in the facility previously. Note that this is only an assumption for the sole purpose of predicting future capacity. e If a facility has submitted a hazardous waste facility permit application and does not yet have a permit, it is included only for projection purposes. There is no basis at this time for knowing whether the permit would be granted or even if the application contains all regulatory requirements. Should the national capacity assurance planning process proceed to Phase 3, additional validation of this projection will be attempted. e If a facility is permitted for capacity that was not commercially available in 1991, that permitted capacity is included in the projection years. 15

18 Summary of Table 6 by facility: Category Organics Recovery Alternate Energy Resources Arivec Chemicals Chemical Conservation of GA MCF M 81 J Solvents 6,000 15,000 2,200 1,340 6,600 6,000 11,250 6,695 1,338 4,150 6, ,695 1,338 4,150 6, ,695 1,338 4,150 Energy Recovery - Liquids Medusa Cement ,200 80,200 StabilizatiodChemicai Fixation CWM (OHM) Tri-State Steel Drum 1,792 64,671 2,465 64,671 12, ,708 12, ,708 Fuel Blending Alternate Energy Resources Chemical Conservation of GA CWM (OHM) Tri-State Steel Drum M 81 J Solvents ENSCO 52,800 21,451 5, ,637 20, ,800 27,265 10, ,637 8, ,800 27,265 20,000 93,075 8,300 3,600 52,800 27,265 20,000 93,075 8,300 3,600 Hazardous Wastewater and Sludges Treatment Alternate Energy Resources Tri-State Steel Drum CWM (OHM) 32, , ,500 73, ,500 32,500 73, ,500 16

19 4 Table 6: Expected Maximum In-state Commercial Subtitle C Management Capacity (tons) Metals Recovery lnorganics Recovery Organics Recovery 31,140 29,433 18,183 18,183 Energy Recovery - Liquids 80,200 80,200 Energy Recovery - Sludges/Solids Stabilizatiordchemical 66,463 67, , ,908 Fixation Incineration - Liquids and Gases Incineration - Sludges/Solids Fuel Blending 270, , , ,404 Hazardous Wastewaters and 32,500 32, , ,684 Sludges Treatment 11 Landfill I I I I Deepwell/Underground InjectiQn I I I 17

20 Hazardous Waste Minimization and Reduction The Georgia Hazardous Waste Management Act was amended in 1990 to require large quantity generators of hazardous waste to develop and to submit hazardous waste reduction plans by March 1, 1992, and biennially thereafter. During the fail of 1991, EPD developed an instruction manual and forms to serve as a guide to the completion of this requirement. Thus, for the first time in 1991, facilities were required to complete and submit Hazardous Waste Reduction Plans providing detailed outlines of on-site and corporation-wide waste reduction efforts. An update to the original plan has been submitted with the 1993 Biennial Report. Georgia saw a decrease of 19.7% in off-site shipments of hazardous waste from 1989 to According to biennial reports, hazardous waste shipped off-site was 114, tons in 1989 and 92, tons in This decline is attributable to several factors, including hazardous waste reduction efforts by Georgia generators. Other factors include variations in manufacturing output to economic conditions and one-time cleanups whose volumes may significantly change commercial demand from year to year. Further, in 1993, the Georgia Legislature passed Senate Bill 200 creating the Pollution Prevention Assistance Division (PAD) within the Georgia Department of Natural Resources. The mission of P2AD is to facilitate the development of a nonregulatory, multimedia pollution prevention program within the state that encourages reduction of toxic and hazardous chemicals at the source. The P2AD program is an expansion of the hazardous waste source reduction program of the Georgia Hazardous Waste Management Authority. P2AD's pollution prevention program seeks voluntary participation from industry. The current programs offered consist of both technical and financial assistance to industry and other organizations. The technical programs include an information clearinghouse, telephone technical assistance, on-site pollution prevention assessments, and various types of workshops to assist industry to reduce waste through source reduction measures. P2AD also provides matching grants to industry and non-profit organizations to demonstrate feasibility of various pollution prevention options, prepare education programs, or develop employee training courses on pollution prevention concepts. P2AD continues to develop various industry-specific technical outreach programs (e.9. fact sheets, workshops, etc.) which focus on large quantity hazardous waste generators and treatment, storage, and disposal facilities. These ongoing efforts not only reduce toxic chemical releases to the environment; they reduce, minimize, or eliminate the amounts of hazardous waste being treated on-site or shipped off-site for management. 18