Document NGG2a2y4KODw31Y1ZzyZYbnzg

cm CHEMICAL MANUFACTURERS ASSOCIATION j-C. ^ \ . -'Z'"? I To: RCRA Task Group RCRA Work Groups November 19, 1990 Enclosed for your information is a copy of the 1988 CMA Hazardous Waste Survey. No action is requested. Dorothy Allen Kellogg 2501 M Street, NW, Washington, DC 20037 202-887-1100 Telex 89617 (CMA WSH) VVV 000004749 CMA Hazardous Waste Survey Pr+pmwdfor Chemical Manufacturers Association 2501 M Street NW Washington, DC 20037 Prmpandby Tlschter/Kocumk 116 East Main Round Rock. Texas 78664 90149 August 1990 00000*750 Table of Contents Page Executive Summary..................................................................................... E-1 Introduction................................................................................................. 1 Survey Response................................... Number of Participants................................................................................. Primary SICs................................................................................................... 2 2 4 Generation and Management.................................................................. Overview...................................................................................................... Data Distributions........................................................................................ Domestic Sewage Exclusion ...................................................................... 6 8 11 14 Hazardous Wastewater........................... Overview...................................................................................................... Treatment...................................................................................................... Disposal--Underground Injection..................................................... 15 16 18 20 Hazardous Solid Waste (Non-Wastewater)........................................... Overview...................................................................................................... Material Reclaimed/Reused/Recovered........................................................ Burning for Energy Recovery...................................................................... Treatment...................................................................................................... Disposal ...................................................................................................... 21 22 24 25 26 28 Trend Analyses............................................................................................. 1987-1988 Comparison............................................................................. 1985-1988 Trends................................... Hazardous Wastewater (1985-1988)............................................................ Hazardous Solid Waste (1985-1988)............................................................ 1981-1988 Trends.................................................................................... Hazardous Wastewater (1981-1988) . . . Hazardous Solid Waste (1981-1988)............................................................ 31 32 34 38 40 42 46 48 Appendices A--Hazardous Waste Generation by SIC (1988) B--Zero or Less Than 0.5-ton Generators by SIC (1988) C--Blank Copy of 1988 CMA Waste Survey VVV 000004751 CMA Hazardous Watte Survey page T-1 . > &. Table of Contents List of Figures Number Page 1 Survey Participation........................................................................... 2 Hazardous Waste Generation (1988).................................................. 3 Hazardous Solid Waste Generation (1988) Ail Survey Plants.............................................................................. 4 Hazardous Solid Waste Generation (1988) Only Plants with Greater Than 0.5 Tons..................... ........................ 5 Hazardous Wastewater Generation (1988) All Survey Plants.............................................................................. 6 Hazardous Wastewater Generation (1988) Only Plants with Greater Than 0.5 Tons.............................................. 7 Domestic Sewage Exclusion Wastewaters (1988)............................. 8 Hazardous Wastewater Management (1988).................................... 9 Hazardous Wastewater Treatment (1988)........................................... 10 Hazardous Solid Waste Management (1988)...................... 11 Hazardous Solid Waste Treatment (1988).......................................... 12 Hazardous Solid Waste Disposal (1988)........................................... 13 1985-1988 Hazardous Wastewater Management Trends.................. 14 1985-1988 Hazardous Solid Waste Management Trends .............. 15 1981-1988 Hazardous Wastewater Management Trends.................. 16 1981-1988 Hazardous Solid Waste Management Trends .............. 2 8 12 12 13 13 14 16 18 22 26 28 39 41 47 49 CMA Hezardouw Weete Survey '88 page T-2 MV 000004752 -1 ft. Table of Contents List of Tables Number Page 1 Survey Participation (1981-1988)..................................................... 2 Primary 2800 SICs of Survey Respondents in 1988 ......................... 3 Generation and Management (1988) Overview ................................ 4 Hazardous Wastewater (1988) Overview.......................................... 5 Hazardous Wastewater (1988) Treatment.......................................... 6 Hazardous Wastewater (1988) Disposal--Underground Injection..................................................... 7 Hazardous Solid Waste (Mon-wastewater) (1988) Overview.............. 8 Hazardous Solid Waste (Non-wastewater) (1988) Material/Reclaimed/Reused/Recovered .......................................... 9 Hazardous Solid Waste (Nonwastewater) (1988) Burning for Energy Recovery............................................................ 10 Hazardous Solid Waste (Nonwastewater) (1988) Treatment.............. 11 Hazardous Solid Waste (Non-wastewater) (1988) Disposal................... 12 Comparison of Hazardous Waste Generation and Management Practices for 471 CMA Member Plants Reporting in 1987-1988 ..................... 13 Comparison of Hazardous Waste Generation and Management Practices for339 CMA Member Plants Reporting in 1985-1988 (including recycle)............................................................................. 14 Comparison of Hazardous Waste Generation and Management Practices for 339 CMA Member Plants Reporting in 1985-1988 (excluding recycle)............................................................................. 15 Comparison of Hazardous Waste Generation and Management Practices for 190 CMA Member Plants Reporting in 1981-1988 (including recycle).............................................................................. 16 Comparison of Hazardous Waste Generation and Management Practices for 190 CMA Member Plants Reporting in 1981-1988 (excluding recycle)............................................................................. 3 5 9 17 19 20 23 24 25 27 29 33 35 37 43 45 WV OOOOO4753 CMA Hszardoim-Waate Survey pageT-3 Table of Contents this page is intentionally blank CMA Hazardous West* Survey 88 page T-4 VVV 00000^7*>4 Executive Summary Since 1981. the Chemical Manufacturers Association (CMA) has conducted an annual hazardous waste survey of its member companies to characterize die waste generation and management practices of the chemical industry. Only plants with primary Standard Industrial Classification (SIC) 2800 are asked to participate in the survey; This report is a summary of the results of the 1988 survey and includes a comparison with previous years' surveys. Number of Participants Five hundred and eighty-two (S82) plants responded. Only 66 of these plants were first-time respondents. Seventy-seven (77) companies responded, representing about 40 percent of CMA's member companies. This year, thirty-five (35) of these 77 companies were in the top 50 chemical companies in sales for 1988 {Chemical and Engineering News, June 19, 1989). Survey Participation | CMA Waste Survey *88 Ms 58 differs somp j of companies in sales for 1988* Generation and Management Overview `Source: Chemical and Engineering News, June 19.19S9 This survey divided hazardous waste into two categories, solid waste and wastewater. This was done because the volume of wastes that are mostly water, are much larger the other type of wastes that are more typically thought of as solid and mask any trends in these latter wastes. The survey divides wastes into two categorise-- solid waste end wastewater The survey defined wastewaters as NPDES treated wastes, those discharged to a Publicly-Owned Treatment Works (POTW), wastewaters that are disposed by underground injection, and any other aqueous waste. This definition was solely for the purpose of categorizing responses to the survey -- it does not represent a regulatory distinction. VVV 000004755 CMA HaantoueWaateSurvmy page E-1 Executive Summery Solid waste, defined here as afl other haaiai--res not fitting the survey definition of wastewater, is not intmrkd K> be coostaneaBA's RCRA definition of solid waste. Hazardous solid waste by the survey definfchmrefenred to in the report tables as solid (non wastewater) waste. Hazadoos y*1^ wasre^hfdBdous wastewater (both as defined here) equals the sum total of waste ArimmA u hazartioreraSACRA and those added in state regulations (state only). The figure below shows that g"*****TM hytboBcy plants was 97.0 percent hazardous wastewater (213.2 million tons) and 3i) pmrffeBrdous solid waste (6.7 million tons). Of the 582 plants reporting, there were 86fftrea(15 percent) that either did not generate any hazardous waste or generatedless thaiQLScat. Hazardous Wastewater 213.2 million tons of hazardous tuutwarere generated. 99.2 percent of the hazardous wastewater was RCRA-defined hazardous were. The remaining 0.8 percent was state-defined hazardn.^ waste. 30.0 percent of the hazardous wastewater was hazardous by characteristic. The remaining 70.0 percent was hazardous by fitting. 88 CMA Hazardous Wast* Survey page E-2 VVV 00000475t> Executive Summary The figure below shows the percentages ofhazardous wastewater that were treated and disposed. 90.4 percent of the hazardous wastewater generated by the survey plants was treated (192.6 million of 213.2 million tons). Hazardous Wastewater Management (1988) 9.6% Disposed 20.5 million tons -underground Injected 90.4% Treated 192.6 million tons -NPDES -POTW -other treatment The figure below shows the percentages of the different treatment practices for hazardous wastewater from this survey. Hazardous Wastewater Treatment (1988)* * 0.7% Other treatment 1.3 million tons -chemical, physical, biological, Inclnsratlon, snd combination of these methods 7,4% POTWa 14.2 million tons (86 peccant of thus wastewater was treated prior to discharge to the POTW.) 91.9% NPDES 177.2 million tons *VV 000004757 CMA Hazardous Waste Survoy pageE-3 Executive Summery Hazardous Solid Waste (Non-Wastewater) 6.7 million tons of hazardous solid waste woe generated. 98.8 percent of die hazardous solid waste was RCRA-defmed hazardous waste. The remaining 1.2 percent was state-defined hazardous waste. The figure below shows the percentages ofhazardous solid waste that were recycled, treated, and disposed. Recycling included material reclamation/reuse/recovery and burning for energy recovery. Hazardous Solid Waata Management (1988) 12.5% Treatment 0.84 million tone -incineration -ether treatment 11.5% Disposal 0.77 million tone -landfill -aurfaea Impoundment -weste.pile -undeegmund ln|ectlon (her dtoaoeal 75.7% Recycling 6.0 million tone -materiel reeiemaUo reuse/recovery -burning lor energy recovery 0.2% Ramalnad In Storage 0.02 million tons The figure below shows the percentages of the different treatment practices for hazardous solid waste from this survey. IjMjrdouj^oll^Jtejt^rreBtrnen^lsaa^^^l 19J% Other treatment 0.183 million tone -chemical, physical, biological, thermal, solidification, and combination of these methods 80.7% Incineration 0.681 million tone CMAHaxardousWaete Survey '88 page E-4 VVV 000004758 Executive Summary The figure below shows the percentages of the different disposal practices for hazardous solid waste from this survey. Hazardous Solid Waste Disposal (198$) 58.7% Landfill 0.452 million tons 24.1% Surface impoundment 0.185 million tone 5.5% Inieetion 0.043 million tone 5.3% Waste pile 0.041 million tona 6.4% Other disposal 0.050 million tons Domestic Sewage Exclusion (DSE) Twenty (20) plants reported discharging 11.3 million tons of wastewater to a POTW under the DSE. Survey respondents were asked to report those wastes that they did not include in their hazardous waste quantities because of the DSE. These DSE wastewaters were not reported in this survey as hazardous wastes and are not included in any of the hazardous waste quantities. Trend Analyses Trend analyses in this report are based on two periods, 1981-1988 and 1985-1988. The latter period was chosen because 1985 marked the year many recycled wastes became pan of the survey database. Plants were used in trend analyses only if they had responded every year during a trend period. There were 190 plants for the 1981-1988 trend analysis and 339 plants for the 1985 trend analysis. To emphasize the impact of recycled wastes during the 1985-1988 period, both the 1981-1988 and 1985-1988 trend groups were analyzed first with recycled wastes included and then without recycled wastes. VVV 0OOOO4759 CMA HmzmMous Waste Survey page E-5 Executive Summary The trend analyses often show sharp changes in hazardous waste generation and management because of the actions of a few plants with large wastes. These changes are highlighted because otherwise they tend to mask more subtle trends. To highlight the most recent changes, a comparison of the current survey year with the previous survey year (1987-1988) is included in this report. This comparison is based on 471 plants that responded to the survey in 1987 and 1988. In the following sections, the comparison of plants that responded to both the 1987 and 1988 surveys is presented first Next the comparison of 1985-1988 trend plants is presented, and finally the 1981-1988 trend plants. 1987-1968 Comparison Total hazardous waste generation increased from 1987 to 1988 by 9.7 percent (19.0 million tons). In general, changes that occurred between 1987 and 1988 in a particular category happened because of the actions of a few plants with-very large wastes relative to the others m that tame category. The reasons for these changes are given below. Recycling appeared to decrease by 10.6 percent because a variance from the soKAwaste definition was granted for one waste. Waste quantities treated in NPDES facilities increased.12J. percent The largest pan of this increase was from a plant that aggregated hazardous andjxmiazarious wastewater for common treatment Wastewater treatment by means other than in NPDES facilities or by discharge to a POTW decreased by 58.0 percent Most of this decrease came from two plants. Underground injection increased 8.0 percent. Most of this increase was from reclassification of one waste. Landfill disposal increased by 50.8 percent This increase is from cleanup wastes, primarily from impoundment closures and cleanouts. 1985-1988 Wastewater Trends The trends in wastewater quantities for the 1985-1988 trend yean are shown in the figure on the facing page. The lower half of the figure, which presents wastewater quantities managed by different practices as a percentage of the total wastewater treated and disposed, is useful in showing any trends in wastewater management practices over the trend years. Usage of NPDES facilities, POTWs, and other wastewater treatment methods has changed little from 1985 to 1988. Quantities treated in NTOES facilities were 85.4 percent in 1985 and 86.8 percent in 1988. Quantities discharged to POTWs were 6.7 percent in 1985 and 5.9 percent in 1988. Quantities treated by means other than in NPDES facilities or discharged to POTWs were 0.6 percent in 1985 and 0.2 percent in 1988. Usage of underground injection has changed little from 1985 to 1988. Quantities injected undeiground were 7.3 percent in 1985 and 7.0 percent in 1988. ___ CMA Hazardous Waste Sumy 88 -------------------------------------------------------------- page E-6 VVV 000004760 .. i m Executive Summary ]1985-1988 Hazardous Wastewater Manag ement Trends Oils from 339plant* reporting alt 4 yaan Pareant of Hazardous Yaar 1988 Yaar 1988 VW 000004761 CAM Hazardous Wamto Survey page E-7 t Executive Summary 1985-1988 Hazardous Solid Waste Management Trends Data from 339 plants reporting all 4 years. Excludes recycled wastes in 1985-1988 and 200,000 tons cleanup wastes in 1987. Millions of Tons psr Ysar 1985 Psrcent of Hazardous Solid Waste Treated and 1988 ... CM* Hazardous WasteSurvey 88 --------------------------------------------- page E-8 VVV 00000^762 * ik Executive Summary 1985--1980 Solid Waste Trends The trends in solid waste quantities for the 1985-1988 trend years are shown in the figure on the facing page. The lower half of the figure, which presents solid waste quantities managed by different practices as a percentage of the total solid waste treated and disposed, is useful in showing any trends in solid waste management practices over the trend years. The percentages exclude waste quantities that obscure trends. The excluded quantities are the impoundment cleanup waste in 1987 and recycled wastes in 1985-1988. Incineration has increased from 26.6 percent in 1985 to 43.3 percent in 1988 primarily because there were increases from a few large wastes. Without these wastes, the percentage incinerated for 1985 through 1988, respectively was: 18.2, 34.1,24.2, and 24.0 percent. Solid waste treatment decreased from 22.4 percent in 1985 to 9.4 percent in 1988. Most of the decrease that occurred in 1986 was when a plant changed treatment chemicals to render a waste nonhazardous. Landfill disposal was essentially the same from 1985 (2Z2 percent) through 1987 (22.9 percent). In 1988, cleanup wastes increased landfilled wastes to 29.5 percent Disposal by means other than underground injection and landfill decreased from 28.8 percent in 1985 to 17.8 percent in 1988. CMA Hazardous Waste Survey ,qq VVV 000004763 page E-9 Executive Summary '! ft. 1981-1983 Hazardous Wastewater Management Trends Data from 190 plants reporting ail B years Million* Tons par Percent ol Hazardous Wastawater Trsatsd and Disposed CM4 Hmzardoua Waste Survey page E-10 VVV 000004764 Executive Summary 1981-1988 Wastewater Trends The trends in wastewater quantities for the 1981-1988 trend years are shown in the figure on the facing page. The lower half of the figure, which presents wastewater quantities managed by different practices as a percentage of the total wastewater treated and disposed, is useful in showing any trends in wastewater management practices over the trend years. Quantities treated in NPDES facilities were 81.6 percent in 1981 and 90.1 percent in 1988. Quantities discharged to POTWs were 9.9 percent in 1981 and 3.6 percent in 1988. The quantity discharged to POTWs decreased in 1985, primarily because one plant had a wastewater reclassified as nonhazardous in that year. This decrease in discharge to POTWs caused the percentage of waste (but not the quantity) treated in NPDES facilities to increase in 1985. Since these changes in 1985, the percentage usage of NPDES facilities has increased slightly and discharge to POTWs has decreased correspondingly. Quantities treated by means other than in NPDES facilities or discharged to POTWs were 3.3 percent in 1981. Since 1983, usage of treatment methods other than NPDES and POTWs has remained relatively the same. CMA Hazardous Waste Survey VVV 000004765 P8E-11 -: & Executive Summary 1981-1988 Hazardous Solid Waste Management Trends Data from 190 plants raporting ail 8 years. Excludes recycled wastes in 1985-1988 and 200,000 tons cleanup wastes in Percent of Hazardous Solid Waste Treated and Disposed * ... CMA Hazardous Waste Survey 88 ------------- ------------------------------ page E-12 VVV 000004766 Executive Summary 1981-1968 Solid Waste Trends The trends in solid waste quantities for the 1981-1988 trend years are shown in the figure on the facing page. The lower half of the figure, which presents solid waste quantities managed by different practices as a percentage of the total solid waste treated and disposed, is useful in showing any trends in solid waste management practices over the trend years. The percentages exclude waste quantities that obscure trends. The excluded quantities are the impoundment cleanup waste in 1987 and recycled wastes in 1985-1988. Incineration was essentially the same level for 1981 and 1982. Since 1982, there has been a steady increase in incineration. Most of the increases in 1986-1988 have been from a few plants with large wastes. Other solid waste treatment decreased from 14.0 percent in 1981 to 5.8 percent in 1988. Landfill disposal has fluctuated between 13.0-29.7 percent from 1981 to 1988. The recent increase in 1988 was the result of cleanup wastes. Disposal by means other than underground injection and landfill decreased from 58.4 percent in 1981 to 19.7 percent in 1988 with the largest decrease occurring between 1982 and 1983. Although the group of trend plants is different for the periods 1981-1988 and 1985-1988, both groups show the same trends in hazardous solid waste daring 1985 through 1988. CAM Hazardous Waste Survey VVV 000004767 pageE-13 Executive Summary Relationship of Waste Generation to Manufacturing Production Since the 1986 survey, CMA has collected manufacturing production data from the survey respondents in an effort to normalize hazardous waste trends and to judge progress in waste minimization. As yet, the use of production data has not proved satisfactory for several reasons. The primary reasons appear to be the inherent variability between waste generation and manufacturing production and the relatively small number of plants on which to base trends. On this latter point, the number of plants is small because the evaluation must be on a common basis -- on those plants that have provided data on generation and production for all years of the survey. CMA intends to continue to collect data, however, including production, to broaden the database so that it can be used to give perspective to hazardous waste generation -- particularly in waste minimization and overall trends for the chemical industry. 0 CMA Hazardous Waste Survey *88------------------------------------------------------ page E-14 VVV 000004768 Introduction Since 1981, the Chemical Manufacturers Association (CMA) has conducted an annual hazardous waste survey of its member companies to characterize the waste generation and management practices of the chemical industry with primary Standard Industrial Classification (SIC) 2800. Trends in waste generation and management practices are very important, as they reflect the industry's response to environment concerns related to hazardous waste management CMA has conducted this survey since 1981. The CMA hazardous waste survey has always included a core set of questions in three areas: generation, treatment and disposal. Since 1985, with the revised solid waste definition at 40 CFR (Code of Federal Regulations) 261.2, recycle has been included in the core. Besides these areafc~ CMA has continually used the survey as a means of collecting data for proposed or anticipated^ hazardous waste regulation. The 1988 survey covered these areas: hazardous waste generation and management; the Organic Toxicity Characteristic (OTC); corrective action; and nonhazardons waste generation and management and surface impoundment inventory. A copy of the 1988 survey form is in Appendix C. Much of the data presentation is in tables and figures, consistent with the earlier CMA survey reports which generally follows the format of the survey form. First, a general description of the companies and their plants that participated in the survey is given. Then follows generation and management practices and finally, trend analyses based on the CMA surveys since 1981. Because many reported values are estimated waste quantities, the values in this report should be interpreted as having only three significantfigures. Most of the waste quantities in this report were not rounded to three significant digits to avoid round-off errors in the sums presented in the tables. In the trend analyses shown in this report waste generation and waste management do not balance in the 1981-1984 period. This occurred as a result of waste in storage at the beginning or end of a survey year and math errors. Since 1984, survey responses have been checked for imbalances and followup calls are made to the survey respondents. CMA Hazardous Waste Survey VVV 000004769 pagei Survey Response ____________________________________ Number of Participants Participation in the 1988 survey is summarized in Figure 1 and Table 1. Table 1 abo gives a summary of survey participation since 1981. Plants Five hundred and eighty-two (582) plants responded to the 1988 survey. Only 66 of these plants were first-tune respondents, not having participated in the survey before. Companies * Seventy.-ven (77) companies responded to the 1988 survey, representing about 40 percent of CMA's member companies. Participation in the survey by major chemical companies bn always been high and as suck, provides a realistic view of hazardous waste generation aad management practices in ftu industry. This year, for rrimgh, thirty-five (35) of these 77 companies were in the top 50 chemical companies in sales fcr 1988 (Chemical and Engineering News, June 19,1989). One hundred and fifty (150) companies have participated m CMA's survey since the sorwy started in 1981. Survey Participation CMA Waste Survey JdS 582 pianta-from 77 different companies participated 35 of these 77 companies were In the top 50 chemical companies in sales ter 1988* * Source: Chemical and Engineering News, June 19,1989 Figure 1 Trend Plants - Trend analyses in this report tbeind on two periods, 1981-1988 and 1985-1988. Plants were used in a trend anatyrisredpiftiiey had responded evmyyear during a trend period. There were 190 plants forthe UR-1988 trend analysis and 339 plants for the 1985-1988 trend analysis. As shownmTaUe l eadaPlatmresponding every year since 1981, the number of plants avadabie for luad mnlysashas decreased with time. Each year some plants drop from the trend group became Rydose, stop production, are no longer a CMA member, or simply choose not Bpmtipn. Hfcete Survey 2 VVV 000004770 00d UZ^OOOQO AAA AAAilTS nopMZIH VftO SM*N 6uu99iJtCu3 PUB /eofuioqo :9&nos 1 1961 utpoyets XSA//TS 9Q199UIS AOAJOS S; tfWD Uf p0JBdt0U2d BABtf SWU8dUJ00 (OSl) Am pBJpUPq 9U0 .. peqsuqnd sbm yodaj A&ajps b jaipe poOueqo dtqsjBUMO Ausduioo jo sesuodsej Abajhs jteqi ui sde6 p&im OAsq siuBfd euios Bsnzoaq suodej Aoajhs snofABjd way j&ufp Aetu sjeqmrtu osotu _ _ _ _6 Z8C Z90 -- 061. ZIZ *"v : V>: t&r* S861 89UIS J6BX Ai9A0 Ouipuodsoisujeid `S'^wAT86i SOUjSMBA./U0A0"'" Buipuodsaj suJBid 3 (D en SC SC LZ w ee !6ujpuodsej seies u; seiuedwoo os doj. LL 99 09 08 SB 56 YL SI #,6u;puodsej se;ueduioo 99 IS zz os m 00C 0 SCS l/.WW/.V.W^W'AV^AV.WA' 28S SSS 6SS 089 .......... ZZL LZZ 8ZS SCS IHIililll 88 Z8 98 SB 09 8 28 1.8 '"61 JB0A ifc;fr&&!! auiji isju oguo} fiujpuodsai siueud 6u!puod$di siueid --jo jaquinN siuvdptutd o JtquinN MuodMy Aiiuns U Wl) 0961-1861> ,uonsdptvd AMins Survey Response Primary SICs Only plants in SIC major group 28, Chemicals and Allied Products, are in the 1988 survey. Each plant reported its primary SIC within this group. Frequency of Occurrence The number and percentage of survey plants by primary SIC are listed in Table 2. As shown below, three SICs accounted for over 50 percent of the plants: Moat Frequently Reported Primary SICs (as Percentage of Survey Plants) 2869 2821 2819 Miscellaneous Industrial Organic Chemicals Plastics Materials, Synthetic Resins Miscellaneous Industrial Inorganic Chemicals 23% 18% 15% Waste Generation The nun frequently reported SIC did not always relate to the highest sum of hazardous waste reported (see table of hazardous waste generation by SIC in Appendix A). The three highest quantities of solid waste and wastewater generated by primary SIC are shown below: Highest Hazardous Solid Wssts Generation by Primary SIC (as Percentage of Total Hazardous Solid Waste) 2823 2869 2821 CeMuiosic man-made fibers Miscellaneous industrial organic chemicals Plastics matariais and synthetic resins 62% 20% 5% Highest Hazardous Wastewater Generation by Primary SIC (as Percentage of Total Hazardous Wastewater) 2869 2800 2812 Miscellaneous industrial Organic Chemicals Chemicals and allied products Alkalies and chlorine industrial gaaes 63% 11% 9% ____ CM4 Hazardous Waste Survey '88 ------------------------------------------------------------------- page 4 vvv 000004772 Primary 2800 SICs of Survey Respondents In 1988 (Table 2) SurviyRnpenM Primary SICs 1 1 Primary sic ..-...-.v.-.-:" v." Product Type Plants Number Percentage 2869 2821 2819 2812 2865 2879 2899 2824 2891 2843 2851 2834 2873 2893 2816 2822 2800* 2833 2874 2844 2895 2841 2813 2823 2842 2831 2835 2892 Miscellaneous Industrial Organic Chemicals Plastics Materials, Synthetic Resins Miscellaneous Industrial Inorganic Chemicals Akalies and Chlorine Industrial Gases Cyclic Crudes and intermediates Miscellaneous Pesticides and Agricultural Chemicals Miscellaneous Chemicals and Chemical Preparations Synthetic Organic Fibers Adhesives and Sealants Surface Active and Finishing Agents Paints, Varnishes, Lacquers Pharmaceutical Preparations Nitrogenous Fertilizers Printing Ink Inorganic Pigments Synthetic Rubber Chemicals andAllied Products Medicinal Chemicals. Botanical Products Phosphatic Fertilizers Perfumes, Cosmetics, Toilet Preparations Carbon Black Soap and Other Detergents Industrial Gases Cellulosic Man-made fibers Specialty Cleaning, Polishing Biological Products In-vitro and In-vivo Diagnostic Substances Explosives 136 108 89 32 30 27 24 21 14 12 12 9 9 8 7 7 6 6 5 4 4 3 2 2 2 1 1 23.4% 18.6% 15.3% 5.5% 5.2% 4.6% 4.1% 3.6% 2.4% 2.1% 2.1% 1.5% 1.5% 1.4% 1.2% 1.2% 1.0% 1.0% 0.9% 0.7% 0.7% 0.5% 0.3% 0.3% 0.3% 0.2% 0.2% * May include research and development facilities, or plant reported general code instead of specific SIC. CMA Hazardous Waste Survey VVV 000004773 page5 Generation and Management This section begins with an overview of generation and management from the 1988 survey. Following the overview are mote detailed descriptions of the management practices for hazardous wastewater and hazardous solid waste. The 1988 survey divided hazardous waste into two categories, solid waste and wastewater, even though every hazardous waste under RCRA (Resource Conservation and Recovery Act) hazardous waste The survey divides wastes Into two categories-- solid waste and wastewater regulations is first defined as a solid waste. This was done because the volume of wastes that are mostly water, are much larger the ocher type of wastes that are more typically thought of as solid (including sludges and nonaqueous liquids) and mask any trends in these latter wastes. The survey respondents were asked to put their hazardous waste into these two categories. Because many solid wastes contain water, there has been confusion for some respondents about the category to which a particular waste should be assigned. To avoid confusion, the 1988 questionnaire defined wastewaters as wastes that are treated by an NPDES permitted treatment plant, discharged to a Publicly-Owned Treatment Works (POTW), wastewaters that are disposed by Wastewater la defined here aa wastes treated by an NPDES plant or sent to a POTW, underground injected wastewaten, and other aqueous wastes. underground injection, and any other aqueous waste the respondent would view as a wastewater. This definition was solely for the purpose of categorizing responses to the survey -- it does not represent a regulatory distinction. In the case of POTWs, even though they must also have NPDES permits, they are called out separately as a management practice. Satidawute, defined here as all other hazardous wastes not fitting the survey definition of wtewater, is not intended to be consistent with EPA's RCRA definition of solid waste. wT-arrinns solid waste by the survey definition, is referred to in the report tables as solid (non wastewater) waste. Hazardous solid waste plus hazardous wastewater (both as defined here) equals die sum total of waste defined as hazardous under RCRA and those added in state regulations (state only). Since the 1985 survey, respondentshave been allowed to separate underground injection disposal into either solid waste or wastewater categories, frior to 1985, both solid waste and wastewater could be reported as underground injected, but only as a lumped quantity. The quantity of solid waste reported as underground injected, however, has typically been a very small percentage of die total quantity of solid waste generated and has little impact on the comparisons between surveys. Al' ... CMA Hazardous Waste Survey 88----------- ---------------------------------------page 6 VVV 000004774 Generation end Management Prior Co 1985, recycled wastes were not defined as RCRA solid wastes and therefore were not in the pre-1985 surveys as hazardous wastes. These recycled wastes added significantly to the total hazardous solid waste generation during 1986-1988 where large quantities of recycled wastes were reported by only a few plants. The recycled wastes have caused large fluctuations in the trends of hazardous solid waste since 1985. In many cases, these wastes had been generated prior to 1985. Their abrupt appearance in 1985 or later, (later-- in the case ofa state adopting the revised definition after 1985), following the broadening of the solid waste definition, causes an apparent increase in the generation of hazardous solid waste. To add to the erratic nature of this category, plants may receive variances for these wastes under 40 CFR 260.30, and the recycled wastes drop out of the generation quantities in subsequent years when this happens. These situations are noted in this report where they affect the interpretation of the data. CMA Hazardous Waste Survey VVV 000004775 page 7 Generation and' Management Overview A general overview of the 1988 survey data is presented here in Figure 2 and Table 3. The detail of the data in section of Table 3 is discussed in later tables of the report Total Generation The 582 survey respondents reported generation of 219.9 million tons of hazardous waste in 1988. As shown in Figure 2, this total consists of: 213.2 million tons hazardous wastewater, and 6.7 million tons hazardous solid waste. Zero or Less Than 0.5-Ton Generators Of the 582 plants reporting, there were 86 plants (15 percent) that either did not generate any hazardous waste or generated less than 0.5 tons (see Appendix Bfor listing by SIC). CMA Hazardous Watte Survey 83 page 8 WV 000004776 6aBsd *7.7*00000 AAA ^ AvunsWM 9nopjmz8H mo 10'0 zoo GEO SCO SCO 96'l 6E00 90 E'6 99 908 ffO Z*66 OE 07.6 tzs'gi 987`Zfr ESZ*8ZZ frZfr'EW 017*99/. 9ES`Z8Z> 681*98 906`Z'1. Z9Z`89*`0Z 991*01Z>1 106*1Z1`ZZ1 pua-jeoA je efeiois uoipefuj punoj6j9pun lesodsia snopnzsquou oi pejB&Q jo paiejeupui Aj9aoo8j AQjeue joj peaing pojeAOoej/pesnaj/peujiBloe; |eusiBft 6uipXoa^ eiSBM P!IS pue-jeaA ve sSbjois niflo uojpefui punojGjepun (ai pe&iBipsip jbibm01SBm) MIOd jejBMaiseMsaadN JOlBMeiseM iuui#6suew 8697 t/'t zsg'm^iz Z9Z* 179*9 816*061'1Z 6QS8M 0)8)S S1SBMVH0U eiSBM ejeis pm vyOU sb pepjAipqns eiSBM P!|os janMBiseM 0JSBM pips PUB JBlBMejSEM SB pBpjAJpqnS uopBjeuao (SUO) 08L*Z98`6I>Z) PBIBJ9UBQ *s*M Plios pus JapMipiM (SUOl) Aiiiusno Z89 = iuB|d AaAjns jo nqumu |bio (s Biqei) M0fAJAO (8860 IuwimSwiw pu uonaiawo M9|AJ8AQ WMUMOvmvi pin UOHBMIMO Generation and Management Overview this page is intentionally blank *qq CMA W"wriail> Watte Survey page 10 VVV 000004778 Generation and Management Data Dfatrlbutions Data distributions are used here to show characteristics of waste generation in the chemical industry. From these distributions, one can see just how varied waste generation is within the chemical industry. They are also useful in showing what waste generation might be for an individual plant and what is typical for the majority of chemical plants in this survey. The variation in generation among the survey plants is extremely high. What the distributions show is that there are many plants generating little or no hazardous waste and a few plants generating very large quantities of waste. This type of data is therefore skewed towards the low generation rates. The survey data show that there are many plants generating little hazardous waste and only a few plants generating very large amounts of waste. A population of data with these characteristics is said to be skewed from the normal distribution. Conventional statistical measures such as die mean (or average) and standard deviation cannot be used with a skewed population distribution because they are misleading measures of central tendency and variability. The more appropriate statistic is the median, the value at which half of the plants generate more waste, and the other half of die plants generate less. As such, the mean waste generation rates are given in the text for information only. CMA Hazardous Waste Survey ,qq VVV 000004779 page 11 Generation and Management Data Distributions Figures 3 through 6 present the data distributions (as cumulative probability) of the hazardous generation of the 1988 survey plants. Figures 3 and 5 include all 582 plants reporting in 1988. Figures 4 and 6 include only those plants that generated greater than 0.5 tons of hazardous waste in 1988. The curves illustrate the skewed nature of the population of waste generation rates. The characteristics of the data distributions are consistent with the previous CMA hazardous waste surveys. Hazardous Solid Wastes Figure 3 shows that 50 percent of the plants generated less than 157 tons of hazardous solid Hazardous Solid Waste Qanoratton (1988) Ail Survey Plants Figure 3 waste in 1988 (median value). The mean value for hazardous solid waste generation was 11,463 tons in 1988. Sixteen (16) percent of the survey plants (93 out of 582) reported generating no hazardous solid waste or less than 0.5 tons. When only generators of more than 0.5 tons of solid waste are grouped. Figure 4 shows that 50 percent of these plants generated less than 285 tons of hazardous solid waste in 1988 (median value). The mean value for these plants was 13,643 tons per year. Hazardous Solid Wote BaiiaiaUunQM^ . . Only Plants with (teaster Than OSJiawa Figure 4 ___ CM4 Hazardous Waste Survey 88 ------------------------------------------------------------------- page 12 0 20 40 60 60 100 Cuairirtw PrabaMIty (%) VVV 000004780 Generation and Management Hazardous Wastewater Figure 5 shows that 50 percent of the plants generated less than 0.5 tons of hazardous Hazardous Wnlmtor Generation (IMS) ___ __________________All Survoy Plante____________ Figure 5 wastewater in 1988 (median value). The mean value for hazardous wastewater generation was 366,307 tons per year. The wastewater mean is equivalent to a 0.24 million gallons per day flow. Data Distributions Sixty-six (66) percent of the survey plants (385 out of 582) reported generating do hazardous wastewater or less than 0.5 tons. When only generators of more than 0.5 tons of wastewater are grouped. Figure 6 shows that 50 percent of these plants generated less than 38,050 tons of hazardous wastewater per year (median value). This wastewater quantity is equivalent to a 0.025 million gallons per day flow. The mean value for these plants was 1,082,187 tons per year. This wastewater quantity is equivalent to a 0.71 million gallons per day flow. . Hazardous Wastewater Generation (IWt) : : .______ Only Plente with Creator Then 0.5 Tom_________ Figure 6 0 20 40 60 60 100 Cumulative Probability (%) CMA Hazardous Waste Survey WV 000004781 page 13 i Generation and1 Management Domeatfe Sewage Exclusion The DSE excludes materials as solid wastes after they are mixed with domestic sewage (40 CFR 261.4(aXl)(u)) and treated at a POTW. Because a material must be defined as a solid waste before the determination is made that the material is a hazardous waste, the DSE effectively defines a material as nonhazardous at the same time that it excludes it from being defined as a solid waste. Survey respondents were asked to report those wastes that they did not include in their hazardous waste quantities because of the DSE. Such materials were not reported in this survey as hazardous wastes and are not included in any of die hazardous waste data shown in other tables of this report The data reported by plants in the 1988 survey were gathered in an attempt to gain insight into DSE practices. Twenty (20) plants of the 582 survey respondents reported discharging wastewaters to a POTW under the DSE. The total DSE wastewater reported by these plants was 11.3 million tons per year. As shown in Figure 7, twelve plants (12) reported discharging 1.7 million tons of wastewater that would have been hazardous by characteristic if not exempt under the DSE (IS percent of the total DSE wastewaters). Nine (9) plants reported discharging 9.6 million tons of wastewater that would hew beinliii lnlniii h.v fitrfnf ifnmnrmpTnnflrrthrP^iF Thr mrnnlil inrlulr ffrrrrf wastewater* wastewaters that are a mixture of a listed wastewater with a nonhazardous or dmcteristtcaUy-haz&dous wastewater, and wastewaters derived from a listed wastewater. CMA Hazardou* Waste Surveys '88 page 14 VVV 000004782 Hazardous Wastewater Because many solid wastes contain water, there has been confusion for some respondents about the category to which a particular waste should be assigned. To avoid confusion, the 1988 questionnaire defined wastewaters as wastes that are treated by an NPDES permitted treatment plant, discharged to a Publicly-Owned Treatment Works (POTW), wastewaters that are disposed by Wastewater la defined here as wastes treated by an NPDES plant or sent to a POTW, underground Injected wastewaters, and other aqueous wastes. underground injection, and any other aqueous waste the respondent would view as a wastewater. This definition was solely for the purpose of categorizing responses to the survey -- it does not represent a regulatory distinction. In the case of POTWs, even though they must also have NPDES permits, they are called out separately as a management practice. The POTW quantities do not include wastes reported by respondents under the DSE. This wastewater section begins with an overview of hazardous wastewater generation and management practices. Separate discussions of the treatment and disposal management practices then follow. CMA Hazardous Waste Survey ,qq VVV 000004783 page 15 Hazardous Wastewater Overview Table 4 is an overview of the hazardous wastewater generation and management practices of the 1988 survey plants, showing waste quantities and number ofplants in each category. In addition, the waste quantity in each category is shown as a percentage of hazardous wastewater generated by the survey plants. Generation 213.2 million tons of hazardous wastewater were generated Of this total, only a very small percentage remained in storage (0.04 peicent) awaiting treatment or disposal at the end of 1988. 99.2 percent of the hazardous wastewater was RCRA-defined hazardous waste. The remaining 0.8 percent was state-defined hazardous waste. 30.0 percent of the hazardous wastewater was hazardous by characteristic. The remaining 70.0 percent was hazardous by listing. Listed wastewaters contain nonhazardous wastes that were mixed with listed wastewaters (mixtures) and wastewaters derivedfrom listed wastes. 0.3 percent was generated by site cleanup activities from RCRA, CERCLA, or other remedial actions. ^ Tin ilmljii fiiim mm ii ii iin i iifiimmi itiir nln rrmimnd hafilim iranhnmii in Tulili 4 because it was repeated as a solid waste in the survey. Management Figure 8 shows the percentages erf hazardous wastewater that were treated and disposed. Wastewater treatment included NFDES and POTW facilities and other treatment practices. Disposal was by underground injection. f "" Hazardous Wastewater Management (1968) | 9.6% Disposed 20.5 million tons Figure 8 ___ CMA Hazardous Wmgto Survty 88 ------------------------------------------------------------------- page 16 VVV 000004784 Hazardous Waatewator (1988) Ovwvtow (Table 4) Hamtkw Wiitowilir Overview Quantity (tons) Generation Hg| Subdivided as RCRA and state waste RCRA State Subdivided as characteristic and listed Characteristic Listed/Mixture 211,551,340 1,639,578 63,941,771 149,249,147 Number of Plants Percent of Wastewater Generated (213,190,918 tons) 187 99.2 18 0.8 158 30.0 67 700 Management* NPDES wastewater POTW wastewater Underground injection Other treatment -- Storage at year-end Sits cleanup wastewater Site deanup wastewater included in above quantities from RCRA, CERCLA, or other remediai action 177,171,901 14,210,165 20,468,757 1,254,906 99 43 '33 50 83.1 6.7 9.8 0.6 85,189 16 0.04 nmiMi SWU.S^,--------- -- , 535,502 21 0.3 * Sludge from wastewater treatment that remained hazatdoue wee reported as a eotid waste. CMA Hazardous Waste Survey VVV 000004785 page 17 Hazardous Wastewater Treatment Table 5 is a summary of the hazardous wastewater treatment practices of the 1988 survey plants, showing waste quantities and number of plants in each treatment category. These categories am further divided into those that are company-owned by the survey plants and commercial facilities. Waste quantities are also shown as a percentage of hazardous wastewater treated by the survey plants. As shown in Table 5,90.4 percent of the hazardous wastewater generated by the survey plants was treated (192.6 million of 213.2 million tons). Treatment practices included: NPDES permitted facilities: discharge to a POTW; and chemical, physical, biological, incineration, and combinations of the same. 86 percent of the wastewater discharged to POTWs was treated prior to discharge to the POTWs. Of the total hazardous wastewater treated, 98.7 percent was treated in company-owned facilities (91.8 percent NPDES facilities, 6.2 percent POTW, and 0.7 percent other methods). Commercial facilities treated the remaining 1.3 percent (0.1 percent NPDES facilities, LZpwcentPOTW, and 0.04 percent other methods). Figure 9 shows the percentages of the different treatment practices for hazardous wastewater from this survey. Hazardous: Wastewater Treatment (1988) 0.7% Other treatment 1.3 million tone -chemical, physical, biological, Incinaratlon, and combination of these methods 7.4% POTWs 14.2 million tons (66 percent of this wastewater was treated prior to discharge to the POTW.) 91.9% NPDES 177.2 million tons Figure 9 CMA Hazardous Waste Survey '88 page 18 wv 000004786 Hazardous Wastewater (1988) Trsstmsnt (Table 5) ' Total................................ Wastewater Traatsd (192,636,972 tons) 'NPDES............................................ Tanks only (387 on-site tanks) Wholly/panfaJly in impoundments Total NPDES Tons % total wastewater treated Company-Owned FadUtiee Tone Number si Plants :i=^ 27,186,904 149,747,753 176^34657 91.8% 62 27 Hazardous Wastewater Trsstmsnt Commerdai Facilities Tone Number of Plante 50,555 166,689 237,244 0.1% 15 3 68% of tha total POTWdfachargaa was traatadprior to diacharga to tha POTW Tanks only (115 on-site tanks) Wholly/partially In impoundments Total POTW Tons % total wastewater treated 11,689.176 ' 301,117 11,990,293 6% ' Ottier Treatment Chemical Physical Biological Incineration Combination of above methods Not specified Total Other Treatment Tons % total wastewater treated 461,046 1,824 0 240,921 401,069 73,760 1,178,640 0.7% Treatment Totals Traatad wastawatar is 90.4% of total hazardous wastawatar ganaratad. Tons % total wastewater treated 190,103,590 98.7% 30 2 9 1 0 8 2 5 1.761,299 458,573 2,219,872 1.2% 10 4 2,117 1,367 13 1,270 14,626 56,873 76,266 0.04% 2 5 2 7 5 6 2,533,382 1.3% CMA H*zmrx$oum Wamto Survey VVV 000004787 PSfl6l9 Hazardous Wastewater Disposal--Underground Injection Table 6 is a summary of the hazardous wastewater disposal practice of underground injection of the 1988 survey plants, showing waste quantities and number of plants for facilities that are companyowned by the survey plants and commercial facilities. Waste quantities for company-owned and commercial facilities are also shown as percentages of hazardous wastewater underground injected. to shown in Table 6,9.6 percent of the Hazardous wastewater generated by the survey plants was underground injected (20.3 million of 213.2 million tons). 93.0 percent of this wastewater was injected at company-owned facilities. The remaining 7.0percent was injected at commercial facilities. Hazardous Wastewater (1983) Disposal--Underground Injection (Table 6) Total Waatewater Underground Injected (20,464,787 tone) Company-Owned FaotUtlee Commeralat Faeiltiee Ton* Number ( Plante %Total Waata Injected s Tbna IHil i of Plant* %Total Waate Injected Wastawatar that is underground Injected is 9.6% of total hazardous wastewater generated. 19.045.794 24 93.0% 1.422,963 13 7.0% CUA Hazardous Waste Survey oo - paps' 20 - VVV 000004788 Hazardous Solid Waste (Non-Wastewater) The following section on hazardous solid wastes details the management practices of the 1988 survey plants. These summaries specifically exclude all hazardous wastes that are defined as wastewaters in this survey.. This solid waste section begins with an overview of generation and management practices. Separate discussions of these individual management practices then follow: recycling, treatment, and disposal. CMA Hazardous Wasto Survey 9qq VVV 0000047S9 page 21 Hazardous Solid Wasta (Non-Wastawater) Overview Table 7 is an overview of the hazardous solid waste generation and management practices erf the 198S survey plants* showing waste quantities and number of plants in each category. In addition, the waste quantity in each category is shown as a percentage of hazardous solid waste generated by the survey plants. Generation 6.7 million tons erf hazardous solid waste were generated. Of this total* only a very small percentage remained m storage (0.2 percent) awaiting treatment or disposal at the end of 1988. 98.8 percent of the hazardous solid waste was RCRA-defined hazardous waste. The remaining 1J2 percent was state^defined hazardous waste. 1.6 percent of the hazardous solid waste was from site cteaapaanmies from RCRA* CERCLA* or other remedial actions. The sludge from wastewater treatment that also remained hazardous is included in the generation quantity in the table. It was 9.6 percent of die hsardous solid waste generated. Management Figure 10 shows die percentages of hazardous solid waste that were recycled, treated* and disposed. Recycling faHtufad material reclamation/teese/recovery and burning for energy recovery. Treatment included incineration and other treatment methods. Disposal included landfills, surface impoundiraits* waste piles* underground injection (of liquids), and other disposal methods. Hazardous Solid Waata Management (1988) 12.6% Treatment 0.M million tons Incineration other treatment ii.s% Disposal 0.77 million tons -landfill -surface Impoundment Figure 10 ... CMA HMzardou* Waste Survey '88 ----------------------------------- -------- page 22 VW 000004790 Hazardous Solid Waata (Non-Wastewater) Hazardous Solid Waste (Non-wastewater) (1988) Overview (Table 7) Overview Quantity Number (tons) of Plants Percent of Solid Waste Generated (6,671,262 tons) Generation* RCRA State 6,593,242 78,020 455 115 988 18 Management Material redaimed/reused/recovered Burned for energy recovery Incineration Other treatment Landfill Surface impoundment Waste pile Underground injection Other disposal 4,282336 758,710 680,949 162,525 451,810 185,556 40,896 42,785 49,969 Storage at year-end >^g^^^^9SS4^^^IBe9ClttgCac:^^e!KS3^Sag^^in rBnnnnpitipiWfi]ffinrmnririMgSg?I^^SBSg^^ Site cleanup solid wast+ Site cleanup solid wastes included in generation from RCRA, CERCLA, or other remedial action 15,524 104,803 201 643 178 11,4 343 102 84 Z4 292 68 6 28 1 0.6 20 0.6 10 0.7 WM 10 02 ViMiWa S/Mj, 99 15 * Sludge from wastewater treatment that remained hazardous was reported as a solid waste. This sludge (639,7$$ tons) represents 9.6% percent of the total hazardous solid waste generated. CMA Hazardous Waste Survey VVV 000004791 pegs 23 Hazardous Solid Waste (Non-Wastewater) Material Reelaimed/Reused/Recovered Table 8 is a summary of the hazardous solid waste material reclamation/reuse/recovery practices of the 1988 survey plants. These wastes do not include hazardous solid waste that was burned for energy recovery (see Table 9). Table 8 shows waste quantities and number of plants for facilities that are company-owned by the survey plants and commercial facilities. Waste quantities for company-owned and commercial facilities are also shown as percentages of material reclamation/reuse/recovery. Of the material reclaimed/ieused/recoveredL 98.0 percent was recycled at company-owned facilities. The remaining 2.0 percent was recycled at commercial facilities. The majority of recycled waste was recycled in company-owned facilities. On average, the larger volume wastes were recycled in company-owned facilities. The frequency of plants using commercial facilities was more than 4 times that of company-owned facilities. More than 95 percent of the material reclaimcd/rcused/recovered was generated by oneplant If the largest single waste is excluded from these recycled wastes, the reduced total is 0.171 million tons. On this reduced basis, 512 percent was recycled in company-owned facilities while 48.8 percent was recycled in commercial facilities. Hazardous Solid Waste (Non-wastewater) (1988) Material Reclaimed/Reused/Recovered" (Table 8) Company-Owned Fsdiitias " Commercial FacllHlee Tana Number of Plants %Total Materiel R/R/R- Number Totm- ol Plante %Total Malarial R/R/R" AilmitfHilfteWmitf rtuwd/ifCOVfd (tot* 4,282,536 tone) 4.199.012 37 Same as above without largest singIs waata (total 171.074 tons) 87,550 36 96.0% 63.524 175 51.2% 83.524 175 2.0% s 48.8% * Material tedsimed/reuaedfrecceered is waste recyded. minus those wastes tost are burned torenergy recovery. ~ Percentages era baaed on the total for that row. The first total (4,282,536 tons) represents the quantity reportedby sR the surveyplants. The second total (171,074 tons) is the same, but without the single largest wests. ___ CKtAHmzarctov* Weete Survey 88 --------------------------------------------------------- ----- page 24 VVV 000004792 Hazardous Solid Wasta (Non-Wattewter) Burning for Energy Recovery Table 9 is a summary of the hazardous solid waste burned for energy recovery by the 1988 survey plants. This table shows waste quantities and number erf plants for facilities that are companyowned by the survey plants and commercial facilities. Waste quantities for company-owned and commercial facilities are also shown as percentages of hazardous solid waste burned for energy recovery. As shown in Table 9,11.4 percent of the hazardous solid generated by the survey plants was burned for energy recovery (0.759 million of 6.67 million tons). Of the waste burned for energy recovery, 81.1 percent was burned in boilers, 11.7 percent in industrial furnaces, while the remaining 7.2 was burned in units not specified by the survey plants. Of the waste burned for energy recovery, 89.8 percent was recycled at company-owned facilities. The remaining 10.2 percent was recycled at commercial facilities. Hazardous Solid Waste (Non waatewatar) (1988) Burned for Energy Recovery (Table 9) Total Watte Burned tor Energy Recovery (758,710 tone) ComptnvQrmed Faoeiltta Tons Number of Planta %Total Waata Burned Commercial FaelHtiee Tone Number of Plants %TotaJ Waste Burned Boiler* 606,271 70 794% ........................................ ....... Industrial Fumaoea 624tso 1*6 - aant .v.y.%:.^:A^y.y.wAV.%y.wAy. 9,140 28,038 13 42 1.2% 3.4% Total* Burned tor energy recovery Wasfe burned terenergy moovery* 11.4% ot total hazardous eoUd waste generated. 681.627 85 89.6% 77,083 110 10.2% CMA Hazardous Wait* Survey VVV 000004793 page 25 Hazardous Solid Waste (Non-Wastewater) Treatment Table 10 is a summary of the hazardous solid waste treatment practices of the 1988 survey plants, showing waste quantities and number ofplants in each treatment categoiy. These categories are further divided into those that are company-owned by the survey plants and commercial feilities. Waste quantities are also shown as a percentage of hazardous solid waste treated by die survey plants. As shown in Table 10,12.6 percent of (he hazardous solid waste generated by the survey plants was treated (0.843 million of 6.67 million tons). Treatment practices included: incineration, physical, biological, thermal other than incineration, solidification, and combinations of these methods. Of the total hazardous solid waste treated, 89.3 percent was treated in companyowned facilities (72J percent incineration and 16.8 percent other treatment methods). Commercial feilities treated the remaining 10.7 percent (82 percent incineration and 2.5 percent other treatment methods). Figure 11 shows the percentages of the different treatment practices for hi irrtr-- wM waste from this survey. Figure 11 CMA Hazardous Wist* Survey '88 page 26 vw 000004794 Hazardous Solid Waal* (Non-Wastewater) Hazardous Solid Waste (Non-wastewater) (1988) i leauuem (Table 10) Treatment Total- Solid Waste Treated (643,474 tons) Company-Owned Facilities Tons Number of Plants Commercial Facilities Tons Number of Plante incineration Tons % total solid waste treated ' 611.806 72.5%- * Other Treatment Chemical Physical Biological Thermal Solidification Combination of above methods Not specified Total Other Treatment Tons % total solid waste treated 1 l4* v VtJ.V.J |J*V*V*V*V.V. 40,212 83,983 11 3,614 246 12,419 994 141,479 16.8% 105 6 4 3 3 2 7 4 69,143 8.2% 309 ................................ ..... .... ......... . ... 4,528 130 5,187 1,231 3,804 5,230 936 21,046 2.5% 17 2 3 3 12 10 8 Treatment Totals Treated solid waste is 126% of total hazardous solid waste generated. Tons % total solid waste treated 753,285 89.3% 90,189 10.7% CMA Hazardous Waste Survey ,qq VVV 000004795 page 27 Hazardous Solid Waste (Non-Wastewater) Disposal Table 11 is a summary of the hazardous solid waste disposal practices of the 1988 survey plants, showing waste quantities and number ofplants in each treatment category. These categories are further divided into those that are company-owned by the survey plants and commercial facilities. Waste quantities are also shown as a percentage of hazardous solid waste disposed by the survey plants. As shown in Table 11,11.6 percent of the hazardous solid waste generated by the survey plants was disposed (0.771 million of 6.67 million tons). Disposal practices included: landfill, surface impoundment, waste pile, underground injection, and other methods (physical, biological, detonation, ocean disposal, and combinations of these methods). Of the total hazardous solid waste disposed, 64.0 percent was treated in company-owned facilities (33.4 percent landfill, 24.1 percent surface impoundment, 5.3 percent waste pile, 12 percent underground injection, and less than 0.1 percent other methods). Commercial facilities treated the remaining 36.0 percent (2SL3 percent landfill, less than 0.1 percent surface impoundment, 4.3 percent underground injrrfrw. and 6.4 percent other methods). 3 Figure 12 shows the percentages of the different disposal practices for hazardous solid waste from this survey. Hazardous Solid Waste Disposal (1988) 58.7% Landfill n A9 million (ana 24.1% Surface impoundment 0.185 million tons Figure 12 5.5% Injection I 0.043 million tone 5.3% Waato pile 0.041 million tons 8.4% Other dispoaal 0.050 million tona CMA Hazardous Watt+Survoy '88 -- page 28 VVV 000004796 Hazardous Solid Waste (Non-Wastewater) Hazardous Solid Waste (Non-wastewater) (1988) Disposal (Table 11) Disposal CAI4 Hazardous Waste Survey ,qq VVV 000004797 peg*29 Hazardous Solid Waata (Non-Wastewater) Disposal this page is intentionally blank '88 CM Hazardous Waste Survey page 30 VW GQ00Q479ti Trend Analyse* Trend analyses in this report are based on two periods 1981-1988 and 1985-1988. The latter period was chosen became 1985 marked the year many recycled wastes became pert ofthe survey database. Plants were used in trend analyses only if they had responded every year during a trend period. There were 190 plants for the 1981-1988 trend analysts and 339 plants for the 1985 trend analysis. To emphasize the impact of recycled wastes during the 1985-1988 period, both the 1981-1988 and 1985-1988 trend groups were analyzed first with recycled wastes included and then without recycled wastes. The trend analyses often show sharp changes in hazardous waste generation and management because of the actions of a few plants with large wastes. These changes are highlighted because otherwise they tend to mask more subtle trends. For example, when EPA changed die definition of a solid waste in 1983, there was a large increase in hazardous waste reported as recycled. Other reasons can be changes in plant operations or differences in regulatory interpretation. These sorts of changes for the 1981*1987 period have been noted in previous survey reports. To highlight the most recent changes, a comparison of the current survey year with the previous survey year (1987-1988) is included in this report Since the 1986 survey, CMA has collected manufacturing production data from the survey respondents in an effort to normalize hazardous waste trends and to judge progress in waste minimization. As yet the use of production dau has not proved satisfactory for several reasons. The primary reasons appear to be the inherent variability between waste generation and manufacturing production and the relatively small number of plants on which to base trends. On this latter point the humber of plants is small because the evaluation must be cm a common basis -- on those plants that have provided data on generation and production for all years of the survey. CMA intends to continue to collect data, however, including production, to broaden the database so that it can be used to give perspective to hazardous waste generation--particularly in waste minimization and'overall trends far the chemical industry. In the following sections, the comparison of plants teat responded to both the 1987 and 1988 surveys is presented first Next the comparison of 1985-1988 trend plants is presented, and finally the 1981-1988 trend plants. CMA Hmzmrdotm Wmatm Survov VVV 000004799 pfle31 <* i Trend Analyse* 1987-1988 Comparison Table 12 is a comparison of plane that responded to both the 1987 and 1988 surveys (471 plane). Ie purpose is to highlight changes that have occurred since the 1987 survey, in particular, any unusual events that have affected waste categories. Categories for comparison are: generation, recycling, treatment and disposal. Storage at the end of the year is presented merely to provide balance in the numbers. Generation Total hazardous waste generation increased from 1987 to 1988 by 9.7 percent (19.0 million tons). Wastewater increased 10.3 percent (19.4 millioQ tons). Solid waste decreased 3.7 percent (0.4 million tons). These changes occurred because of the actions of a few plants with very large wastes relative to the others in a particular category. The reasons for these changes are given in the following sections. Recycling Recycling appeared to decrease by 10.6 percent because a variance from the solid waste definition was granted far ooe waste. Treatment Waste quantities treated m NPDES facilities increased 12.1 percent. The largest part of this increase was from a plant that aggregated hazardous and nonhazardous wastewater for common treatment Discharge to a POTW increased marginally by 33 percent Wastewater treatment by means other than in NPDES facilities or by discharge to a POTW decreased by 58.0 percent Most of this decrease came from two plants. Itineration increased 11.5 percent Solid waste treatment by means other than incineration was essentially unchanged (1.8 percent decrease). Disposal Underground injection increased 8.0 percent Most of this increase was from reclassification of one waste. Landfill disposal increased by 50.8 percent This increase is from cleanup wastes, primarily from impoundment closures and cleanouts. There were 278 plants common to 1987 and 1988 that landfilled hazardous waste. Of these 278 plants, the large cleanup wastes responsible for the landfill increase were generated by only 9 plants (3 percent of the 278 plants). For die rest of the 269 plants, landfilled wastes decreased by 12 percent from 1987 to 1988. Disposal by means other than underground injection and landfill decreased by 6.0 percent. This comparison excludes the 200,000 tons of cleanup waste from an impoundment in 1987. CMA Hazardous fflstto Surrey page 32 VVV 000004800 TrantfAoalyiM 1987*1988 Comparison Comparison of Hazardous Watts Generation and Management Practices for 471 CMA Member Plants Reporting in 1987--198& (Table 12) [1] [2,3] Generation Wastewater Solid waste Total generation 1087 1988 Percent Change from 1987 188.337 6.793 195.130 207.692 6.405 2144)97 10.3% 5.7% 9.7% Treatment [1] NPDES POTW discharge [4] Other Total wastewater Incineration Other Total solid waste Total treatment 155.671 12.148 2.298 170.117 0.530 0.163 0.693 170310 174.496 12346 0.966 188.008 0.591 0.160 0.751 186.758 12.1% 3.3% 56.0% 10.5% 113% 1.8% 8.4% 103% Disposal [5] Underground injection [6] Landfffl [2] Other Total disposal 18.235 0.287 0.294 18316 19.700 0.432 0.276 20.409 8.0% 50.8% 6.0% 63% Storage at yeanend 16.7% [1] Most of inerts** from on* pisrrt that aggregated hazardous and nonhazardous waste for common wastewater treatment [2] Exdudaa approtomatafy200,000 tons from daanout ofimpoundmant in 1997. [3] Decrease baeausa variane* as aoMd waste was granted to ona raeydad waste. [4] Most of daeraasa from two plants. [5] Most of incraaaa from radasadicalion of on* waste. [6] Incraas* from daanupwast* that was landfBMdin 1998 by loss than 10 plants. CMA Hazardous Waste Survey *vv 000004601 pags33 Trend Analytes 1985--1988 Trends Trends are discussed In this section mostly in the context of overall trends from 1985 to 1988 based on 339 plaits responding every year during this period. Where abrupt changes occur, these are also discussed to the extent that the reason is known or there is a plausible explanation These changes occurred because of the actions of a few plants wife very large wastes relative to the others in a particular category. Table 13 shows the 1985-1988 trends with recycled wastes; Table 14 shows these trends without recycled wastes. Generation (The solid waste generation excludes 200,000 tons of cleanup waste from an impoundment in 1987.) Wastewater generation increased 11.9 percent from 1985 to 1988. When recycled wastes are included (see Table 13), hazardous solid waste generation appeared to increase 230 percent from 1985 to 1988. When recycled wastes are NOT included in the trend analyses (see Table 14) hazardous solid waste generation increased 14.7 percent from 1985 to 1988*> Recycll ng (see Table 13) Recycled waste increased by a factor of nine from 1985 to1988 wheircwo plants added recycled wastes after their states adopted the 1985 HPA revised definition of solid waste in 1986. After 1986, recycled waste decreaied because a variance from fen ulii.1 waste definition was granted to one pint Treatment The quantity of wastes treated in NPDES facilities increased 13.7 percent from 1985 to 1988. Tire fluctuation in these wastes over this period was primarily the result of changes in the classification and management practices far one waste. Discharge to aPOTW remained essentially the same from 1985 through 1988. Wastewater treatment by means ocher than in NPDES facilities or by discharge to a POTW remained essentially fee same from 1985 through 1987. The decrease in 1988 was primarily from two plants. Incineration increased 93.1 percent from 1985 to 1988. The increases since 1985 have been primarily in wastes from a few plants. Solid waste treatment by means other than incineration decreased an overall 50.0 percent from 1985 to 1988. Most of the decrease that occurred in 1986 was when a plant changed treatment chemicals to render a waste nonhazardous. Disposal Underground Injection increased 8.1 percent from 1985 through 1988. Most of fee increase feast 1987 to 1988 was from the reclassification of one waste. ^ Landfill disposal was essentially unchanged from 1985 to 1987. A large increase from cleanup wastes occurred in 1988. Disposal by means other than underground injection and landfill decreased 25.8 percent from 1985 to 1988. This comparison excludes the 200,000 tons of cleanup waste from an impoundment in 1987. ___ CAM HMZMrtou* Watt* Sumy 88------------------------------------------------- page 34 VVV 000004802 Trend Analyeee 1985-1988 Trends Comparison of Hazardous Waste Generation and Management Practices for 339 CMA Member Plants Reporting in 1985-1968 (including recycle) (Table 13) ........... siSSiw&S& (million tone par year) Generation IU Wastewater ia.3] Solid male Total Qonoratton Recycling [3] (wee Table U lor tend* without recycled weatea) Treatment m NP0ES POTW dlocharge Other Total wastewater [*] IndneraBon [5] Other Total eolid watte Total treatment OISPOMI ` * -- UnOVfyullM n)0G8DTI [7] LandM 12] Other Total dltpotal Storage at year end 1SSS 1666 1887 1888 173.80 1.83. 17324 103.16 728 j00,tt 174.18 6.44 18023 184.43 6.02 20026 iliii 0.67 820 52S 4.68 AM 14821 11.60 1.10 16121 020 024 023 161.74 12.61 024 021 13.16 16822 10.47 1.07 18126 0.44 0.11 025 16121 140.88 1121 1.02 18220 020 0.13 023 183.13 168.62 1124 0.46 16022 0.56 0.12 0.66 16120 WW. A.AVM.W. .V., ..... : 1123 025 026 1224 11.70 026 026 1222 13.63 0.38 023 1424 J||i|||||||| 0.06 021 0.02 0.02 [1] Ructuetion* during 1985-1988period primeiCy bom change* in managementofon* was*. [2] Bxdude* approximately 200,000 ton* from deanoulofImpoundment in 1987. [3] FfuctmUon during 1985-1988 period from change* in ciuctScctcn ofa few large recycled name. {4] Inerea** from 1985 to 1988 from on* waste rodaaailedas hazardous. Increaae* in 1987and 1988 from aeverai plant*. [5] Moot of decree** from 19BS Id 1966 torn one plant that changed treatment Chornaia to render waale nonhazardott*. [6] Moot ofincreaae from 198710 1988 bom redaaaiication ofon* watte. [7] fdo*t ofincreaae bom 1987 to 1988 bom cleanup nmate diet emalaniJSIed by teeeralplant*. CMA Haxmadotm Wamtm Survmy ,gg vvv 000004803 ' page35 Trend Analyses 1985-1988 Trends this page is intentionally blank CMAHazarxfoas Waste Sunny '88 page 36 vw 000004804 TwndAinlytM 1986*1981 Trends Comparison of Hazardous Waste Generation and Mansflsmsnt Practical for 339 CMA Member Plants Reporting In 198S-1988 (excluding recycle) (Table 14) mmm (million tone per year) 1665 1986 1967 1988 Generation [1] Wastewater [2] Solid waste Total generation Treatment ti] NPOES POTWdtochaige Other Total wastewater PI Incineration W Other Total eoUd waste Total treatment 173.80 1.16 17437 193.18 1.08 19426 174.18 1.19 17837 194.43 1.33 196.76 148.51 11.60 1.10 161.21 029 0.24 0.53 161.74 169.82 10.47 1.07 16136 0.44 0.11 035 16131 Disposal [5] Underground injection [6] LandfiH PI Other Total dispose! Storage at yeer-MMl 12.61 0.24 0.31 13.16 11.83 035 026 1234 0.06 0.01 [1] Actuations during 1985-1988panodprimarify from changat mmanagamant ofona waste. [2] Exctudaaapproximataty200.000 tons from daanout ofimpoundmantin 1987. [3] Increase Item 1965 to 1968Pom one waste/ectesaflied a* hazardous. Increases in 1987end 1988 from severe/ plants. [4] Mott of decrease from 198S to 1986 from one pltnt that changad traatmantchamicat&ttr* render waste nonhazardous. [5] Most of incraasa from 1987 to 1988 from rodaaaihcatron of ona wests. [6] Moat ofincraasa from 1987 to 1988 horn daanup waste that was land/Madby several plants. CMA Hazardous Watto Survey ,qq VVV 000004Q05 psgs37 Trend Anily< Hazardous Wsstswatsr (1985-1988) The trends in waste quantities for die 1985-1988 trend yean shown in the top half of Figure 13 and have been discussed in the previous section on Tables 13 and 14. The lower half of the figure, which presents wastewaterquantities managed by different practices as a percentage of the total wastewater treated and disposed, is useful in showing any trends in wastewater management practices over the trend yean. Treatment As a percentage of wastewater treated and disposed for a given year Usage of NFDES facilities, POTWs, and ocher wastewater treatment methods has changed little from 1985 to 1988. Quantities treated in NPDES facilities were 85.4 percent in 1985 and 86.8 percent in 1988. Quantities discharged to POTWs were 6.7 percents) 1985 and 5.9 percent in 1988. Quantities treated by means ocher than in NPDES facilities or discharged to POTWs were 0.6 percent in 1985 and 02 percent in 1988. ^ Disposal As a percentage of wastewater treated and disposed for a given year Usage of underground injection has changed little from 1985 to 1988. Quantities injected underground were 7.3 percent in 1985 and 7.0 percent in 1988. ___CMA HszMrdou9 Wast* Survey 88 ----------- --------------------------------------------------- page 38 VVV OOOOOA8O6 Trend Analytes Hazardous Wastewater (1985-1988) ,1985-1988 Hazardous-Wastewater. Mavtag ement: Trends Data from 339plants reporting all 4 years | Millions of Tons per Year, Percent of Hazardous Wastewater Treated and Disposed 1987 Year 1988 Figure 13 1986 1987 Year 1988 CmrHaawtdoumWrnBf Survey ,qq VVV 000004307 page39 Trend* Analyses Hazardous Solid Waste (1985-1966) Hie trend* in waste quantities for the 1985-1988 trend yean are shown in the top.half ofFigure 14 and ham been discussed in the previous section on Table 14 which excluded recycled wastes. The lower half of the figure, which presents solid waste quantities managed by different practices as a percentage of the total solid waste treated and disposed, is useful in showing any trends in solid waste management practices over the trend years. The percentages exclude waste quantities that obscure trends. The excluded quantities are the impoundment cleanup waste in 1987 and recycled wastes in 1985-1988. Treatment As a of total solid waste treated and disposed for a given year (excluding an impoundment cleanup waste in 1987and recycled wastes in 1985-1988): Incineration has increased from 26.6 percent in 1985 to 43.3 percent in 1988 primarily because there were increases from a few large wastes. Without these wastes, the percentages incinerated for 1985 through 1988, respectively were: 1&234.1,24.2, and 24.0 percent. Solid waste treatment deerrltd from 22.4 percent in 1985 to 9.4 percent ialJM. Most of die decrease that occurred in 1986 was when a plant changed treatment chemicals to render a waste noohazardous. Disposal As a percentage of total solid waste treated and disposed for a given year (excluding an impoundment cleanup waste in 1987 and recycled wastes in 1985-1988): Landfill disposal was essentially the same from 1985 (222 percent) through 1987 (22.9 percent). In 1988, cleanup wastes increased landfilled wastes to 29.5 percent. Disposal by means other than underground injection and landfill decreased from 28.8 percent in 1985 to 17.8 percent in 1988. This comparison excludes the 200,000 tons of cleanup waste from an impoundment in 1987. ! CRMNBMdQtsllMeSUrvfy '00 page 40 VVV 000004806 Trend Analyses Hazardous Solid Waste <1985-1988) 1985-1988 Hazardous -Solid WasteManagement Trends Data from 339 piants reporting ait 4 years. Excludes recycled wastes in 1905-1988 and 200,000 tons deanup wastes in 1987. Millions of Tons per Year 1985 1986 Year Percent of Hazardous Solid Waste Treated and Disposed 100 1988 Figure 14 1985 1986 Year 1988 '88CMM!uMdam.W89t*GuNav VVV 000004809 page 41 Trend Analyse* 1981--1988" Trends Trends are discussed in this section mostly in the context of overall trends from 1981 to 1988 based on 190 plants responding every year during this period. Where abrupt changes occur m the intervening years, these are also discussed to the extent that the reason is known or there is a plausible explanation. These changes occurred because of the actions of a few plants with very large wastes relative to the others in a particular category. Table 15 shows the 1981-1988 trends with recycled wastes; Table 16 shows these trends without recycled wastes. Generation (The solid waste generation excludes 200,000 tons of cleanup waste from an impoundment in 1987.) Wastewater generation decreased 6.9 percent from 1981 to 1988. With the addition of recycled wastes to the hazardous waste definition (see Table 15), hazardous solid waste generation decreased 6.6 percent from 1981 to 1988. When recycled wastes arenot included in the trend analyses (see Table 16), hazardous solid waste generation decreased 35.7 percent from 198&A.198&. Recycling (see Tabu 15) Recycled wsstet first appeared in the survey in 1985 when BA revised itMfcfinition of solid waste, many recycled wastes subject to hn atdouj waste detanmation. In 1986, there was a large increase in therecycled quantity, primarily from one plant when its state adopted the revised solid waste definition into its hazanfaus waste regulations. Since then, the plant received a variance from the solid wastedefinition and it became nonhazaxdous, --tug the quantity of hazardous recycled wastes substantially from 1986 to 1988. Treatment The quantity of waste treated in NPDES facilities was essentially unchanged from 1981 to 1988. Fluctuations from 1985 to 1988 were primarily from changes in the classification and management of one waste. Discharge to a POTW decreased 66*5 percent from 1981 to 1988. The large decrease from 1984 to 1985 was primarily from ooe plantwhose wastewater was reclassified as nonhazardous. Wastewater treatment by means other than in NTOES facilities or by discharge to a POTW decreased 94.1 percent from 1981 to 1988. Indratkmtncreaseti64J percent from 1981 to 1988. '' Solid wasteeftmetbymets otherthan mcmeratiorrdecreased by 76.7 percent from 1981 to 1988. The increases since 1985 have been primarily in wastes from a few plants. Disposal Umferground injection increased by 7.0percent from 1981 to 1988. Most of the increase from 1987 to 1988 was from the reclassification of one waste. Landfill disposal decreased 28.6 percent from 1981 to a low in 1985. After 1985, landfilled wastes changed little until an increase in 1988 from cleanup wastes. Disposal by means other than underground injection and landfill decreased by 82.1 percent from 1981 to 1988. This comparison excludenshe 200,000 tons of cleanup waste from an impoundment in 1987. Ctt#Hmrmrk*m MWeStney w page 42 VVV 000004810 Trend Analyses 188t-1?8* Trends Comparison of Hazardous Watts Osnsratlon and Management Practices for 190 CMA Msmbar Plants Reporting In 1981-1968 (including recycle) (Table 15) (million tone par year) 1981 1982 1983 1984 1985 1986 1967 1988 Ganaration [1] Wastawatar (2,31 Solid waata Total ganaration Ml Racydlng [3] (saa Tabia 16 for fronds withoutracydad wastaa) Traatmant [1] NPDES M POTW diaeharga Othar Total wastawatar [5] Incinaration Othar Total aalfd mraata Total traatmant lSKilWlWlftiivi. Plapoaal [6] Undarground injacdon m Landfill [2] Othar Total cflapoaaf 172.51 1.62 174.33 NA 143.36 17.39 5.74 166.49 0.31 0.30 0.60 167.09 9.12 0.28 1.23 10.63 16834 124 160.48 NA 13536 19.66 6.01 160.94 0.22 0.22 0.44 161.36 B.33 037 034 9.94 172.07 0.95 173.02 NA 137.64 15.65 0.94 15433 033 0.16 0.39 15433 10.09 0.24 030 10.64 14331 0.90 144.11 130.17 1.50 131.67 NA 0.62 114.04 17.33 1.62 133.19 0.26 0.02 038 133.47 114.90 5.99 0.56 121.47 0.24 0.08 0.32 121.80 10.02 036 0.35 10.63 6.70 030 039 930 156.22 334 169.77 139.09 2.29 141.38 160.64 1.70 162.34 2.63 135 032 mmmM 14235 12437 5.30 5.76 0.87 0.83 148.42 130.87 0.40 0.46 0.05 0.07 0.45 0.63 146.67 ?g13i1.g4p05^ 144.72 5.83 0.34 150.90 0.51 0.07 0.58 151.47 731 031 034 836 834 034 034 8.72 9.76 0.34 0.22 10.32 [1] Fluctuations during 1985-1988 pariodprimarily from changaa m managamantof ona wasta. [2] Exdudaaspproximataly200,000 tons from doanoutofimpoundmantin 1987. [3] Fluctuation during 1985-1988 pariod fmmchangaainciasaitication ofa fswlargsracydsd wasta*. [4] Dacrassa from 1984 to 1985primarily from ona wasta radassdad as nonhazardous [5] Incraasa from 1965 to 196$ from ona wasta radaaatiladas hazardous. Inertasas in 1987and 1988 from savaral plants. [6] Most ofincraasa from 1987 to 1988 from radaasrfieabon ofona wasta. [7] Most ofincraasa from 1987 to 1988 from daanup wasta that was iandSladby savaral plants. CMMJimntou* W*9tmSiuv9Y VVV 00Q0G4811 page43 Trend ~ Analyse# 1981-1988 Trends :-U this page is intentionally blank K.j. C9M HSierdbcieWS-rSurvey- '88 page 44 VVV 000004312 Trend Analyses 1981-1988 Trends Comparison of Hazardous Waste Generation and Management Practices for 190 CMA Member Plants Reporting in 1981-1988 (excluding recycle) (Table 16) iliilH; IMMiMmmmmsM. (million tons per\rear) 1981 1982 1983 1984 1986 1986 1987 1988 Generation MHl jpjpjl tiiiiti [1] Wastewater [2] Solid waste Total generation 172.51 1.82 174.33 16824 124 169.48 172.07 0.95 173.02 143.21 090 144.11 130.17 0.68 131.06 15622 0.92 157.14 139.09 1.04 140.13 160.64 1.17 181.82 Traatmant . illllill llSPI [1] NPDES 14328 13526 137.64 114.04 11420 14225 12427 144.72 [3] POTW discharge 17.39 19.66 15.65 1723 5.99 520 5.76 5.83 Other 5.74 6.01 0.94 122 0.56 027 023 024 Total wastewater 166.49 16094 1M23 133.19 121.47 148.42 13027 15020 M incineration 02t 022 0.23 026 024 0.40 026 0.51 Other 0.30 022 0.16 0.02 0.08 0.05 0.07 0.07 Total solid waste Total treatment Disposal 0.60 0.44 029 028 022 167.09 16128 154.63 133.47 121.60 ilHll 11111111111 025 023 028 148.87 13120 15127 HI ** [5] Underground Injection 9.12 8.33 10.09 10.02 8.70 721 624 9.76 [6) Landfill 028 027 024 026 020 021 024 0.34 [2] Other Total disposal 1.23 10.63 0.94 9.54 0.30 10.64 025 10.63 0.29 9.20 024 826 024 8.72 0.22 10.32 1] Fluctuation* during 1985*1966periodprima/tybom changes in management of one waste*. 2] Excludes approxtmataiy200,000 tons from cleanout of impoundmentin 1967. 3] Decrees* from 1984 to 1985 primarily from one waste redassded as nonhazsrdous. 4] increase fmm 1985 to 1986 from on* west* reclassified a* hazardous, hcresses in 1987and 1988 from severalplant*. [5] Most of increase tom 1987 to 1968 from nciaaaMcatlon of one mate. [6] Most of Increase from 1987to 1988 tom deenup waste that was landfUled by several plants. CMA Hazardous Waste Survey VVV 000004813 page45 iB Trend Anelyno* Hazardous - Wastewater (1981-1988) The treads In waste quantities for the 1981-1988 trend yen are shown in the top half of Figure 15 and have been discussed in the previous section on Tables 15 and 16. The lower halfof the figure, which preseres wastewater quantities managed by different practices as a percentage of the total wastewater treated and disposed, is useful in showing any trends in wastewater management practices over the trend years. Treatment As a percentage of wastewater treated and disposed for a given year Quantities treated in NPDES facilities were 81.6 percent in 1981 and 90.1 percent in 1988. Quantities discharged to POTWs were 9.9 percent in 1981 and 3.6 percent in 1988. The quantity discharged to POTWs decreased in 1985, primarily because one plant had a wastewatcciw.Uttiifierl4s ncwiharairinwt m thatyear. This decrease in discharge to POTWs caused the percentage of waste (but not the quantity) treated in NPDES facilities to increase in 1985. Since these changes in 1985, the percentage usage of NPDES facilities has increased slightly and discharge to POTWs has decreased correspondingly. Quantities treated by means other than in NPDES facilities or discharged to POTWs were 3.3 percent m 1981. Since 1983, usage of treatment methods nthrr then NPDES and POTWs has remainedrelatiuely the same. Wastewater Disposal As a percentage of wastewatertreated and disposed fey a given year. Usage of underground injection has fluctuated between 4.9-7.0 percent from 1981 to 1988. Quantities injected underpound were 5.2 percent in 1981 and 6.2 percent in 1988. Comparison to 1985-1988 Group ot Trend Plants Although the group of trend plantrisdifferenrfor the peoodfcl98l-l988 and 1985-1988, both groups show the same trends fat'hazardous wastewater during 1985 through 1988 (see Figures 13 and 15for comparison of7985-/988period). . IH CMAHaxMrioumWuf-Sunfty '88 page 46 VVV 000004-814 Trend Analyses Hazardous Wastewater (1961-1988) <1981-1988*Hazardoua^Wastewater,MaireflementTrend8 Data from 190 plants reporting aU 8 years Millions ot Tons per Year Percent of Hazardous Wastewater Treated and Disposed Figure 15 CMAHaamdouaWaata Surmv '88 VVV 000004815 page 47 Trend Analyses Hazardous Solid Wasto (1981-1998) Tbe trends in waste quantities for the 1981-I9U trend years ire shown in the top half ofFigure 16 and law been discussed in the previous-aoahreon Table 16. The lower half of the figure, which presetts solid waste quantities managed byAfferent practices as a percentage of the tool solid waste treated and disposed, is useful in showreg any trends in solid watte management practices over the trend years. The percentages exclude,waste quantities that obscure trends. The excluded quantities are the impoundment cleanup wastem 1987and recycled wastes in 1985-1988. Treatment As a percentage of tool solid waste treatedand disposed for a given year (excluding an impoundment cleanup waste in-1987and recycled wastes in 1985-1988): Incineration was essentially die tares level to 1981 and 1982. Since 1982, there has been a steady increase in inrincrarion Mret of the increases in 1986-2988 have been from a few plants with large wastes. wwOther solid waste trritmrnf decreased from 14.0 percent in 1981 to 5.8 percent in 1988 Disposal . As a percentage of total solidwane nrnrri red disposed for a given year (excluding an impoundment cleanup waste in 1987and recycled wastes in 1985-1988): Landfill disposal has fluctuated between 13.0-29.7 percent from 1981 to 198^The recent increase in 1988 was the result of cfenup wastes. Disposal by means other than underground injection and landfill decreased from 38.4 percent in 1981 to 19.7 percent m 1988 with the largest decrease occurring between 1982 and 1983. This comparison excludes the 200,000 tons of cleanup waste from an impoundment in 1987. Comparison to 1985-1988 Group of Trend Plants Although the group of trend plants is differed to the periods 2981-1988 and 1985-1988. both groups show the same trends in hazardous solid waste during 1985 through 1988 (see Figures 14 and 16for comparison cf1985-1988period^ K / V: '88- page 49 VVV 000004-316 Trend Analyses Hazardous Solid Waste (1981-1988) 1981-1988 Hazardous Solid Waste Management Trends Data from 190 plants reporting ati 8 years. Excludes recycled wastes in 1985-1988 and 200,000 tons cleanup wastes in 1987: Millions of Tons per Percent of Hazardous Solid Waste Treated and Disposed 100 Figure 16 CMA Hazardous WasteSurvey VVV 000004817 page 49 VVV 000004818 Hinrtout Wit Owwiilon by SIC (1988) Group Numbor Description Industry Numbor Tons Numbor ot Plants Tons Numbor of Plants 280 Chemical manufacturing (general) 2800 Total SIC 280 62.308 62,306 22.710,776 [5] 22,710,776 [2] 281 Indusirial fhdrgsnie chemicals 2812 2813 2816 2819 Totatr SIC 281 282 .......... Plastlo matorlals and synthetic rosins, synthotlo rubber,' synthotle ond othor man-mads fibers, except glass 2821 2622 2823 2624 Total 8IC 262 73.133 86 54,016 190,614 317,681 . [98]. 314.239 .12,561 4,114,883 11,440 4,453,123 [122] 20.001.243 6,678 1.376,310 7.414.762 28,798,993 6,041,102 830,827 0 1,955,213 8,827,142 [44] [39] 2833 2834 2838 Total* SIC 263 284 Soaps, dotorgonts, and clsorting propsrations, perfumes, cosmetics, and othor toilot propara tlons 2841 2842 2643 2844 Total SIC 284 6,261 56,185 91 62,537 [15] 3.811 2,795,911 0 2,799,722. [4] 3 25 2,505 224 2,757 [16] 0 242 18 24 284 [3] CMi/teanbiif VVV 000004819 fiiaviy page A-i Appendix A Hazardous West*. Generation by SIC (1988) 285 Paints, vamishss, iacqusrs, enamels, and allled products US'. Industrial organic chemicals 2851 35,980 14,325 Total SIC 28S 35,930 [11] 14,325 [7] yskapaais miiMimmmm&v:.,, ....... 2865 2866 Total SIC 266 66,482 1.358.940 1,425,422 [166] 8.133.672 k. 134,387.381 I4r,i6,ns3 [7i] 267 Agricultural ehamlcals 2673 2874 2679 Total SIC 267 5,271 144 292,102 297,617 ** [31] 0 0 7,427,491 7,427,491 [16] 2 89 Miscellaneous chemical products 2891 2892 2693 2895 2699 Total SIC 266 2,344 1,165 230 11 10,069 13,919 [39] 329 634 16 0 90,153 91,132 [12] Total for all SICs 6,571,262 [466] 213,160,616[167] *'H > ' - * . * 6 .3 ar= page A-2 VVV 000004320 k Appendix B Zero or Lees Then 0.5-ton Generators by SIC (1988) VVV 00000*821 Appendix B Zero or Leee Than 0.5-ton Generators by SIC (1988) Standard Industrial Clwlflcrtten Group Number Description Industry Number 2 80 Chemical manufaeturinQ (general^ 2800 Total SIC 280 Number of Plante Between Zero and 0.5 Tona Generation itai 281 Industrial Inorganic chemicals 2812 2819 Total SIC 281 5 27 32 282 Plastic materials and synthetic resins, synthetic rubber, synthetic and other man-made libera, except glass 2821 2822 Total SIC 262 m&MSmm 283- Drug$. 2831 2834 Total- SIC- 283 15 1 16 264 Soaps, detergents, and cleaning preparations^ perfumes, eoametlee, and other toilet preparations 2841 2843 Total SIC 284 CHW Wnmtea Wait* Survey Wy 000004822 page B-1  I ft Appendix- B Zero or Loss Than 0.5-ton Gsnsrstors by SIC (1988) mmm"SSnS^rtlSSiS^riS^CUiStflcaBBoSri Group Number Description ' Industry Number 286 Industrial organic chemicals 2865 2869 Total SIC 286 287 Agricultural chemicals 2873 2874 2879 Total SIC 267 289 Miscellaneous chemical products 2891 2893 2895 2899 - Total SIC 289 Number of Plants Between Zero and 0.5 Tons Generation 1 9 10 3* 1 6 10 3 1 3 4 11 Total for all SICs 86 CMAHazardou*W9St*Sun*r~~ '88 page B-2 WV 000004823 f Appendix C Blank Copy of 1988 CMA Waste Survey WV 000004824 < -, A <: Table ofCoitunu 1988 CMA Waste Survey Hazardous-- Nonhazardous Confidential Information Parent Company Name- _______________________________________________________ if facility was purchased in 1988 from a different company, please give SELLER-COMPANY name BELOW. This allows us to keep track of plans and their code numben from year to year. Seller-Company Name ____ ______________________________________________ Subsidiary Name _____________________________________|________________ Plant Name and Address . EPA Identification No. Contact Name Title Telephone Number *; ' * . < * - * ^ - 'Hi.- . __________ : : WP). We encourage you to make a thorough and complete response to this questionnaire. CMA staff and CMA's contractor, Tischler/Kocurek (TK), will be reviewing your responses and contacting you to clarify any ambiguities. The confidential information will not be released to anyone outside CMA or TK and cannot be accessed by other CMA member companies. Please CALL Dianna Kocurek of TK, Round Rock, Texas, at 512.244.9058 if you have any QUESTIONS regarding this questionnaire. Completed surveys should be RETURNED to; r Completed Dianna Kocurek Tischler/Kocurek 116 East Main Round Rock, Texas 78664 call... ' ? vi ... .jj. 09? ^ r Q* uestions^9. 79 Surveys To bo completed by TK: CMA Code No:__ Date Received: -- T VVV 000004825 .4 1988 CMA Waste- Survey Hazardous -- Nonhazardous Table ofContents CMA Introductory Letter Confidential Information Introduction.............................................. ............................ .................. Page 1 _ Instructions 1. Plant Description A. Plant SIC Code ............ 4 B. Plant Location .................................................... 4 Hazardous Wasto 2. Hazardous Waste Generation A. Hazardous Solid Waste..................................... 6,8 B. Hazardous Wastewater ............................ ........ 10,12 C. Domestic Sewage Exclusion......................... 14 3. Hazardous Solid Waste Management A. Treatment--Hazardous Solid Waste............. 16 B. Disposal -- Hazardous Solid Waste .............. 18 C. Reclaimcd/Reuscd/Recyclablc-- Hazardous Solid Waste.......................... 20 4. Hazardous Wastewater---Management ................. 22 5. Hazardous Waste--UndergroundInjection .......... 24 6. Production Basis .......................................................... 26 7. Calculation Check--Hazardous Waste ................. 28 8. OTC--Organic Toxidxy Characteristic................... 31,32 9. Corrective Action ......................................................... 34 Nonhazardous Wastes 10. Subtitle D--Nonhazardous Wastes A. Generation and Management Practices........... 37,38 B. Surface Impoundment Inventory .................... 40 '"'tv Questions 5 5 7,9 11,13 15 17 19 21 23 25 27 29 33 35 39 41 ..'.-^1 ForlKusofrilolephone folioi 4* .) vvv 000004826 Introduction 1988 CMA Wane Survey Hmtxrdous--Nonitatarxieta Assurance of Confidentiality Each plant is given a code number on the bottom right-hand comer of the cover page and on eacbpageof the survey. The cover sheets are removed and placed in a confidential file. Thus, the survey can be processed without identifying a plant by name. Following completion of the project, the cover sheets will be retained in a separate, confidential file. CMA and TK have carefully established this system for your protection in the belief that the responses to this survey will be more candid and complete once the respondent has been assured of confidentiality. Please contact JIM MULLIGAN or CMA to inquire about confidentiality or intent of this project. His telephone number is 202.887.1270. introductory Note CMA needs accurate and complete information about generation and disposition of both hazardous and nonhazardous waste by the chemical industry. CMA needs this information for legislative and rulemaking advocacy, for evaluation of the Environmental Protection Agency's ongoing regulatory impact analyses, and for analyzing industry-wide trends. The goal is to establish a comprehensive in-house data base by continuing this survey on an annual basis. General instructions Please read the instructions on the page facing each set of questions as these instructions will explain what information is needed, as well as give definitions and notes related to the questions. Briefly review all the questions before beginning. That way you will save time if you know in the beginning what kind of information you need to answer the questions. Some - naprovide lotherrecpmresents. V*"* * , * , - ... r. . * r You may PRINT rather than type your answers -- in fact, we recommend it to save you time.. Please print neatly, though, and in INK or BALL POINT because pencil often does not copy well. ;. Responses to the survey questions should correspond to 1988 calendar year records and practices. Do NOT include any INVENTORY (wastes left irtstonge at the end of a calendar year, awaiting treatment or disposal) from previous years in your responses. VVV 000004827 1 Introduction 1988 CMA Wast* Survey Hazardous--Nonhaxardoua Definition of a Plant/Only SIC 2800 Plants Only SIC 2800 industry plants need respond to this survey. An SIC 2800 industry is defined by the Bureau of Census as any plant whose largest source of revenue is from the manitfacture of SIC 2800 products. For this survey, a PLANT includes ALL SIC 2800 FACILITIES at one site, whether operated for manufacturing, waste management, research, or combinations of these purposes. Complete a surveyfor each SIC 2800 plant in the company... Each CMA member company should complete s SEPARATE SURVEY for EACH PLANT in the company. Companies may have a single individual, such as an environmental coordinator, respond for all or several of their plants, or have each plant respond separamiy. Numerical Responses Report waste quantities in TONS. These quantities must be reported AS HANDLED or AS IS tons -- sometimes also called WET tons. If you do not have actual weight measurements, give your best estimate; Give answers to the nearest ton. For your convenience, here are a few unit conversions:.; 1 ton * 2000 pounds 0.907 metric tons - 240 gallons If your answer is zero (0) for any question, you can either leave it blank or write down zero. Avoid Double-Counting Wastes axe subdivided into specific categorieun the survey (wastes that are treated, wastes that are disposed, etc...). The choke of category for a waste can be confusing, for example, if the waste is both treked and disposed -- this can lead to double-counting of waste quantities if the instructions are not followed exactly. To help you avoid double-counting (and having to contact you for clarification), there are CALCULATION CHECKS in Section 7 (hazardous waste) and Section 10 (nonh&zardous waste). Please complete these checks to verily that your numbers balance. On the next page is an EXAMPLE DIAGRAM of how hazardous waste quantities are categorized and how they should balance. Nonhazardous wastes are categorized and balanced in a similar fashion. VVV 000004828 2 Solid Hazardous Waste 2988 CAM Worn Survey Hasardous--Nonhamrdemi Incineration - 3,000 tons (on-site companyfacility) {SecJA} Landfill 3 tons (off-site commercialfacility) (SecJBJ fazardous. Wastewater 2,004,820 tons lSec2B) Recycle -150 tons (offsite companyfacility) (Sec3CJ NPDES treatment - 2,000,000 tons (on-site company tankfacility) {Sec.4] Injection - 4,800 tons (onsite companyfacility) (SccJJ Left in Storage 20 tons (onsite companyfacility) {Sec.7B.4j Example Diagram of How Hazardous Wastes may be Categorized for this Survey VVV 000004629 1. Plant Description Instructions 1988 CAM Waste Survey Hasardous--Nonhasardous A. Plant SIC Code ONLY SIC 2800 INDUSTRY plants should respond to this survey. An SIC 2800 industry plant is defined by the Bureau of Census as any plant whose largest source of revenue is from the manufacture of SIC 2800 products. Ifyour primary SIC code is NOT 2800, do not complete the survey. You may wish to notify your company environmental coordinator that the facility is not SIC 2800. SIC codes starting with 28 as the first two digits represent manufacturing of "Chemicals, Allied Products." SIC 2800 Codes - Chemicals, Allied Products * *.v $i 'X'V \*r 2812 Alkalies and Chlorine Industrial Gases 2813 Industrial Gases 2816 Inorganic Pigments 2819 Afire. industrial Inorganic Chemicals 2821 Plastics Materials. Synthetic Resins 2822 Synthetic Rubber 2823 Cellulosic Man-Made Fibers 2824 Synthetic Organic Fibers 2831 Biological Products 2833 Medicinal Chemicals. Botanical Products 2834 Pharmaceutical Preparations 2841 Soap and Other Detergents 2842 Specialty Cleaning, Polishing 2843 Surface Active andfinishing Agents 2844 Perfumes, Cosmetics, Toilet Pi 2831 Paints, Varnishes, Lacquers 2861 Gum and Wood Chmricals 286S Cyclic Crudes andfidmmdieees 2869 Misc. Industrial Organic Chemicals 2873 Nitrogenous Fertilisers 2874 Phosphatic Fertilisers 2873 Fertilisers. Mixing Only 2879 Misc. Pesticides and Agric. Chems. 2891 Adhesives and Sealants 2892 Explosives 2893 Printing Ink 2895 CarbonBlack 2899 Misc. Chemicals and Chemical Preps. i Plant Location A list of codes for STATES is given below. Alabama........ 01 Alaska ...........02 Arizona......... 03 Arkansas....... 04 California ......05 Colorado ....... 06 Connecticut ...07 Delaware....... 08 Wash., DC ....09 Florida.......... 10 Georgia ......... 11 Cetfstf' for 8totoo ^ .r Hawaii ............12 Idrie>................13 Illinois............ 14 Indiana ............ 15 Iowa ................16 Kansas ............ 17 Kentucky .........18 Louisiana.........19 Maine ............. 20 Maryland ........ 21 Massachusetts .22 Michigan__ ,_23 Minnesota ...~.~24 Mississippi ......25 Missouri ........26 Momma ...........27 Nebraska......... .28 Nevada ............. .29 . New Hanpshire 30 " NewJersey.......31 New Mexico .....32 New York ........ 33 cr North Carolina .34 North Dakota ...35 Ohio............ ...36 Oklahoma .......37 Oregon ........ ...38 Pennsylvania ...39 Rhode Island . ...40 South Carolina 41 South Dakota ..42 Tennessee .......43 Texas .......... ...44 Utah..............45 Vermont ....... 46 Virginia ........ 47 Washington ...48 West Virginia 49 Wisconsin .....SO Wyoming .....51 Virgin Islands 52 Puerto Rico ...53 VVV 000004830 4 1. Plant Description Questions 1988 CMA Waste Surety Hazardous-- Nonhasardous Enter the codes for your plant's primary 2800 SIC and the state in which your plant is located* - v- ' ^ A. SIC Code Cl] H your primary SIC coda is not 2800. ..do not complete thesurvey. You may. wishto noafyyourcompany envirmimtntal coordinator that tkefacility is notSIC2800. ............... B. State Code [2] ;C *aji*sw a,os `Tu'' .. - tf your facility did not ganarata anyhnardeus wastalirlSSSi. ...your survey responseustillimportcuutd CMA ^ is ustfid to knowwht ow many SIC 2800facilities did hot generate hazardouswaste: ffyoiidid not generate any hazardous waste in 1988~ . `r\ *' -.compiata'only tha following saettona In the survey: 1A.1B 2A(l)i 2B(1), 2C(l),2C(li) 8 9 10 VVV 000004831 Instructions 2. Hazardous Waste Generation 1988 CMA Waste Survey Haurtbus'--NoHhatardous A. Hazardous Solid Waste Do NOT foirfiMte WASTEWATER in this section (wastewaters will be counted in Section 2B). In this survey, wastewaters are defined to be wastes that are treated by an NPDES permitted treatment plant, discharged to a Publicly-Owned Treatment Works (POTW), WASTEWATERS that are disposed by UNDERGROUND INJECTION, or any other AQUEOUS waste which you would classify as a wastewater. For UNDERGROUND INJECTED wastes, these wastes may be counted as WASTEWATER or SOLID wastes, whichever is the common description at your facility. If you consider an underground injected waste as a solid waste, then it should be included in this section. 2 Do NOT include thefollowing wastes in this section: A Hazardous wastewaters A RGRA wastes which are not subject to full regulations ^under at provisions of 40 CFR 261.5 (conditionally exempt smaLLgemrutm ), or 40 CFR 261.6(a)(3) (selected recycled wastes) A Delisted waste* The following are descriptions of the different types of hazardous solid waste that you should count in this section. Recyclable Solid Hazardous Wastes Prior to 1985, RECYCLABLE wastes were exempted from full regulation at 40 CFR 261.6(a). However, due to the change in solid waste definition many of these wastes are now subject to some regulation. Review the current regulations at 40 CFR 261.6 and 40 CFR 266 (if these regulations are in effect in your state) to be sure that you correctly INCLUDE these recyclable wastes which were regulated in 1988. . Listed Solid RCRA Hazardous Wastes..including mixtures of a solid waste and one or more listed wastes RCRA listed solid wastes ancapecifically identified by Subpart D of 40 CFR 261: "Each Virp--waste listed in this Subpart is assigned an EPA Hazardous Waste Number which precedes tbe name ofthe woese.0 Any solid hazardous waste generated by your plant which can be defined hyiw rfrihrsr numbers should be included in responding to this question. listed wastes mixed with ocher solid wastes should meet the definition of hazardous waste in 40 CFR Subpart A, 261.3(a)(iii) and (iv). Also, INCLUDE RCRA listed wastewater TREATMENT SLUDGES or sludges resulting from the treatment of RCRA listed*wastes. Characteristic Solid RCRA Hazardous Wastes RCRA hazardous characteristic wastes exhibit one or more of the characteristics identified in Subpart C of 40 CFR 261. INCLUDE RCRA hazardous CHARACTERISTIC wastewater TREATMENT SLUDGES. State Solid Wastes RCRA allows states to adopt more expansive definitions or listings of hazardous wastes than those adopted by the federal government Include ADDITIONALwastes generated by your plant which were considered to be hazardous wastes ONLY by your STATE. Remember to INCLUDE all wastewater TREATMENT SLUOGES considered hazardous by your state. VVV 000004832 6 1988 CMA Waste Survey Haxardous--Nonhesardems Questions 2. Hazardous Wasta Generation A. Hazardous Solid Wasta Enter the TOTAL quantity of solid hazardous waste (RCRA and STATE) generated at your plant during the 1988 calendar year, EXCLUDING hazardous WASTEWATER and wastewaters which were underground injected. (i) TOTAL RCRA and state SOLID, hazardous waste __ , __. f [. ifytf ,tons (3) Of the total RCRA and state solid hazardous waste in 2A(i) above, enter the quantity of solid waste generated at your plant which was considered hazardous by STATE regulations ONLY, EXCLUDING state WASTEWATER and wastewaters which were underground injected. (ii) STATE only SOLID hazardous waste Stop! Ifyourfacility is in Texas, do not include. * ClassI NonHazardous.. wastes in your hazardous waste quantities. Count your Class I-NonHazardous waste in Section JO, __ tons [4] Of the total RCRA and state solid hazardous waste in 2A(i) above, enter the quantity of all solid hazardous wastewater treatment SLUDGES (RCRA and STATE). (iii) SOLID hazardous SLUDGES from wastewater treatment __ __ ,,tons [51 - ................... WV 0000G4833 7 Instructions 2. Hazardous Waste Generation 1988 CMA West* Survey Hazardous- Nonhaxardous A. Hazardous Solid Waste SIta-CJaanup Waataa Of the total solid hazardous waste counted in 2A(i), enter the quantity that was the result of RCRA, CERCLA, or other remedial action. Major Changam In Waata Quantltlaa You may have had a major change in your solid hazardous waste generation from 1987 to 1988, either in waste type or quantity. If this happened at your facility, please enter the decrease (or increase) in tons and add a brief comment for explanation. CMA uses these data in its trend analyses to explain abrupt changes in waste generation and management practices. Examples of these types of changes would be regulatory interpretation, process startup or shutdown, and delistings. m VVV 000004634 8 1. Questions 2. Hazardous Waste Generation 1988 CMA Wane Survey Hazardous--Nonharardous A. Hazardous Solid Wasta Enter the quantity of solid hazardous waste reported in Section 2A(i) that was the result of RCRA, CERCLA, or other remedial action. (iv) SOLID hazardous site-CLEANUP wastes _____ ___ ,______ ___ ,tons 16] {Didyour waste practices I change significantly since ITM_________ Enter the quantity of solid hazardous waste that was the result of a MAJOR CHANGE In WASTE PRACTICES from 1987 to 1988 (answer this question only if you consider the change major; you be the judge of what is considered major). If the change was an INCREASE in waste quantity, enter the quantity on UNE (1) below. If the change was a DECREASE in waste quantity, enter the quantity on UNE (2) below. If there was no major change in waste quantity, but the type of waste changed significantly, briefly explain the reason for the change below. (y) Major changes in solid hazardous wane quantities from 1987 to 1988 Line(l) . increase in . quantity' ' * '" __ '''' * 7 "tons [7] ` Line (2) DEcrease in __ _______, _____ _______ ___ ___ tons quantity -r*-*- - - - -x- id- 10* Please give a brief explanation if there was a major change in solid hazardous waste quantity or type from 1987 to 1988. [9] VVV 000004835 9 1988 CMA Wan* Sunny Hcaardous^Nonhaxardous Instructions 2. Hazardous Waste Generation B. Hazardous Wastewater Definition of Wastewater r // In this survey, wastewaters are defined to be wastes that are treated by an NPDES permitted treatment plant, discharged to a Publicly-Owned Treatment Works (POTW), WASTEWATERS that are disposed by UNDERGROUND INJECTION, or any other AQUEOUS waste which you would classify as a wastewavr. /vCf In this survey, wastewaters are defined to bdwastes that are treated by an NPDES permitted treatmentplant, discharged to a POTW, wastewaters that are disposed by underground infection, or any other aqueous wrote that yourfacility calls a wastewater. The following are descriptions of the different types of hazardous wastewater that you should count in this section. Characteristic and Listed Hazardous Wastewaters Of the total RCRA and STATE wastewater, enter how much is LISTED wastewater (or mixtures of wastewater with listed hazardous wastewater) or CHARACTERISTIC wastewater. If a wastewater is a listed waste or a mixture of a waste with a listed waste, but also exhibits a hazardous characteristic^), die wastewater should be counted only in the listed waste quantity; DO NOT DOUBLE-COUNT listed wastewater as characteristic wastewater. Characteristic hazardous wastes are defined in Subpart C of 40 CFR 261. Listed hazardous wastes are identified in Subpart D of 40 CFR 261. State Hazardous Wastewaters RCRA allows states to adopt more expansive definitions or listings of hazardous wastewaters than those adopted by the federal government Include ADDITIONALwastewaters generated by your plant which were considered to be hazardous wastewaters ONLY by your STATE. Be sure to include state hazardous wastewater fitting the survey definition of wastewater. excluded Waste* Do NOT include thefollowing wastes in this section.' A Hazardous solid wastes A RCRA wastes which are not subject to full regulations under the provisions of 40*CFR 26l.3(a)(iv) (mixture rule)A0 CFR 261.5 (conditionally exempt small generator)t or 40 CFR 261.6(a)(3) (selected recycled wastes) A Delisted wastes A 'Wastewaters that you do not count in your hazardous waste generation quantities because you believe it is exempted from such by the Domestic Sewage Exclusion (40 CFR 261.4(a)(1)(H)). Because there are several interpretations of the applicability of the Domestic Sewage Exclusion,pleisense the interpretation held at your facility. vvv 000Q04Q36 10 Questions 2. Hazardous Waste Gensration 1988 CAM Waste Survey Hazardous--Nonhasardous B. Hazardous Wastewater Enter the TOTAL quantity of all RCRA and STATE hazardous wastewater and underground injected wastewaters generated at your plant during calendar year 1988, Of this total, enter the quantity that was CHARACTERISTIC hazardous wastewater and the quantity that was LISTED hazardous wastewater. If a wastewater was a LISTED waste, but also had hazardous characteristics, include it only in the LISTED waste category below. If a wastewater was a MIXTURE of a waste and a LISTED waste, include it in the LISTED waste category. (i) TOTAL RCRA and state hazardous WASTEWATER,,tons [10] (a) CHARACTERISTIC RCRA and state hazardous wastewater,,tons [11] (b) LISTED/MIXTURE RCRA and state hazardous wastewater,,tons [12] Stop! Ifyourfacility is in Texas, do not include Class ! NonHazardous wastes in your hazardous waste quantities. Count your Class I-NonHasardous waste in Section 10. Enter the quantity of all hazardous wastewater and underground injected wastewaters generated at your plant that was considered hazardous ONLY by the STATE, and not under RCRA. (ii) STATE hazardous WASTEWATER _________ ,,tons [13] VVV 000004837 11 Instructions 2. Hazardous Waste Generation 1988 CMA Wax* Survey Hazardous--Nonhcaardous B. Hazardous Wastawatar Site-Cleanup Waatea Of the total hazardous wastewater counted in 2B(i)f enter the quantity that was the result of RCRA, CERCLA, or other remedial action. Major Changam in Waata Qumntitimm You may have had a major change in your hazardous wastewater generation from 1987 to 1988, either in waste type or quantity. If this happened at your facility, please enter the decrease (or increase) in tom-anri add a brief comment for explanation. CMA uses these data in its trend analyses to explain abrupt changes in waste generation and management practices. of these types of changes would be regulatory interpretation, process startup or shutdown, and delistings. VVV 000004838 12 Questions 2. Hazardous Waste Generation 1988 CMA Waste Survey Hazardous--Noahasardous B. Hazardous Wastewater Enter the quantity of hazardous wastewater reported in Section 2B(i) that was the result of RGRA, CERCLA, or other remedial action. (Hi) Hazardous site-CLEANUP WASTEWATERS, ______,tons [14] {Didyour waste practices I change significantly since I 1987? Enter the quantity of hazardous wastewater that was the result of a MAJOR CHANGE In WASTE PRACTICES from 1987 to 1988 (answer this question only if you consider the change major; you be the judge of what is considered major). If the change was an INCREASE in waste quantity, enter the quantity on UNE (1) below. If the change was a DECREASE in waste quantity, enter the quantity on LINE (2) below. If there was no major change in waste quantity, but the type of waste changed significantly, briefly explain the reason for the change below. (tv) Major changes in hazardous wastewater quantities from 1987 to 1988 Line(l) INcrease in quantity tons 115) Line (2) DEcrease in quantity tons [161 Please give a brief explanation if there was a major change in hazardous wastewater quantity or type from 1987 to 1988. (HI VVV 000004839 13 ! 2983 CMA Waste Survey Hazardous--Nonhanxrdous Instructions 2. Hazardous Waste Generation C. Domestic Sewage Exclusion (40 CFR 261.4(a)(1)(H)) Note: The waste you report in Section 2C should be waste you count as NONHAZARDOUS (and not frrfrHwrt in the hazardous wastewater quantities in Sections 2B(i) - (iv))under the Domestic Sewage Exclusion. There are several interpretations of the applicability of the Domestic Sewage Exclusion; piety use the interpretation held at your facility. In this section, enter die waste quantities that you l exclude from your calculation of hazardous wastewater generation by the.Domestic Sewage Exclusion. Place these quantities in die **iw***tw#. i +3^ 4* VVV 000004840 14 Questions 2. Hazardous Wasta Generation 1988 CMA Waste Survey Htnardotu--Nonhaeardata C. Domestic Sewage Exclusion (40 CFR 261.4(a)(1)(H)) renter the quantity of wastewater that was generated in calendar year 1988 that would be a listed or characteristic hazardous wastewater ifyou did not exclude it from the hazardous waste definition by the DOMESTIC SEWAGE EXCLUSION. If a wastewater would be a listed waste, but also would have hazardous characteristics, include it only in the listed waste category below. If a wastewater would be a mixture of a waste and a listed waste, include it in the listed waste category. Remember, the wastewaters that you exclude by the Domestic Sewage Exclusion should not be counted in your hazardous wastewater quantities in Section 2B(i^(iv). (i) CHARACTERISTIC RCRA and state Domestic Sewage . Exclusion wastewater,,_____________ _______ tons [18] (ii) LISTED/MIXTURE RCRA and state Domestic Sewage Exclusion wastewater,,tons [191 VVV 000004842 15 1988 CMA Warn Survey Hazardous--Nonhastrdotu Instructions 3. Hazardous Solid Waste* -- Management A. Treatment -- Hazardous Solid Wastes TrmatmenttoNonhazardous Level In this section, treated, wastes should be included ONLY IF SUCH TREATMENT MADE THE1 YtfASTE NONHAZARDOU3. (For the purposes of this surveyt INCINERA TION is considered a TREATMENT method, excluding any hazardous residues that were subsequently disposed--count these residues in Section 3B). Do NOT include waste which were treated and marf* LESS HAZARDOUS -- such wastes should be reported in Section 3B or Section 5. Wamtewater Excluded ______ Do NOT include WASTEWATER in this section. Wastewaters will be counted in Sections A and 5. Underground Injection Excluded Underground injection wastes should NOT be INCLUDED in this sectioarthese wastes will be counted in Section 5. Underground injection wastes are those injected through a. bored, drilled, or driven well; or through a dug well, where the depth of the dug well is greater ^ largest surface dimension. Subeurface Injection Excluded Subsurface injection wastes are those injected below the surface of the ground and which do not meet the definition of underground injection wastes (for example, landfarming wastes). Subsurface injection wastes should NOT be INCLUDED in this section as treated wastes; they are counted in Section 3B under waste disposal. Hazardous Residues from Incineration and Othar Treatment Excluded Any hazardous residue from incineration or other treatment that was separately disposed of should NOT be INCLUDED. For example, if an incineration residue was still considered hazardous and was landfilled, don't count the landfilled quantity in Section 3A -- count it in Section 3B. * Recyclable Western Burned In Bollerm end Industrial Furnaces Do NOT include any recyclable wastes that were legitimately BURNED in BOILERS or industrial FURNACES (wastes that had a heating value GREATER THAN 5000 Btus per pound); count these wastes in Section 3G If die waste was burned in a boiler, but had a heating value LESS THAN 5000 Btua per pound, INCLUDE the waste UNDER INCINERATION in Section 3A. Other Recyclable Wastes Excluded Do NOT include any other recycled/reused/reclaimed wastes which were handled as RECYCLABLE materials at 40 CFR 261.6 or 40 CFR 266 -- count these wastes in Section 3C. Fuel Blending Included -- Lees Then 6000 Btue per Pound If a waste with a heating value LESS THAN 5000 Btus per pound was blended with other materials for fuel and was burned, it should be listed under the INCINERATION category of this section. . VVV 00000*342 16 1988 CAM Waste Survey Hazardous--Nonhaxarctous Questions 3. Hazardous Solid Waste -- Management A. Treatment -- Hazardous Solid Waste Enter the quantity of RGRA and state hazardous solid waste treated under the following categories during the calendar year 1988. Do NOT include burning in BOILERS or industrial FURNACES of wastes with GREATER THAN 5000 Btus/lb, other RECYCLABLE wastes, WASTEWATER, UNDERGROUND INJECTION wastes (solid or wastewater), or HAZARDOUS RESIDUES from incineration or other treatment On-Site and Off-Site COMPANY-OWNED Facilities ("as-is" tons) COMMERCIAL Facilities ("as-is" tons) (i) Incineration ________ ,,_________ _____________ ,, 120] [21} (Incineration includes wastes wish LESS THAN 5000 Btua/lb that were burned in boilers or industrialfurnaces.) (ii) Other [22] Please give description of other treatment ' ____________ P4] (Examples: chemical, physical, biological, thermal, solidification, detonation) [23] [25] (iii) Total RCRA and state wastes for Section 3A,,__________________ _____________ ,,_______ [26] . [271 VVV 000004843 17 1988 CMA Waste Survey Hazardous--Nonhaxardous Instructions 3. Hazardous Solid Wasta -- Management B. Disposal -- Hazardous Solid Waste Wastewater Excluded Do NOT iwindg wastewater in this section. These wastes will be counted in Sections 4 and 5* Underground Injection Excluded Underground injection wastes should NOT be INCLUDED in this section; these wastes will be counted in Section S. Underground injection wastes are those injected through a bored, drilled, or driven well; or through a dug well, where the depth of the dug well is greater than the largest surfacedimension. Recyclable Waatee Burned In Boilers- end Induetrlel Fummcea Excluded Do NOT include any recyclable wastes that were legitimately NRNED in BOILERS or industrial FURNACES (wastes that had a heating value GREATER THAN 5000 Btua per pound); count these wastes in Section 3C Other Recyclable Waatee Excluded Do NOT include any other recycled/reused/reclaimed wastes which were handled as RECYCLABLE materials at 40 CFR 261.6 or 40 CFR 266 -- count these wastes in Section 3C. Subaurface Injection INCLUDE subsurface injected wastes in this section. Subsurface injection wastes are those injected below the surface of the ground and which do not meet the definition of underground injection wastes (for example, landfarming wastes). Surface Impoundmenta _ Whether materials were being treated, stored, or disposed of in a surface impoundment may involve close questions ofjudgment If the wastes were treated to a nonhazardous level, count the wastes in Section-3A. Wastes thatwere treated, butremained hazardous (or were not treated) were DISPOSED of in an impoundment if the owner or operator intended that the materials were to REMAIN there UPON CLOSURE -- include these wastes in Section 3B. If the wastes remained hazardous, but were only being stored in the impoundment for disposal later, the stored wastes are not included in either Section 3A or 3B, but may show up as storage in the overall waste ba1aT1<" in Section 7 -- if you've counted it in your generation for that year. Please put the waste in proper category -- treatment, storage, or disposal and toroid double-counting the waste. Waste Pllee As with surface impoundments that may have been used either for treatment, storage, or disposal, use your judgment regarding materials placed on waste piles. Please try to avoid double-counting. Hazardous Incineration and Treatment Realduea Any HAZARDOUS RESIDUE from incineration or other treatment that was disposed should be INCLUDED in Section 3B (if thescresidues remained hazardous after treatment, they should not have been counted in Section 3A). Farexamph^if an i nr in--fion residue was still considered hazardous and was lawdfifleH, fmwt i-wiim gnantity in this section. VVV 000004844 18 1988 CMA Wait* Survey Hatardous^Nenhaatrdous Questions 3. Hazardous Solid Waste -- Management B. Disposal -- Hazardous Solid Waste Enter the quantity of RCRA and state hazardous solid waste disposed under the following categories during the calendar year 1988. Do NOT include burning in BOILERS or industrial FURNACES of wastes with GREATER THAN 5000 Btus/lb, other RECYCLABLE wastes, WASTEWATER, or UNDERGROUND INJECTION wastes (solid or wastewater). On-Site and Off-Site COMPANY-OWNED Facilities ("as-isn tons): COMMERCIAL Facilities . ("as-is" tons) (0 disposal _____ _________________________ [28] (H) Surface impoundment disposal ________,________ ,________ (Hi) Waste pile disposal [30] ________,________ ,________ (iv) Other [32] disposal __ ______ ,______ ______________ Please give- . [34] description of other disposal ' (Examples:. biological, lauifarm, chemical). [36] M Total RCRA and state wastes -^ for Section 3B________ ,_________ ,_________ [38] [29] [31] [33] [35] [37] [39] VVV 00000*845 19 1988 CMA Waste Survey Hazardous--Nonhasardaus Instructions 3. Hazardous Solid Wasta -- Management C. Reclalmed/Reused/Rscyclable -- Hazardous Solid Waste Prior to 1985, RECYCLABLE wastes were exempted from full regulation at 40 CFR 261.6(a). However, due to the change in solid waste definition many of these wastes are now subject to some regulation. Review the current regulations at 40 CFR 261.6 and 40 CFR 266 to be sure that you correctly include these recyclable waste which were regulated in 1988. Boosed for Energy Recovery bettardtZ983, EPA developed a sham recycling enforcement policy that considered the burning of low heating value hazardous waste 0e$s than 5000--8000 Btu/lb) in a boiler or industrial furnace as incineration and subject to regulations under the inrintor aandards of Subpart O of Parts 264 or 265 (see 40 CFR 260.10 for the definition of-B&iler and industrial furnace ). On May 6, 1987, EPA proposed extensive regulations for the burning of hazardous waste in boilers and industrial furnaces (52 FR 16982). Vi Burning In Boilers end Industrial Furnaces In this survey, burning of any waste with LESS THAN 5000 Btu/lb heating value is counted as INCINERATION in SECTION 3A. EPA's proposed regulations would apply to burning in boilers or industrial furnaces irrespective of the heating value. However, to be consistent with past CMA surveys and EPA policy, only INCLUDE waste quantities in Section 3C if the heating value was GREATER THAN 5000 Btu/lb. Other Wastes Burned for Energy Recovery If you have a waste that was burned for energy recovery, but you do not know if it was burned in a boiler or industrial furnace, count this waste as other wastes burned for energy recovery. If the waste went to a fuel-blender, and you do not know the type of unit the blended waste was burned in, also count it as or other wastes burned for energy recovery. INCLUDE only those wastes with heating value GREATER THAN 5000 Btu/lb. Other Redatmed/Reuaed/Reeycted Wmmtem Enter the quantity of waste repotted in Section 2A(i) that was handled as a recyclable waste at 40 CFR 261.6 and 40 CFR 266, EXCLUDING any waste BURNED for energy recovery. VVV 000004846 20 1988 CMA Waste Sunny Haxodotu--Nonhiaarxknu Questions 3 Hazardous Solid Waato -- Managamant C. Reclalmod/Reused/Recyclable -- Hazardous Solid Waste Enter the waste quantities counted in Section 2A(i) that had a heating value of 5000 Btuflb or MORE and that were BURNED'for ENERGY RECOVERY. Count the waste as burned in a boiler, an industrial furnace, or other type of unit If you do not know the type of unit the waste was burned in, count the waste as Other, Section C(iii). If the waste went to a fuel-blender, and you do not know the type of unit the blended waste was burned in, also count it as Other, Section C(iii). On-Site and Off-Site . COMPANY-OWNED Facilities ("as-is" tons) COMMERCIAL Facilities ("as-is" tons) (i) RCRA and state wastes BURNED in BOILERS (ii) RCRA and state wastes BURNED in industrial FURNACES m RCRA and state wastes BURNED in OTHER units (or type of unit was mot known) [40) [42] [44) 1 [41] [43] [45] Enter the waste quantities counted in Section 2A(i) thatwere handled as recyclable wastes under 40 CPR 261.6 or 40 CFR 266, EXCLUDING wastes that were BURNED for ENERGY RECOVERY. On-Site and-Off-Site COMPANY-OWNED Facilities ("as-is" tons) COMMERCIAL Facilities ("as-is" tons) (iv) Other RCRA and state wastes that ________ ,,_________ _____________ ,, were reclaimed/ [46} reused/recycled (irrciwiing wastes burnedforenergy recovery) [47} VVV 000004847 1988 CMA Waste Survey Hazardous--NorOtatardous Instructions 4. Hazardous Wastmwater -- Management Definition of Wastewater In this survey, wastewaters are defined to be wastes that are treated by an NPOES permitted treatment plant, discharged to a Publicly-Owned Treatment Works (POTW), WASTEWATERS that are disposed by UNDERGROUND INJECTION, or any other AQUEOUS waste which you would classify as a wastewater. A POTW is any device or system used in the treatment of municipal sewage or industrial waste of a liquid nature which is owned by a State or municipality. In this survey, wastewaters are defined to be wastes that are treated by an NPDES permitted treatment plant, discharged to a POTW, wastewaters thbt are disposed by underground injection, or any other aqueous waste that yourfacility calls a wastewater. Wastewaters Excluded from this Section In this section, do NOT include hazardous wastewaters which were UNDERGROUND INJECTED; these wastewaters are counted in Section 5. Do NOT include wastewaters that you exclude from your hazardous waste generation quantities by the DOMESTIC SEWAGE EXCLUSION. Please note that any HAZARDOUS RESIDUE from treatment or pretreatment of wastewater that was separately disposed of should NOT be INCLUDED in your response to this question. These residues are counted as solid hazardous waste in Sections 2A and 3. Number of On-Site Tanks Only those tanks that were COMPANY-OWNED and ON-SITE at your facility should be counted. Do not count any tanks that were off-site at another company-owned facility to which you sent hazardous wastewater for treatment In counting the number of tanks, include those that were used for the treatment or storage of hazardous wastewater. Hazardous Wastewaters Discharged to POTWs In addition to the total waste you count as discharged to a POTW, enter the waste quantity that was TREATED prior to discharge to the POTW. * vvv 00GQ0A8A8 22 J988 CMA Waste Survey Hazardous--Nontoxardous Questions 4. Hazardous Wastewater--Management Enter' the quantity of RCRA and state hazardous wastewater (EXCLUOING UNDERGROUND INJECTION wastewaters and HAZARDOUS treatment RESIDUES disposedseparately) treated under thefoUowing categories during the calendar year 1988. NPDESu Facility (i) In tanks only On-Site and Off-Site COMPANY-OWNED Facilities ("as-isn tons) [48] i - (ii) Wholly or partially in impoundments [50] COMMERCIAL Facilities ("as-is" tons) [49] r- [51] (iii) Number of on-site tanks POTW - wastewaters discharged to a POTW (iv) In tanks only [Si [53] [54] (v) Wholly or partially in impoundments , [55] [56] (vi) Number of on-site tanks ________ [57] (vii) Of the quantity in (iv) and (v) above, enter the quantity of wastewater that was TREATED prior to discharge to the POTW. -- * * ' [591 Other wastewater management' methods (vm)Other methods Please give description of other methods (60) m Totala (ix) Total RCRA and state wastewater for_____ ______________ ,_________ _____________ ,, Section 4 [64] [61} [63] [65] VVV 000004849 23 2988 CAM Waste Survey Hazardous--Notthcoardotis Instructions 5. Hazardous Waste -- Underground Injection Definition of Underground Injection Underground injection of hazardous wastes means the injection of wastes through a bored, drilled, or driven well; or through a dug well, where the depth of the dug well is greater than the largest surface dimension. Underground infection of hazardous wastes is defined as the injection of wastes through a bored, drilled, or driven well; or through a dug well, where the depth ofthe dug well is greater than the largest surface dimension. Both Solid Waste and Wastewater Included In this section, INCLUDE both SOLID waste and WASTEWATER. Count the underground injected wastes as solid wastes or wastewater whichever is the description common at your facility. VVV 000004850 24 1988 CMA Waste Survey Hazardous--Nonhaaardous Questions 5. Hazardous Waste -- Underground injection Enter the quantity of RCRA and state hazardous waste disposed of by underground injection as solid waste and wastewater during the calendar year 1988. On-Site and Off-Site COMPANY-OWNED Facilities (nas-is" tons) COMMERCIAL Facilities ("as-is" tons) (i) Solid waste.____ ___,,__ __________________,, [66) [67] (ii) Wastewater (iii) Total RCRA and state waste for Section 5 ________ ,, ______ ______ ___ ___ ,, [68] ________ ,,_________ _____________ ,, [70] [69] [71] VVV 000004851 25 6. Production Baals instructions 1988 CMA Waste Survey Hazardous--Nonhtnardaus CMA believes that the hazardous waste survey database has shown decreases in waste generation by the rhgmioi industry since 1981. Critics such as the National Resources Defense Council, the Office of Toxic Assessment, and the National Public Radio have suggested that these decreases are merely the result of decreases in manufacturing and plant closings. CMA is asking for production data here to refine these claims. CMA has tried in the past to relate waste generation trends to production trends indirectly by other means (production ratios, U.S. Federal Reserve Board production indices). These methods have not satistified the critics who want to see a direct comparison of waste generation and production for facilities in the CMA database. Confidentiality The production data that you report will be kept confidential by CMA's contractor -- neither CMA or other member companies will have access to the data. You arcsoMkadsodiat names of actual products, only the total production for your facility. Any reporting-of the data by CMA will only be in summary form -- no single facility will be identified. Only Processes Generating Hazardous Waste Report your production numbers only for those processes that generated hazardous waste in 1988. You can report the production in any unit you wish (tons, pounds, millions of pounds, thousands of pounds) -- but please specify what unit you are using. VVV 000004852 26 4 r\ 1988 CMA Wm Sunny Hazardous Nonhaaanions -' v-iV'-r 6. Pro&uctfomBasis- OutsUone* Enter the total production of all processes that GENERATED HAZARDOUS WASTES. 1988 production V,fr * .'> . n>. -I Units - . ..[73] P*. < '*:% .... < . , .fc ** ... - `vstv** rr;l -..*tw *>' .* -.^i ? ^ * i-P . - UaM-^4. "V ' VVV 000004853 27 *k 1988 CMA Wasu Survey Hazardous Nonhatardeus Instructions 7. Calculation Check -- Hazardous Waste The purpose of this checksheet is to make sure that your numbers for hazardous waste add up correctly. In the early surveys, this check was not done and it caused quite a few headaches in working with the data. If your numbers do not add up correctly on the checksheet, it means that you have double- counted or mis-counted wastes in some part of the survey. If this happens, please go over the numbers you've reported in the survey once again. If your numbers don't add up when CMA's contractor looks at them, you will be called. And chances are that you've put all your worksheets away and will have to drag them out again when CMA's contractor calls you. So do yourself a fawia --d l littk your numbigs now. r- ThrrisksMbeMancmg-act works: Solid Waste Generation * Treatment Dlepoeai + Underground infmctad Burned for Energy Recovery Othmr Reelalmed/Reumed/Reeyelmble + Stormgo Wastewater Generation Treatment Underground Injected + Storage STORAGE in the above equations should be zero unless you actually had wastes left in storage as of December 31, 1988. If you had NO WASTES LEFT IN STORAGE at the end of 1988 and storage does not equal zero in the above equations, then you haven't counted your hazardous wastes'correctly in each section of the survey. If you did have WASTES LEFT IN STORAGE at the end of 1988, the storage numbers above should be a reasonable estimate of this amount Please make sure your numbers Balance I \This is an examplefor.... Hazardous Solid Waste Generation 12 tons Storage -1 ton Disposal 1 ton 9 M Recycle - 2 tons Ml Ml Injected - 2 tons Burned - 2 tons Treatment 4 tons VVV 000004854 28 * . -l a -i. . y.-W-t'. 1988 CMAWameSmue^ Hmm*m--hlmkmm*ea Questions 7. Calculation- Check--Hazardous Waste* Solid Waste 1. Generation _________ ,,_______ tons[74] lsee2A(i)J 2. Treatment _________ ,,tons [75] {seerowtotai3A/iii)J 3. Disposal _________ ,,tons [76] {stem total 3B(v)} 4. injection _________ , ______ ,tons [77] [see raw total 5(i)J 5 . Bum**, for Energy Recovery __ ___ ___ , ,tons [78] {set row toudsZlSf^mjJ '* 6 Other ReoialmedJReueesU ReoyoimMe*, _ __ ,_______________ __ tons[79} [see retv mmUlflfcJJ ^ 7. Sfors (as of12/31/88) __ ___ ___ ,,tons [80] {subtract lines 23A3 from Hue 1] Ifyou did not have any solid wastes which were generated m 1988 and left in storage as of December 31,1988, then line 7 should be equal to zero. Ifit is not, then please re-check your solid wastequantities in sections 2,3, and 5. If you had solid waste which was generated in 1988 and left in storage as of December 31, 1988, please check that the value on line 7 matches storage records for your facility, or is a reasonable estimate of the quantity of 1988 solid wastes left in storage. Wastewater 1. Generation _____ ___ ,______ ___ ,tons [811 {see2B(i)J 2. Treatment - . tOB*to21Istemioial4(ixil . 3. Injection __ ______ ,_________ ,__________ tons [83] {see rowtotal5(H)] 4. Storage(as cf12/31/88) _________ ,, ________ ,_________ tont(M. tsabmecslines23 y flem Until Ifyou dSdnot-hawaiiy wmewaterwhkh swfewHaiiat^indikft in storagwarof December 31,1988, their line-4 shouldbe-equaL to zero~ If it is not, then please re*check your wastewaterquantities in sections 2,4, and5. If you had wastewaterwhich was generated in 1988 and.left in storage as of December 31, 1988, please check that the value on line 4 matches storage-records for your facility, or is a reasonable estimate ofthe quantity of 1988 wastewaters left in storage. 1988 CMA Waste Survey Haxardous--Nonhaxardats f VVV 000004656 30 < -*.u 29S&CMWmM*Smr Instruction* 8. OTO -- Organic* ToxtcitjrCharmctariaUc tw - Background- - -v -- -- --------- ;------ Two yecuffl in its 1986 survey, CMA asked for infonnatioironEPA's Organic Toxicity Chaxactenstte<0TCJ tharEPA ptupoeetfln fao-1986MT* pi uyuauhPTC nunasiBanndwcteaa- about 40 organic th*ppa. projected contanmatuarof drinking watersnppjtoby these compounds, The waythe OTC would work wouldbe, if the'conceatntioiraf rf ^ a ww wt above these levels, that wastrwould be* RQIA hazardous wattestkg-wittrwatray if die concentration m the wastewater was aboyethcsclevels.it would also be a RCRA hazardous waste;- , Six months after the OTC levels ateidentified EPA must decide whether a ban on land-based levels. --v* -v -i ~++i- as.'oi*-?ov/oc-'.: - '' TVeataieayodOTC^liarBeiwitrtr*rsawBuiTVhn nurd in Tntnyrtw lemecfcthcarspecified ' levels so that tfae waster can then be haodkdn land-based units* If treatment capacity is not- available for an OTC-chaiaeteristic waste at the timeEPA issues its landbandecision; EPA may- delay the^banfora periodiof up to l7tns; CMAheonnr.i nedbocaa>eEPA does not haver adequatedatnootreatinrnrrspeatry fnr wssiesiHiai win hreemnOIOcfaaaBiBriidc.wastesmorders to make* well-informed decision. Of parricularcflfr.onto CMA is thetreatment.cspacity for incineration ofsolidwastes > - vV Since*June*198d EPA haschangedsomeofthchamanhealfocriterixanditsprojcctioiis of contamination in drinking watersupphes; Consequently, the OTC levels arc likely to change when EPA issues its final rule on this subject, probably in the fall of 1989. Therefore, CMA is asking for data in this survey to address these,changes^ Specifically, CMA is asking for 2 items: (1) the quantity of your wastethatwill become hazndous bytheOTC-characteristic; and (2) what method would you use to remove the land ban restriction from the waste. OrganteToxlcky Cha--rt--iiBcii I mmlm Urn iliu OTC fevelwahaww at the bottom of 4tibeBWIeMUtiael>eui|eBasnuwfrthaTCrfmm a liaiw Them*? levels are the Report Only Wastes*' That ire Nonhlamous Now^-IT your waste is already- a storage;or disposalfacility mfluenrpainfc I,,,, i^wumcnrthe.] the Baser Your Answers* on Current* CondltUmsw~Decidc if your waste is OTCefamcsniitfebasedopyourcungttcondkkTOnotwhatluypenedin 1988. .'VC Total OTC-Charsctorlstlc Wastes^Report the total amounted nonhazaidous waste that wouldbeOTC-chiractcrisiic --> ......... , o-.. . - .***<* ... .. \ ~ -V'*;* . . -- VVV G00004857 --tt-; 1988 CMA Wests Survey Hazardous--Nonhasattbus Instructions 8. OTC -- Organic Toxicity Characteristic OTC-charactsristlc Wastes Handled in Land-based Facilltles--Of your total waste that would be OTCcharacteristic, report the quantity that is currently handled in a land-based facility. Land-based facilities axe: landfills, surface impoundments, waste piles, land application units, and injection wells. Remember though, you should count the unit if waste is OTC-characteristic before it enters the land-based facility (see Point of Application ofOTC Levels). Alternate Handling MethodS~.Of your OTC-characteristic wastes haiwttrd in land-based facilities, choose alternate methods that you think you would likely use to meet OTC levels for these wastes. For each method you choose* report the tons of waste for which the method would beused. If you would use several methods for a waste, report the tons of this waste for each method. For example; if you would use both strippin^end biological treatment for 10,000 tons of wastewater, report 10,000 tons for snipping and 10,000 tons for biological treatment Also report what type of facility you would likely use for each alternate method -- a company-owned facility or a commercial facility. The company-owned facility can be either at your site (on-site) or elsewhere (off-site). You will have to use your best judgment for choosing alternate methods and facilities, based on your knowledge of the waste and facilities. If you have no idea what alternate method and facility type you would use for a waste, report the tons of this waste as Don't Know. Note: For this survey, assume that stabilization orfixation will not be an adequate method for organic constituents, unless you are certain it will workforyour waste. Jamiary-l98M)raftFlnaliRidar Organic Toxicity CharactsristiC'Concantrations^ mg/L benzene...................... 0.5 1.2-dichlonarftiane......... GJ carbon disulfide,............. 400.0 1,1-dichloroethylenc-------------0.7 carbon tetrwhloridft...............0J ' 2,4-dtoteotohMne.......... 0.1 rhinnimn*--------------------- 0.03 bepcachkx(aad is hydroxide)- 0.008 chlorobenzene........100.0 hezachlorobenrene ........ 002 chloroform--............. 6.0 hezachlorobofariiene.^...^..... 0.5 o-cresol* 200.0 hezachlorocthane.-.----------- 3.0 m-cresol*..--.....-..... -..... 200.0 isobutanol... ....................1000.0 p-cresol*.....-..... 2000 methyl ethyl ketone..... --.200.0 U-dichlorobemene....-- 300.0 nitrobenzeneI--___2.0 1,4-dichlorohemene..........- 7.5 pemachlorophenol..-._______ 1.0 phenol-.............................. 100.0 pyridine.......... .....................4.0 tetrichloroethylene................ 0.7 2^<46-te(racfaioropheno]__ 100.0 toluene.......................... 1000.0 trichloroethylene................... 0.3 2.4.5- trichlorophenol... ... 400.0 2.4.6- trichlorophenol........... 2.0 vinyl chloride........................0.2 rndpoewl C*jrKT,Mr?"nm ffT tPgffhfr enwiparad an a threshold nf 200.0 mg/I.. VVV 000004858 32 1988 CMA Want Survey Hasartbus--Nonhasardota Questions 8. OTC -- Organic Toxicity Characteristic On-Site and Off-Site COMPANY-OWNED Facilities COMMERCIAL Facilities ("as-is" tons) ("as-is" tons) (i) Total SOUP WASTE that would beOTC-characteristic_____ _________ ._________ [15] [86] (ii) Of the total in (i) above, the amount that is handled in land-based facilities [87] [88] (iii) Of the land-based total in (ii) above, the amount of SOLID WASTE that will be handled by Incineration--_____.___,____________ [89]..[90] puu^aUetiudsss,.[91][92] --other solids __ _, . , . --193] __. --|M> Reoseftecyde/redamation_____,__ ,,,[955. _ ______ .[9$] Solvent extraction _____,__ _,______ ___ fo?],_______ ______,[9g] Source reduction _____(_____ ___, [oo]. . --[1003 _ _,__________--[101] -- --[102] Wet air oxidation -- -- -- --__* -- -- --[103] -- -- -- --__ -- -- --{104] Other-please give ______,,[ios]..[i06] description here> prrrj png] Don't know _____,,[109].-[no] (iv) Total WASTEWATER that would be OTC-charactrristic_____,________ _ ________, M' .... [HU. . [U2] (v) Of the total in (iv) above, the amount that is handled in land-based fsnlitirs _____ ,._________ ___________ ,._________ , U131 [114] (vi) Of the land-based total in (v) above; the atimgntsofWASTEWATE>r thatwill be-handled by each of the following alternate methods: '* *''v Bkxreatment . _ _____^115) *__ -- -- tii6] Indneratioo--tiquitMm*l,,[H7].[ns] Reuse/recyde/reclaznatioo ,_______ ,_____ --4119].[120] Source reduction _.[1211 -- --[122] Strippingf/ar. mr. steam. me.)_ __. __ __ __ __ __ --[123] -- __ __ __ __._____ --[124] Wet air oxidation -- --* -- --__ _____ --[125J[126] Other-please give..\\zn__________________ .[128] description bere> p-rej t\%m Don't know _____ _ ._____.________ [131]____ *________ *________ [132] VVV 00000^859 33 9. Corrective Action Instructions 1988 CMA Watu S*r~y Haurdoma--NoHteardams Ifyou responded to the CMA 1986 Hazardous Waste Survey, this section will look familiar. In the 1986 survey, CMA asked for information on corrective action to be able to show the economic impact of EPA's corrective action program. After reviewing the dataf CMA felt that most survey respondents were underestimating the number of units that would need corrective action --possibly the idea ofcorrective action was still new at that time. CMA is revisiting this issue now that corrective action is morefamiliar to persons today to be able to update these economic impacts. Background The Hazardous and Solid Waste Amendments of 1984 greatly expanded authorities under RCRA for requiring corrective-action for releases of hazardous waste and constituents at facilities that manage hazardous wastes. A generator that has interim status or has been issued a permit after enactment of the 1984 amendments (November 8,1984) is subject to corrective action requirements ofRCEA section 3004(u) or 3008(h). Conversely, if a generator has a permit issuedprior lo November8,1984 (which has not been re* opened after that date) or is e generator evify, the genesamr is not subject to cexrective action it rpuwmrnM EPA has proposed, or is considering proposing, regulations that may bring-mch exempted generators into the permitting system and therefore, subject to corrective action requiretneinfc As example proposal is the Organic Toxicity Characteristic (OTC) (Section 8 of the survey). For this reason, CMA is requesting INFORMATION from ALL GENERATORS, even those that are currently not subject to corrective action requirements. In 1987, CMA conducted a major study to demonstrate to EPA and Congress that the corrective action program, if strictly and broadly implemented, would affect many solid waste management units at terrific costs to the chemical industry. The study estimated the cost of various cleanup remedies at various types of sites and applied these estimates to the aggregate number of waste management units of CMA members that were likely to be subject to corrective action, based on the responses to the 1986 survey. Your response to this question will augment the study results. In addition, CMA will utilize your responses in its legislative efforts on the corrective action proposal which will be issued shortly. To protect the CONFIDENTIALITY of your information, all data will remain coded and data for all the survey respondents-will be combined so that corrective action problems at individual facilities cannot be identified. Your response will not be exchanged or reviewed by ocher CMA member company personnel. Hazardous Waste- Pannit Status of Facility Check all that apply to the permit status of your facility (plant) with respect to hazardous waste: generator only, have a permit or interim status, don't handle hazardous wastes now, and will not be handling hazardous waste in the forseeabie future. Total Numbsr of Units Enr the-total>number of eacMype of.unit at your facility. Count all active, inactive, dosed units whether or not ibey ere under corrective action now. Number Requiring Corrective Action Of the total ******* of units of each type at your facility, enter the number that are, will be, or are expected to be subject to corrective action requiring physical remediation. Permit Statue -- Hazardous Waste Unite For all hazardous waste units REQUHBNG CORRECTIVE ACTION, enter the number of units that are permitted and those chat have interim status. The sum of permitted and interim status units should be the same as the number of units you counted requiring corrective action. Surface Area/Affeeted Area For all landfills, surface impoundments, land treatment units, and waste piles REQUIRING CORRECTIVE ACTION, enter the surface area in ACRES. For all other units, enter the land area in ACRES that would be subject to corrective action. VVV 000004860 34 I* 1988 GMA W Survey MI------ -------------------- -- r 9. Corrective Action Questions Hazardous Wasts Parvnlt Statua of Facility (check all that apply) Generator only Hazatdoos waste eennit or hucrim mini ~~~ Do oot hiadfe haatdou waste __ WiU doc be henrihiif knartoes waste in the foneeabte future Enter for fhf tJTWf frf U*iamrT hath Omm hand]toy hitwlwi wtt taA tfan-- h--the total number of units; the "***-- and size that era, will be, or era expected id be subject to conectiTe ectioa that will raquoe physical nHi*1*"; tui rtwi permit ttana of the hamdoea uniti raquirint cneractira action. Units Handling Total Hazardous^/asts Numberof Units* EXAMPLE Landfill" Impoundment Land treatment Waste Pile Incinerator Tank (above-ground) Tank (underground) Container storage Iniecdon wells Transfer stations Recycling units Uther*" (please give description ofother NumberRequiring Number ofCorrective Action Surface Area or Corrective Action Units with nurim Status? Permit? Affected Area** (acres) ) S1IMI Total. Number ef Units* EXAMPLE _________ igragan Impoundment I T end trestmwit 1 GometinaAction 4Snft' Aftender Requiring Corrective Action Surface Area or Affected Area" (acres) | Incinerator Tank fabove-ground1) Container storaee Infection wells Transfer stations Recycling units Other"* (please give description ofother ) Count ail active, inactive, aid closed muss whetherornot they are muter corrective action now. ** ForlandfUlt, ratface impoundments, landtreaonent units, and wastepiles* report the surface area ofthe acdve/inacthm units. For all others, report the lendarea that would besubjectto corrective action: For example, sewer Unas, cooling towers, and drainage ditches. VVV 000004861 35 1988 CMA Waste Survey Hazardous--Nonhaxardous VVV 000004862 36 -It 1988 CMA Wane Survey ffrimnirmr r/nnlWnnnfmif 1 0. Subtitle* D -- Nonhazardous^ Waatai Background Nonhazaxdou* wastes have recently received a great deal of attention from Congress, EPA, --- fiA lahriifg riw. tftllrf fwihlgm a Mtinnal iritig One major 1988 Senate bill would have required double linen for all wastewater ponds, regardless of the regulatory statin or quality of tte wastewater. EPA is expected to develop standards for industrial Criteria (proposed 33^133314; August 30,1988). 1 Nonhazardous wastes cover a wide variety ofwastes not defined as hazardous wastes under Subtitle C (Hazardous Waste Management) of die Resource Conservation and Recovery Act (RCRA). chiwiAmi manvfyr*11""** g*"*--** WmA TMgf r "i^nhararrlfm wanes, from waatewaten and wastewater treatment sludges to process wastes, contaminated soil, and plain trash.: .. ^ Congress has-already begun the RCRA reauthorizaion process; the emphasis in the hills mfrrwW^ri h K^n nr. nnnhianiflu.Mmt with new, mfna Urhi^itt Subtitle D (State or Regional Solid Waste Plans) of RCRA. CMA has very little specific data on * nonhazardous waste generation and management practices in the chemical industry for use in commenting on proposed legislation andEPA regulations. Hence, CMA is asking you to supply data in twokey xrtesi 1) nonharetdous waste generetion sad management practices and 2) surface inipnunHmwiw Giventhe expected legislative schedufefor RCRA zeauthorizatbn, the data obtained from this survey may be the only data available to support development of reasonable legislation. This may be CMA's best opportunity to affect the outcome. A. Generation and Management Practices Weetm HOT Clreared Here--In this nonhazardous waste section, do NOT include any wastes that are defined as HAZARDOUS under RCRA or by the state. Also, do not include any material* that are not considered RCRA solid wastes .when they, are recycled in certain weryrisec 40 CTR^26L2<c))) oc a^w^w^^Aat^^doj^cc^t^hazardous because Nonhexardouo Wastewater--use the same definition of wastewater found on page 10 of this survey. Here are examples ofnonharawtoua wastewaterthat you shouldinclude: noncontact ^teaPGTW~(PbblteiyOwnedTreattrient .ooaite^9u>fi&rite*.wa8jipufatere'^aaare recycled and are.notexcluded is wastes by 4ff(ilk z6n%k6rwastewatereJtirawould . hw4iwimderifae QiginkJojricity(^riftterisria(^^ were not hazardous in 1988 (see page 31 of ibis survey foe an of the OTCVTfce amount you report for noncontact cooling water is what you discharge, not.the volume you recycle over and over in the system. Nonhazardoua Solid WMte~solid wastes are any wastes that do not meet the definition of wastewater on page 10 of this survey. Here ire examples ofnonhazardous solid wastes that you should include: ash from coal burning (bottom ash/slag and flyash); trash and garbage; construction and demolition debris and nibble; wastewater treatment sludge; solid process wastes; contaminated soil; wastes burned for energy recovery in boilers, industrial furnaces, or other thermal units, or sent to fuel blenders; wastes that are recycled and are not excluded as wastes by 40 CFR 261.2(e); or wastes that would become hazardous under the OTC but vvv OQOOG^63 37 Instructions 1988 CAM Wane Survey Hazardous--Noniuaardous 1 0. Subtitle D -- Nonhazardous Wastes were not hazardous in 1988. Number of On-Slto Un/te-Count the number of on-site units used to treat, store, dispose, or recycle nonhazardous wastes only. Units you should count are: tanks: container storage areas; impoundments: landfills; incinerators; waste piles; boilers, industrial furnaces, or other thermal units; and land application or treatment areas. Do not count any sumps or ditches. Ifa unit handles hazardous waste as well as nonhazardous waste, do not count it. Ash end Noncontact Cooling Wstsr^Two types of nonhazardous waste covered in this survey are gmfn1*2**3in4 very large amounts -- ash from coal burning and noncontact cooling water. You are asked to report these wastes separately so that these large amounts will not overshadow the other wastes you report Waste Genetstion~M the top of each column, report the total waste you generated in 1988 for that type of waste. Wests Quantittee-SThc waste you report for each management practice should be only that waste generatedin 1988. Please do not count waste that was left over from years before separating die 1988 waste from previous waste, make your Management Practice*..Jor each nonhazardous waste, choose only one management practice that best describes how the waste was handled Yon may have some problemin choosing between the treatment and disposal practices when a waste has gone through both. For example, what practice do you choose for sludge from a wastewater treatment pTant? Use this general rule -- if a waste still must be disposed after treatment, put it in a disposal category. Notes: (1) NPDES--National Pollutant Discharge Elimination System. It refers to your wastewater treatment system (including treatment, storage, and storm water impoundments) that has a permit to discharge its effluent under the NPDES regulatory system. ` (2) POTW--Publicly-Owned Treatment Works, like your city's wastewater treatment plant It includes treatment, storage, and storm water impoundments. (3) Tanks Only--if the waste is treated in tanks ONLY. (4) Impoundments--if the waste is treated entirely or at least in part in a surface jtppnwMhwgHfr- Cotumn Totals and NumOors-Cfteek~.Total the numbers in each column. If the waste generation number at the top of each column is less, than the column total, you probably counted waste that-you had stored from previous,years. Please review the instructions in Waste Quantities MbovesBdconectyoui uumbers. Ifthewaste^generarionnuinberatthe top of each column is more the column total, ask yourself if the difference in the two numbers is die amount of waste you had left in storage at the end of 1988. If that sounds reasonable, day. If not, please check yournumbers again. Site Cleanup Westes~JO( the waste generation amount that you report at the top of each column, report the quantity of nonhazardous waste that was generated through RCRA, CERCLA, or otherremedial site cleanup activities. VVV 000004864 38 I Instruction* 1 0. Subtitle D -- Nonhazmrdoue Wamtmm 19U CMAWasU Survey B. Surface Impoundment Inventory -- On-site Only Each on-site surface impoundment that you report should be entered on a separate line of the inventory form. If your impoundments will not fit all on one page* copy the form and number your pages. If you do nothave answers for every item for an impoundment, leave the unknown item BLANK. Impoundment Jdentlfteetion^Thc identification columa is for your- purposes only so that you can keep track of which impoundments you have included in die inventory, the identification will not be entered into the database of this survey. l/#ag~.Choose all of the following usages that spply to describe each impoundment: NPDES--National Pollutant Discharge Elimination System. It refers to your wastewater treatment system (Including treatment* storage, and storm water impoundments) that has a permit to discharge its effluent under the NPDE5 regulamry system. POTW--Publicly-Owned Treatment Works, like your city's wastewater treatment plant. It includes treatment, storage, and sunn water impoundments. Disposal--where you intend to leave the waste when you no longeruse the disposal unit For example, a fly ash pond thatwill be drained and ripped with the ash remaining. An example that is NOT disposal-is a wmeaw treatment pond where sludge is removed from time to xmesmdfmnbe remaining sludge will be removed when the unit is no longer in use. Other--where noneof the above decriptioos fit the impoundment Ifo/uma--Give the capacity of the impoundment in gallons. If your records show volume in ft3, use the following conversion to gallons: UDfP - 7.48 gallons Type ot Waste HsndtedJFoux types of wastes are listed: noncontact cooling water, boiler ash/slag and flyash, other wastewater, and other solid waste. Choose all codes that apply to the impoundment. Liner Type~.Cboosc all of the following liner descriptions that now spply to the impoundment Concrete liner covering all sides and the bottom of the impoundment and where the joints have been sealed to stop leaks Synthetic finer---like one made of plastic or rubber material, one that is not concrete or clay Engineered day finer--where die clay has been brought in and compacted Natural clay liner--where the impoundment has been dug out in a clay soil or located in a depression with day soil; the clay soil that forms the bottom of the impoundment acts as a liner: - Other*-a liner that docs not meet any of die above descriptions None--the impoundment has no liner Ground Water MonftoringsuAtsswer yesif now there are wells specifically for ground water and measuring the groundwater level around the impoundment samples of the Wilt Handle OTC IWsetem Answer yes if the impoundment wiU be used for wastes that will become hazardouslythe GTC. Foranexpbnarinivof tfaeOTC,scepage31. Meets MTRa Mmr^Answer yes if the-impoundment currently nai double-liners, leak detection and collectionand ground watermonitoring equal to hazardous waste technology requirements. Changee Oimwi at OTtXxbooseooly ooeoftbefbUowing changes that apply because of the OTC: n*tr*pttmA tn UTP*--wwpnunrfmnnr will he teunfiaatl to meet MTR* Receive variance -- impoundment is expected to or will receive a variance from the MTR requirement under section 3004(oX2) or 3005(jX2), (3), (4), or (13) of RCRA. Replaced with Tank--impoundment will be replacedwith a tank Closure--impoundment will be taken out-of-sevice and dosed No change--no change is planned for the impoundment Change* before Effective Dete of OTC~Answer yes if, before the effective date of the OTC, the impoundment will be dosed or otherwise taken out-of-service, retrofitted to meet MTRs, receive a variance from the MTR requirement, or replaced with a tank. VVV 000004866 40 Vista Chemical Company 900 Threadneadle Houston, Texas 77079 (713) 588*3000 P.O. Box 19029 Houston, Texas 77224 Fax (713) 588-3236 November- 7, 1990 T06: JSR XF: 33-- Ms. Sandra L. Tirey Associate Director, Health Programs CMA 2501 M Street NW Washington, DC 20037 Dear Sandra: Attached is our reply form for participation in Phase II of the OECD High Production Volume Existing Chemicals Testing Program. Vista supports this program but has concerns about the potential cost. We realize that it is difficult to estimate potential costs at this time. However, our commitment is contingent on our presumption that based on the known low hazard of this material, actual testing costs may be relatively low. Sincerely, Thomas G. Grumbles, C.I.H. Manager Environmental Affairs dlj Attachment cc: J. D. Burns, R. D. Gamblin VVV 000004867 CHEMICAL MANUFACTURERS ASSOCIATION REPLY FORM - PAGE 2 PARTICIPATION IN PHASE II OF THE QECD HPV CHEMICALS PROGRAM COMMENTS: k'trir/rtctrirtrlfifiT'itifkieJt'kirjtirir-hifirir'trh'irJriftfklelrit Vista Chemical Company designates the following individual to serve as the lead representative for our company in the OECD program: Name: Title: Address \ GV'lom&'i cito.inb^S ^>\cf\CLa*a . fcin \i i.o a \ e.' Vc \ \JT^'l<\ CV\t*rv\cM sft. s { x 'nrtt Phone: Fax: 7l^-6 &B Till - S(d . This re ply form was completed by: Name: Title: Phone: \ V~\ofY\ Cv"i> 0~ CjJfLw . itI S Vr***iVrft1rfrVr-A:*-frtV-iV+A'* VrVfiVVriVVf* *itVri*f"fr Please return completed reply form by COB Friday, October 26, 1990, to: Sandra L. Tirey Associate Director, Health Programs Chemical Manufacturers Association 2501 M Street, NW Washington, DC 20037 202/687-1274 (phone) 202/887-1237 (fax) VVV 000004863 CHEMICAL MANUFACTURERS ASSOCIATION REPLY FORM PARTICIPATION IN PHASE II OF THE OECD HIGH PRODUCTION VOLUME EXISTING CHEMICALS TESTING PROGRAM Vista Chemical Company manufactures the following chemical and agrees to take lead responsibility for sponsoring it in the OECD HPV Existing Chemicals Testing Program: 1-Tetradecanol (112721) Vista Chemical Company prefers to use the following optiaa^to manage our activities in the OECD HPV Existing Chemicals Testing Program: (please check one) ./* ____ Option A: Our company will take lead responsibility for the chemical listed above, including data collection and testing, and will interact directly with EPA, which serves as the U.S. representative to the OECD. ____ Option B: Our company will take lead responsibility for the chemical listed above, including data collection and testing. We request that CMA establish a CHEMSTAR panel of individual producers of different chemicals to interact with EPA and the OECD on behalf of producers of these different chemicals. (The approximate cost to participants will depend on the number of companies and will be discussed with interested companies.) Option C: Our company is interested in forming a consortium of co-producers of the above chemical to share costs of collecting data and conducting testing. We request that CMA establish a chemical specific panel or augment an existing panel within the CHEMSTAR program. (The approximate cost to participants will depend on the scope of the program and will be determined by CMA and interested companies.) VVV 000004869 Surface Impoundment Inventory * Handwritten forms are OKAY, it is not necessary to type your data. 7AM Subtitle D (Nonhazardous Waste) Surface Impoundment Inventory K N-NPDES P-POTW E D-disposal Y O-other Surface Impoundment ID or Number Usage (Choose alt codes that apply) Enter volume in gallons Volume (gallons) C-noncontact cooling water A-boiler ash slaglflyash W-other wastewater S-other solid waste Type of Waste Handled (Choose all codes that apply) C-concrete S-synthetic liner E*engineered clay liner Unnatural clay liner O-other X-none Liner Type (Choose all codes that apply) N-/10 Y yes Has ground- water mon itoring? N-rw Y-yes N-no Y-yes Meets Will MTRs now? handle (double liners, leak OTC detection/collection, wastes? groundwater monitoring) R-will be retrofitted to meet MTRs V-expected to or will receive a variance from MTRs T-will be replaced with lank C-will be closed N-no change N-no Y -yes Changes because of OTC (Choose only 1 code) Before effective date of OTC, will be retrofitted, receive variance, replaced with tank, or dosed? 1998 CAM Waste Survey VVV 0 0 0 0 0 4 8 7 0 ' Ifyou need additional pages, copy thisform. Please number your pages ifyou have more than one page. Page____ of