Document vB1Rjyr7ngbwY5aVJYk8Nzay8

DOW CHEMICAL U.S.A. September 22, 1983 LOUISIANA DIVISION P. O. BOX 150 PLAQUEMINE, LOUISIANA 70764-0150 504 369-8000 J. R. Birdwell General Manager CAPITAL AUTHORIZATION - HAZARDOUS WASTE LANDFILL - LOUISIANA DIVISION This is a preliminary authorization request for $100M on a 51.25m project for the construction of a state-of-the-art hazardous waste landfill for the Louisiana Division. The current hazardous waste landfill in the Louisiana Division does not meet the state and federal requirements for per mitting such a landfill. New state and federal regulations require rigorous require ments be met before a final permit for a hazardous waste landfill is issued. These requirements include such things as impermeable liners, leachate collection systems, leak detection systems and double liners in some cases. The existing Louisiana Division hazardous waste landfill does not meet these standards and cannot be retrofitted to meet them. In addition, the Louisiana Division landfill opera tion is not consistent with the Dow U.S.A. Waste Disposal Policy dated June 30, 1982. The current'landfill operation was an item of major concern on a recent Dow internal environmental audit. The primary reason a hazardous waste landfill is needed in the Louisiana Division is for the disposal of incinerator ash from the Division's Hazardous Waste Incinerator. Approximately 4,000 tons per year of this waste is generated and it must be disposed of in a permitted hazardous waste landfill. In addition, there are a few hundred tons of other miscellaneous inorganic wastes which need disposal each year in a permitted hazardous waste facility. One option to building this new landfill would be to go off site with the waste to a local commercial hazardous waste facility. This is inconsistent with Dow policy on waste disposal and not desirable. Another option would be to transport the waste to another Dow location which has a good facility (i.e. Texas Division). This would involve putting hundreds of trucks per year on the road carrying hazardous wastes and the increased likelihood of a transportation emergency involving hazardous waste. AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY 07355? CONFtDFNTTAI. The cost of this proposed facility is still an estimate. Detailed engineering work has not begun and a final cost estimate will not be available for three to four months. Permitting of the facility cannot begin until after the State of Louisiana receives final approval from the U.S. EPA to run the entire RCRA (Resource Conservation and Recovery Act) program. The granting of this authority to the State of Louisiana is expected in December/ 1983. Permitting would be anticipated to take a minimum of six months which would allow for a 1984 - 1985 construction. It is antici pated the project could be completed by the end of 1985. In summary, the existing Louisiana Division hazardous waste landfill is inadequate, it is not possible to upgrade the current facility to meet state and federal regulations now in place. A new state-of-the-art hazardous waste landfill is required for the Louisiana Division to obtain a final RCRA permit and be consistent with Dow Waste Disposal Policy. The spending schedule for this project is as follows: $M 83 0 n 84 1 00 s t Half ) 84 nd Half) 300 85 850 Martin Environmental Control J. 'R. Birdwe11 sb T. P. Rozas DO 073558 CONFTDFNTT A l.